At Clockwork Inc., your privacy is important to us. We are committed to maintaining the confidentiality, security and accuracy of your Personal Information (as defined in Section I below). Clockwork Inc collects information about you when you use the Site, purchase our products and services, and through other interactions and communications you have with Clockwork Inc and its affiliates and independently owned franchisees (collectively "Clockwork Inc" "us", "we", or "our"). We may share or combine Personal Information among our affiliates and independently owned franchisees and use it consistent with this Policy. This Policy applies to information collected from our customers and used by Clockwork Inc, and describes the information that we (or our trusted Third Party Providers) collect, how we use it and under what circumstances we share that information. This Policy only applies to our residential customers.
Your information may also be subject to our independently owned franchisee privacy policies published on their owned and operated websites. We encourage you to read their privacy policies when accessing their sites.
WHEN YOU ACCESS ANY OF OUR SITES OR SUBMIT ANY PERSONAL INFORMATION TO US BY ANY MEANS, YOUR INFORMATION WILL BE MANAGED IN ACCORDANCE WITH THIS POLICY. TO UNDERSTAND YOUR CHOICES REGARDING YOUR INFORMATION, SEE SECTION IV BELOW.
I. Information We Collect
We collect information:
- Directly from you when you provide it to us, including personal information;
- When you access or use our services or devices;
- Automatically as you navigate through the Site (See Website Use Information in part B below); and
- From third parties or publicly available sources (e.g. from social media services, forums, commercially available services, etc.).
We collect the following types of information:
A. Personal Information: We collect PII, Customer Data and Social Media Content (each defined below and collectively, "Personal Information").
- Personally Identifiable Information (" PII"): "PII" means any information that, by itself or in conjunction with other information, may be used to specifically identify or contact you or others you voluntarily refer to us, such as: (a) contact and identification information, including name, physical address, telephone number, e-mail address, date and place of birth, and driver's license number; (b) credit and financial information such as billing and credit history or payment history, and employment and income information; (3) customer relationship information, such as customer service requests that can be used to identify you or contains your personal information and/or (4) distribution utility account numbers or meter identification numbers.
- "Customer Data" means Customer Energy Usage Data (defined below) when it is combined or linked with your PII. We may collect Customer Data from our devices such as in-home thermostats, smart meters or Connected Home devices where applicable.
- Social Media Content: If you access or log-in to our Site through a social media service or another website, app, service or log-in ("Other Service"), the information we collect may also include your user ID and/or user name associated with that Other Service, any information or content you have permitted the Other Service to share with us, such as your profile picture, email address or friends' lists, and any information you have made public in connection with that Other Service (collectively, "Social Media Content").
B. Non-Identifying Information: We collect Customer Energy Usage Data and Website Use Information (each defined below and collectively, " Non-Identifying Information").
- Customer Energy Usage Data: " Customer Energy Usage Data" means measured energy usage that does not identify the customer to whom the energy usage information relates.
- Website Use Information: " Website Use Information" means the information our servers automatically record when you visit or use our Site, such as your IP address, the type of browser you are using and its settings, the third party website you visited immediately prior to accessing our Site, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Site, the specific Site pages you visit, type of product selected, site brand, order and product identifications, and the duration of your visits. Like many websites, we use, and allow certain trusted Third Party Providers to use "cookies" and other tracking technologies (such as web beacons, pixel tabs, etc.) (collectively "Automatic Data Collection Tools") to obtain certain types of information when your web browser accesses our Site or, to transfer pieces of information to the hard drive of a user's device, or to enable our systems to recognize your browser, and to provide convenience and other features to you such as recognizing you as a returning or frequent user of our Site. We allow our trusted Third Party Providers to utilize Automatic Data Collection Tools for analytic or marketing purposes. Some of the Automatic Data Collection Tools we use are associated with your account with us (including Personal Information), and others are not. We may use "session cookies" (cookies that last until you close your browser) or "persistent cookies" (cookies that last until you or your browser delete them).
II. How We Use Information We Collect
Clockwork, Inc. uses the Personal Information and Non-Identifying Information it collects to:
- Provide the products and services you have chosen;
- Manage and develop our business and operations;
· Establish, manage and terminate business relations with you;
- Review the products and services that we provide to you;
- Obtain credit approval;
- Inform you of our products and services other than those that you have specifically requested;
- Protect us against error, fraud, theft and damage to our goods and property;
- Conform with the requirements of the law or regulatory requirements or to comply with legal process served upon us;
- Protect our legal rights or property or other customers;
- Investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or violations of the terms and conditions of using the Site;
- Enable you to participate in programs such as Refer-A-Friend promotions, general promotions, sweepstakes, contests, games, special events, blogs and chats if you choose to participate for selection and notification of sweepstakes and contest winners and marketing purposes;
- Assist us in offering relevant products and services to you when you visit our Site or contact us by other means; and
- Provide us with business analytics.
We may also monitor and record any communications we have with you, like phone conversations and emails. This is just to make sure we're providing you with a good service and meeting our regulatory and legal responsibilities.
Under our Refer-A-Friend or similar promotions, when you invite others to participate in our services, we may collect the information that you provide about those people such as their name, mailing address, email address, and phone number. When you give us this information on behalf of someone else, you confirm that you have provided them with the information set out in this Policy, and that they have not objected to the uses of their information as described in this Policy.
We may use Customer Data collected from our devices to provide you with feedback about your energy use, your security and home automation system and controls, to help you set energy goals/budgets and track your progress, and to provide you customized content (such as tips and recommendations for reducing energy usage, home security tips, home automation advice, trend monitoring, energy analytics, etc.) and other purposes similar to the foregoing. We may also use Customer Energy Usage Data for customer support, system restoration, and research and development activities for new products and services, and other similar purposes like the foregoing. We also provide Customer Data to third party providers for marketing purposes unless you have opted out of these sharing practices. (see Authorizing Sharing of Customer Data in Section IV below)
We use Non-Identifying Information in a variety of ways, including to help analyze Site traffic, understand customer needs and trends, to improve our products and services as well as marketing purposes, such as carrying out targeted promotional activities and interest based advertising. We may use Non-Personally Identifiable Information by itself or supplement the information we collect with information obtained from other sources, such as information that is publicly available (e.g. social media services, forums, etc.) or commercially available sources. For more information on how this type of advertising works, go to http://www.aboutads.info/principles.
III. Sharing Your Information with Third Parties
A. Third Party Providers:
We may share your Personal Information and Non-Identifying Information with third parties, contractors, consultants and other parties who require the information to assist us to establish, maintain and manage our business relationship with you ("Third Party Providers"), such as marketing our products and services or contacting you regarding our products and services. We may offer co-branded services or features, such as promotions, contests, sweepstakes or other programs with a Third Party Provider ("Co-Branded Services"). By virtue of these relationships, we may share the information you submit to us in connection with the Co-Branded Service with a Third Party Provider. We may share your Customer Data with Third Party Providers engaged by Clockwork, Inc to perform services for or on behalf of Clockwork, Inc or to market Clockwork, Inc products and services. In addition, Third Party Providers may collect your Personal Information directly from you on our behalf.
We require our Third Party Providers to enter into contractual agreements, which require these Third Party Providers to comply with similar confidentiality and data security standards as Clockwork, Inc and prohibit these Third Party Providers from further disclosing or using your information other than to carry out the purposes for which the information was disclosed by us to such Third Party Provider.
B. Transfer of Assets:
C. Legal Necessity:
We may disclose any Personal Information or Non-Personally Identifiable Information about you or any person if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (1) fulfill a government request; (2) conform with the requirements of the law or legal process; (3) protect or defend our legal rights or property, or our Site; or (4) in an emergency to protect the health and safety of our Site's users or the general public.
IV. What Choices Do You Have About Our Use Of Your Information?
Our goal is to provide you with simple and meaningful choices about how your information is used. If you are a customer, you have some choices in sharing Personal Information with Clockwork, Inc. by your selections of our product and services.
A. Accessing and Updating Your PII: It is important that the PII Clockwork, Inc holds about you is accurate and current. As such, it is imperative that you keep us informed of changes to your PII. If you want to know what PII Clockwork, Inc holds about you or wish to change PII that is inaccurate or out of date, please contact us at email@example.com. It may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so upon your request.
When making an access request, we may require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the Personal Information that we hold about you. We may charge you a fee to access your Personal Information in instances that require a disproportionate effort but we will advise you of any fee in advance. We may decline to process requests that are frivolous or unreasonably repetitive, risk the privacy of others, or are extremely impractical. If you need help in preparing your request, please contact our Privacy Officer.
B. Commercial Electronic Communications from Clockwork, Inc: You may unsubscribe from receiving future commercial email communications from us by clicking the "unsubscribe" link included at the bottom of any marketing emails we send, or by emailing us at firstname.lastname@example.org. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
C. Authorizing Sharing of Customer Data : If we are sharing Customer Data with Third Party Providers for the purpose of marketing third party products and services to you, we will provide you an opportunity to opt-out of allowing Clockwork, Inc to release your Customer Data to those Third Party Providers.
D. "Do Not Track" Technology: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference based advertising purposes ("DNT Notice"). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, web beacons and similar technology are not used for preference based advertising purposes – that is, to restrict the collection of information about your online activities for advertising purposes. Unfortunately, given how interest based advertising works, DNT Notices may not effectively accomplish this goal. For this and a variety of other reasons, with respect to our Site, we do not take any particular action based on browser based DNT Notices.
If you do not wish to participate in interest based advertising via third party advertising networks as described below, or to opt out of the use of certain tracking technologies, please visit:
and follow the simple opt-out process. A couple of important notes about this opt-out tool: (1) it includes all the advertising networks that we may work with, but also many that we do not work with; and (2) it may rely on cookies to ensure that a given advertising network does not collect information about you ("Opt-out Cookies"). Therefore, if you use or buy new computer equipment, change web browser or delete these Opt-out Cookies, you may need to perform the opt-out task again.
V. Your California Privacy Rights
You may learn more about your rights under California's privacy laws at http://www.privacyprotection.ca.gov.
VI. Safeguarding Personal Information
Data Security: Clockwork, Inc processes information on our servers located inside and outside the United States; therefore, your Personal Information may be processed on a server located outside of the country where you live. Clockwork, Inc has implemented physical, administrative, and technical safeguards and security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the Personal Information under our control. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure; therefore, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and you do so at your own risk. We are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. In the unfortunate event that your information is compromised, we will notify you in the most expedient time reasonable under the circumstances. We may delay notification as necessary while we take measures to determine the scope of the breach and restore reasonable integrity to our systems as well as for the legitimate needs of law enforcement. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
Data Retention: Clockwork, Inc will retain, use, and store your Personal Information as necessary to comply with its business requirements and objectives, legal obligations, to mitigate and resolve disputes, and enforce our agreements. We do not undertake any obligation to retain your data for any particular length of time and anticipate retaining your Personal Information for as long as it is useful.
Phishing Emails: We will only use your Personal Information to contact and interact with you as described in this Policy.
We will not send you an email asking you to reply by providing personal or account information, or threaten to disconnect your services unless you provide us personal information. If you receive such an email, it may be an attempted identity theft scheme that is commonly called "phishing," where hackers steal your passwords or infect your computer with malicious software. If you are concerned about clicking links provided within an email sent by Clockwork, Inc or one of our affiliates, do not click the link. Instead, you should manually input our website address in your preferred web browser. Doing so will ensure that you do not open a third-party website disguised to look like our website.
For more information about "phishing," and steps you can take to protect your personal information, please visit the Federal Trade Commission's website at www.ftc.gov.
VII. Privacy of Children's Information
Our Site is not directed to children. We do not sell products or services to children under the age of 13. We do not knowingly collect Personal Information from children. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information to us please Contact Us. A parent or guardian of a child under the age of 13 may review and request deletion of such child's Personal Information as well as prohibit the use of that information. We understand that children need special safeguards and privacy protection. We realize that they may not understand all the provisions of our Policy or be able to make thoughtful decisions about the choices that are made available to our adult users. We encourage parents to monitor their children's use of the internet.
VIII. Linked Sites
Our Site may contain links to other websites operated by third parties. This Policy does not apply to your use of third party websites. Clockwork, Inc is not responsible for the information practices or the content on such linked sites, and your use of those third partiy sites is not governed by this Policy. We have no liability or responsibility for those sites or their policies/practices. We recommend that you carefully read the policies, including terms and conditions of use, of each site you visit.
IX. Contacting Us
To get more information about our Policy or if (1) you have questions or comments about our Policy; (2) wish to make corrections to any Personally Identifiable Information you have provided; (3) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; or (4) wish to withdraw your consent to sharing your Personal Information with others (or the Personal Information of others you voluntarily submitted to us), please contact us as follows:
c/o Compliance Department
12 Greenway Plaza Suite 250
Houston, TX 77046
This Policy does not create or confer on any individual or on Clockwork, Inc any rights, or impose on Clockwork, Inc any obligations beyond any rights conferred or obligations imposed by applicable law.
This Policy was last updated on March 1, 2018
*Mister Sparky is a subsidiary of Clockwork, Inc Marketing Limited.
**Clockwork, Inc is comprised of a collection of companies under Centrica US Holdings, Inc., and Clockwork, Inc's wholly-owned direct and indirect subsidiaries and affiliates within the United States.
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