Privacy Policy
This Privacy Policy is meant to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) the policies and practices of Metron-Farnier Holdings Inc., and its subsidiaries and divisions (“Metron-Farnier” “we,” “our,” or “us”) of our online and offline practices regarding the personal data that Metron-Farnier collects, uses, and shares on behalf of end users (“Users”) of our smart water management platform (the “Platform”) accessed through our websites including www.metron-us.com, www.metron-farnier.com, www.metronsubmetering.com, and www.waterscope.us, and any other websites operated by Metron-Farnier (each, a “Website”) or using equipment, devices, meters, and systems provided by and on behalf of Metron-Farnier (“Equipment,” and the Websites and Equipment treated as a part of the “Platform” for purposes of this Privacy Policy). This Privacy Policy also applies to personal data collected directly through personal interaction and in the normal course of business. Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Metron-Farnier Terms and Conditions, located at [Hyperlink].
This Privacy Policy covers all personal data processed by Metron-Farnier, LLC; Transparent Technologies, Inc.; and Metron Sustainable Services, Inc. businesses, and their parents, subsidiaries, and divisions.
Metron-Farnier reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal data, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.
In some cases, we may act as an agent of the water utility or property manager that supplies you with water with which you have a customer relationship (the “Water Provider”). In such a situation, the Water Provider has engaged Metron-Farnier to provide Services to you. This Privacy Policy does not apply to the personal data that Metron-Farnier has collected on behalf and at the direction of your Water Provider. This Privacy Policy also does not apply to the non-personal data described below that is collected by, used by, disclosed by, or disclosed to your Water Provider. This Privacy Policy only applies to the person data for which Metron-Farnier determines the purposes and means of processing of such personal data. For more information about your Water Provider’s privacy practices please contact your Water Provider directly.
1.1. Personal Data. We collect personal data about you both online and offline in various ways when you use our Platform. “Personal data” as used in this Privacy Policy means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The personal data we collect allows us to offer our Platform in a personalized and meaningful manner. The following are the types of personal data we collect:
| Categories | Examples of Personal Data Metron-Farnier Collects | Processing Purpose Used by Metron-Farnier |
| A. Individual Identifiers and Demographic Information | A real name, postal address, online identifier, Internet Protocol address, email address, business address, business name, or other similar identifiers such as phone number, zip code. |
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| B. Commercial Information | Records of water management interactions with the Platform, Equipment, or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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| C. Internet of Network Activity | Browsing history, search history, Bluetooth information, information on an individual’s interaction with a website, application, or advertisement. |
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| D. Home Information | Information collected in connection with your home, building, or dwelling, home, building, or dwelling images, water management services received, service requests, and other home, building, or dwelling related information. |
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| E. Consumption Data | Water usage information from water management system and Equipment, flow measurement, temperature data, and Equipment settings, alerts, and goals. |
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| F. Inferences Drawn from Personal Data | Inferences regarding water use and behaviors. |
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1.2. Non-Personal Data. Personal data does not include:
- Publicly Available Data: Publicly available information from government records.
- Deidentified Information or Aggregate Information: “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Metron-Farnier has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. Non-personal Deidentified Information and Aggregate Information may be combined into a Consumption Report.
- Excluded Information: Certain laws require separate privacy notices or are exempt from general personal data privacy policy disclosure requirements. Such laws include the Fair Credit Reporting Act (FCRA).
1.3. Sources of Personal Data. We obtain the categories of personal data listed above on or through our Platform from the following categories of sources:
- Personal Data You Give Us: We receive the personal data you provide to us such as your name, email address, phone number, address, and home profile. Our Platform offers you the opportunity to create a profile and submit questions and comments that may be visible to other Users of the Platform. The information you provide in areas that are visible by other logged-in Users of the Platform may be read, collected, and used by others who access them. You can choose not to provide certain information, but that may limit your ability to take full advantage of the Platform.
- Automatically Collected Information: We receive and store certain types of information from you every time you use the Platform. For example, we may automatically log your browser type, language preference, the date and time of your visit to the Websites, your Internet Protocol (IP) address, and the website you visited before our Websites. In addition, we receive and store information about your use and activity on our Websites and within our Platform. We may also collect personal data about Users over time and across different websites, apps, and devices when a User accesses the Platform. Third parties also collect personal data this way on our Platform.
- Personal Data from Equipment: We may receive and store water usage information directly from Equipment to create a profile of your water usage (a “Consumption Report”). For example, we may receive and store the times at which your household water use is at its highest or lowest, and may store your settings on certain Equipment such as a smart meter.
- Personal Data from Your Water Provider: We may receive and store certain personal data about you from your Water Provider. For example, your Water Provider may provide us your historic water usage information so that we may present more meaningful information to you and personalize the Platform for you in a meaningful manner.
We use and disclose your personal data only as described in this Privacy Policy or as disclosed to you on our Platform or within our Services. For example, we may use your personal data:
- To Provide Our Services, Equipment, Websites, or Consumption Reports. This could include fulfilling your requests for Services and Consumption Reports. It could also include processing purchases or other transactions. For example, if you share your personal data to request a price quote or ask a question about our Services, we will use that personal data to respond to your inquiry. If you provide your personal data to purchase a Service, or Consumption Report, we will use such information to process your payment and facilitate delivery. We may also save your personal data to facilitate new product or service orders, or process returns.
- To Improve Our Services, Equipment, and Websites. We use personal data to understand and analyze the usage trends and preferences of our Users to make our Services, Equipment, or Websites better, diagnose technical issues, prevent fraud, and develop new features and functionality.
- To Understand Your Interests. We use your personal data to personalize your experience on with the Services and Platform, and to deliver information about Services relevant to your interests.
- To Process Your Payment for Services and Equipment. We use personal data to facilitate payment for Services and Equipment that you select through our Websites.
- To Respond to Your Requests or Questions. We use personal data to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
- To Determine Your Eligibility and Set Up Your Account. We use your personal data to verify your identity or determine your eligibility for some of our Services, Equipment, and promotions. For example, this may include verifying your age, date of birth, and place of residence. If you set up an account through the Services on any Website, we will use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.
- To Market Services and Equipment. We provide you with information and promotions about Services and Equipment. For example, we may use cookies or other online tracking technologies to provide customized advertisements, content, and information; monitor and analyze the effectiveness of marketing activities; and track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other platforms.
- To Secure the Services and Platform. We use personal data to maintain the safety, security, and integrity of our Services, Platform, databases, and other technology assets, business, and other users.
- To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy.
- As Required by Law. We use personal data to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.
We may create non-personal Deidentified Information or Aggregate Information from the information we collect, as permitted by law. We may use such non-personal data for our own purposes or disclose it in a non-personally identifiable manner to:
- Advertisers and third parties for their marketing and promotional purposes;
- Organizations and government entities that conduct research into water usage or smart water meter technologies;
- Other Users of the Services for purposes of comparing water usage to the broader community; or
- Other interested third parties.
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal data that we collect, or you provide:
- Service Providers. We may share your personal data with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy. Access to your personal data by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal data that they are provided with confidential and to comply with all applicable laws.
- Water Providers. To your Water Provider for their own purposes, which may include marketing purposes, and subject to their privacy policy and practices. This may include when we jointly offer events, promotions, or any other product or service offerings with Water Providers. The personal data that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the information related to your account. Water Providers may collect information directly from you, which may be combined with personal data disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a Water Provider, the information that you provide may be shared with us and with that identified Water Provider.
- Related Companies. We may share your personal data with subsidiaries and divisions or companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us).
- M&A Transactions. If we sell all or part of our business or make a sale or transfer of assets or we are otherwise involved in a merger or business transfer, we may transfer your personal data to a third party as part of that transaction, including at the negotiation stage.
- Legal Compliance. When we have a good faith belief that disclosure is necessary to: (a) comply with any court order, law, or legal process, including responding to any government or regulatory request, or to prevent fraud or other illegal activities, such as willful attached on our data technology systems, and as necessary to establish or preserve a legal claim or defense; (b) enforce or apply the terms of commercial transactions and other agreements between us, including for billing and collection purposes; and (c) protect the rights, property, privacy or safety of Metron-Farnier, our customers, Users, or others.
- Consent. Otherwise with your express consent.
We have implemented reasonable measures designed to secure your personal data against unauthorized access or and acquisition. These measures include technology provided by our service providers to encrypt and protect transaction data, and password-controlled access to all or parts of our Websites. You are responsible for keeping your password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of data via the internet is not completely secure. No one can guarantee the security of your personal data transmitted to our Websites, including us. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the websites.
The following applies to residents of California.
- Notice to California Residents. Metron-Farnier must disclose whether the following categories of personal data are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal data in that category about you. In the preceding twelve months, we have disclosed the following categories of personal data in the manner described.
| Category | Disclosed for a Business Purpose | Disclosed for Valuable Consideration |
| A. Individual Identifiers and Demographic Information | Yes | No |
| B. Commercial Information | Yes | No |
| C. Internet of Network Activity | Yes | No |
| D. Home Information | Yes | No |
| E. Consumption Data | Yes | No |
| F. Inferences Drawn from Personal Data | Yes | No |
- Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Metron-Farnier are entitled to ask us for a notice describing what categories of personal data we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “CONTACT DATA” below.
You can make the following choices regarding your personal data:
- Access to Your Personal Data. You may request access to your personal data by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.
- Changes to Your Personal Data. We rely on you to update and correct the personal data contained in your account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal data, please contact us as described below.
- Deletion of Your Personal Data. Typically, we retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal data by contacting us contacting us as described below. We will grant a request to delete personal data as required by law, but you should note that in many situations we must keep your personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal data as described in this subsection within the timeframes required by law.
You can make the following choices to opt out of certain activities regarding your personal data:
- Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for Services or Equipment you have requested, or deliver notifications directly to you through the Platform.
- Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about Services or Equipment tailored to your interest. That advertising may appear either on our Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
- Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.
When exercising the rights or options described in this Privacy Policy, the following guidelines apply:
- No Fee Usually Required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
- What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal data to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time to Respond. We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
- No discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain Services or Equipment. These responses are not discrimination and our reasons for declining your request or ceasing Services or providing Equipment will be provided at that time.
- Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide the requester’s proof of identification, and the authorized agent’s proof of identification.
Our Websites may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Policy. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to review the privacy statements posted on these (and all) websites you visit.