Effective Date: January 1, 2020 (amended July 1, 2021)
Utility Service Partners Private Label, Inc., known as Service Line Warranties of America (“SLWA”), is part of the HomeServe family of companies. HomeServe USA Corp. and its parent, affiliate and subsidiary entities. HomeServe USA Corp. and its parent, affiliate, and subsidiary entities (“HomeServe” or “We” or “Us” or “Our”) are serious about the private nature of your personal data, such as the name, address, telephone number, email address, and other information obtained from, or provided by, you (“You”) to Us, regardless of the manner in which it is provided, including, but not limited to, information provided by mail, e-mail, telephone, mobile phone (including applications or text message), surveys, sweepstakes, contests, on our social media pages or on Our websites (“Website” or “Websites”).
We will update this Policy from time to time, so please review the Policy regularly. If We materially alter this Policy, We will notify You of such changes by posting a notice on Our Website. Your continued use of plans, policies, products, services, or Our Website will be deemed Your Agreement that Your information may be used in accordance with the new Policy.
In the course of Our business or operating Our website, it is necessary for Us to access, collect, use, transmit, disclose, store, maintain and otherwise handle personal data about You. This Policy provides the basis for protecting such personal data while ensuring Our compliance with all state and federal laws and industry requirements.
This Policy applies to all personal data accessed, collected, used, transmitted, disclosed, stored or maintained by Us, including both electronic data and paper records.
We are committed to using reasonable commercial measures to: (1) the safeguard Your personal data, (2) use personal data in accordance with this Policy, and (3) monitor and improve the safeguards so they are effective and appropriate. We adhere to the following practices:
- Personal data You provide will not be accessed or used in a way that is incompatible with this Policy.
- We reasonably protect against unauthorized, inadvertent access, use and/or disclosure through administrative, technical and physical safeguards.
- We strive to prevent breaches of Your personal data with security measures and will notify You of a breach of Your personal data if required by applicable state or federal law.
- We train Our employees with regard to safeguarding Your information.
Please do not provide Us with sensitive information or health information. If You should do so inadvertently, We will use and disclose that information in the same manner as any other Information You provide to Us.
Information We Collect
For purposes of this Policy, "personal data" is any information that identifies, relates to, or describes, directly or indirectly, an individual or household.
In the course of operating Our business and Websites and delivering Our products and services, We collect and process the following categories of personal data:
1. Through Our Websites and Communications with Us. We collect and store the following personal data when You submit it through Our Websites and by email and telephone, such as when You enroll in a plan/policy offered by Us. We use this personal data for typical business and commercial purposes (including to comply with legal obligations and for auditing, security and anti-fraud purposes) and as described more specifically below:
- Personal Identifiers. We receive personal identifiers (which include Your name, postal address, email address, telephone number, utility account number, policy/account numbers, and similar identifiers) and use them to respond to and complete Your requests, fulfill Your orders for products and services (e.g., scheduling and dispatch of contractors/technicians to provide You with Our service), and to communicate with You for informational purposes (including to send You confirmations, technical notices, updates, invoices, surveys, and security alerts) and marketing purposes (including to send You news, promotions, special offers, information, or to offer You other products and services that may be of interest to You). We may communicate with You about sweepstakes or contest, or to process and deliver sweepstakes/contest entries, correspondence, and prizes. We also create internal identification and reference codes to identify You in Our systems.
- Communications and Submissions. We collect the information and content You submit through enrollment forms, email and telephone communications, and Our Websites (including web chat communications, product and service reviews, social media interactions, contest and sweepstakes entry submissions, and service requests). We used this information to provide you the product or service ordered, to respond to and fulfill Your requests, establish and manage Our customer relations and customer service, and to provide and improve Our Websites and Our products and services.
- Financial Information. We receive financial information (such as payment card and bank account information, utility account number and other billing information) to process payments for the products and services You purchase from Us.
- Commercial Information. We collect and generate commercial information and transactional information (such as records of Your residential status, and records of products and services purchased and received by You). We use this information to respond to and fulfill orders, improve Our product and service offerings, communicate with You and with Partners, tailor Our marketing efforts, and for internal reporting purposes.
- Inferences from the information listed above. We will use the information listed above to draw inferences about Your preferences to help Us provide You with personalized content and marketing offers and help Us develop and provide better products and services.
- Audio and Visual Information. We may receive digital photos You submit to us. We use these photos to establish and manage Our customer relations and customer service and may include in our marketing materials. We record customer service telephone calls for quality purposes and to meet our legal obligations and to enforce our rights.
- Signatures. We may collect Your signature and related authentication details in connection with any documents You electronically or physically sign and provide to Us. This information may be used to maintain the integrity of Our processes, enforce rights, prevent fraud, and validate Your identity.
- Privacy Choices. We receive and retain any opt-outs or other choices related to how we collect, use, and disclose personal data.
2. From Contractors and Technicians. We may receive Your commercial information, communications and content, and job photographs and activity descriptions from contractors and technicians when they provide products and services to You. We use this information to provide and improve Our products and services (including by monitoring and reporting the performance of contractors and technicians), to respond to and fulfill orders, and to preform customer service.
3. From Our Partners. We work with Partners to offer products and services, and we may receive your personal identifiers and commercial information from them so that we can send you offers of Our products and services, enroll you in a service, respond to your claims, provide you with our products and services, and for other business and commercial purposes.
4. From Providers of Credit Services. We may receive personal identifiers and commercial information (such as credit rating information) and other personal data listed above from data providers. We use this information to send offers of Our products and services, provide and improve Our products and services and to respond to and fulfill orders.
5. From Others. We may receive personal identifiers and professional and education information from data providers to help us contact You to offer Our products and services that We think may interest You. We use the personal identifiers for the same purposes as described above.
6. Automatic Collection through the Websites. We and Our third-party partners, such as advertising networks and analytics providers, may automatically collect categories of personal data using cookies and similar technology when You use the Websites and receive Our emails. We use this information to provide and improve Our products and services, tailor Your experience on the Websites and Our marketing efforts and create aggregate internal reports on website usage and activity, such as views of certain pages and content. These additional categories of automatically collected data may include:
- Online identifiers. We may collect Your IP address and other device and online identifiers when You use the Websites.
- Geolocation Information. We may use Your IP addresses to estimate an approximate location of the device You are using to access Our Websites in order to enhance and personalize the features and functionality of Our Websites and product and services offerings
- Website activity information. We may monitor and collect website activity information and device information, such as website clicks, content and page views, the website each visitor prior to Our website, domain type, browser version, and internet service provider.
- Inferences from the information listed above. We will use the information listed above to draw inferences about Your preferences to help Us provide You with personalized content and offers and help Us develop and provide better products and services.
7. Anonymous or Aggregated Information. We de-identify or aggregate data We receive and may use and disclose it for any business purpose.
Personal Data Disclosure
We share any of the personal data we receive (listed above) for Our business and commercial purposes and as more specifically described below, including to comply with legal obligations and for auditing, security and anti-fraud purposes.
Service providers. We share any of the personal data described above with service providers (including home service contractors, mailing and fulfillment vendors, service-related technology providers, marketing agencies and survey administrators) that provide services to You and Us, including to help Us conduct satisfaction surveys, send you offers of Our products and services, provide Our products and services, maintain Our databases and Websites, administer emails, and analyze Website usage activity. For example, We provide Your personal identifiers and job request information to home service contractors so they can provide their services to You. We may provide Your personal identifiers to print and communications vendors so that they can send You communications on Our behalf. We may also provide personal data, including personal identifiers, commercial information, and device and IP address information to Our service providers for fraud detection purposes. We require that service providers use personal data only for the purposes specified in Our agreements.
Other third parties providing services to us. We also share personal data (including Your personal identifiers and financial information) with third parties to help Us provide products and services to You such as fulfilling and delivering orders, processing payments, social media functions, and administering sweepstakes or contests. We may share your personal identifiers and commercial information (the products and services You have purchased from Us) with Partners including Your utility so that We can manage Your account and provide You with Our products and services. We will provide Your personal identifiers and financial information to a payment processing vendor to complete a transaction You have requested. In these situations, You are using and directing Us to intentionally disclose personal information (including personal identifiers and financial information) so Our products and services and Your requests can be provided to You.
Affiliates. We may also share any of Your personal data within Our group of companies that operate in or outside the United States (including in the EU) for the purposes described above. By providing Your personal data to Us, You fully understand and clearly consent to such use and transfers as set out in this Policy.
Sales, Mergers, and Acquisitions. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), We will provide personal data and transaction history associated with each relevant business unit to the persons and/or entities assuming control of such business unit or as otherwise necessary to complete the transaction as permitted by law or contract, and they will be able to handle the personal information as stated in this Policy.
Where permitted to do so, We may disclose Your Information to others including any company in Our group of companies, Partners, or third parties to carry out Our services and deliver Our products to You, send You related information, including but not limited to, confirmations, invoices, surveys, technical notices, updates, security alerts, and support and administrative messages, and provide and deliver information and offers on other products and services offered by Us, Our Partners, or third parties that may be of interest to You. We may also share Your Information with Our group of companies or vendors that operate outside the United States (including the U.K., or Canada). By providing your Information to Us, You fully understand and clearly consent to such use and transfers as set out in this Policy.
We may use third party service providers to help Us operate our business, such as authorization of payment transactions, marketing, mailing and fulfillment vendors, home repair technicians, service-related technology providers, and may share Your Information with these service providers for those limited purposes.
We may also provide third parties with statistical, aggregated information about Your use of Our Website and to monitor and conduct an analysis of Our Website traffic and usage patterns, and analyze trends.
If HomeServe, or a portion of HomeServe, is sold to, or merges with, another company, or declares bankruptcy, some or all of the Information collected from You may be transferred to a third party as a result of the transfer of assets. We may also disclose Your Information when we determine it is necessary to comply with applicable laws or protect the interests or safety of HomeServe or any other person.
We are committed to protecting the personal data You share with Us. In order to prevent unauthorized access, use or disclosure of Your personal data, We have put in place commercially suitable physical, administrative and technical safeguards to secure Your personal data in both electronic and paper form. We control access to Our computer information systems containing Your personal data by User ID and password. We control access to Our paper records containing Information by keeping such information in secure areas with restricted access. We use up-to-date versions of security software, including malware, patches and antivirus software, firewalls, and encryption methods.
Transmission of information on the internet is not completely secure and therefore We cannot guarantee the security of the Information sent to Us electronically on Our Websites, or otherwise; transmission of such Information is therefore entirely at Your own risk.
Cookies, Web Beacons, And Other Similar Technologies
Like most websites, We and other companies use browser “cookies,” log files, beacons, pixels, and similar technology on the Websites and in our emails. Cookies and similar technology may collect Your personal identifiers (such as IP address, device and browser identifiers and characteristics, and other identifiers), information about Your device (such as operating system, browser characteristics, and language preferences), and Your usage activity on the Websites (such as Your interaction with Our Websites, the link You used to reach them, and the content and advertising displayed on them and Our content and advertising on other websites and online services).
A cookie is a very small text document, which often includes an anonymous unique identifier. When You visit a website, that site’s computer asks Your computer for permission to store this file in a part of Your hard drive specifically designated for cookies. Each website can send its own cookie to Your browser if Your browser’s preferences allow it, but (to protect Your privacy) Your browser only permits a website to access the cookies it has already sent to You, not the cookies sent to You by other sites. You can manage or disable Your cookies by using tools of Your browser. If You choose to disable cookies, the cookies will not be used. However, if You do choose to remove cookies or reject cookies it may affect certain features or services of Our Website.
Online Advertising and Usage Analytics
We use third-party advertising services to serve ads when You visit some of Our Websites and other websites and online services, third-party email services to send informational and marketing emails, and third-party analytics services to help Us understand and improve the usage of the Websites and our email. These services will collect Your personal identifiers (such as IP address, device id, and cookie information), device characteristics (such as browser version), and website browsing activity from You when you visit the Websites by placing cookies and using other similar technology. They use that information to provide advertisements to You on Our Websites and other non-affiliated websites and/or to provide analytical information for Our Websites. These third-party companies also may collect and combine information about Your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same partners.
We currently use Google Analytics to collect and process certain usage data on Our Websites. To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites. You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:
Network Advertising Initiative: https://optout.networkadvertising.org/?c=1
Digital Advertising Initiative: https://optout.aboutads.info/?c=2&lang=EN
When You opt out of personalized advertising, You may continue to see online advertising on the Sites and/or Our ads on other websites and online services.
We may use a number of third-party services on the Websites including Sizmek for advertising purposes and Google for Website tag management. For a understanding of Sizmek’s privacy practice, see https://www.sizmek.com/privacy-policy/#info-third. For an understanding of Google's privacy practices see https://policies.google.com/privacy?hl=en#infocollect .
Third Party Websites and Interaction
Any links furnished on Our Websites or provided to You by email may allow You to leave Our Websites or in the case of an email, access a third party website. These third-party websites are not under Our control and We disclaim any responsibility for the contents of such linked websites or any link(s) contained in any such linked website(s) or any changes or updates to any of these websites. We further disclaim any responsibility for any form of transmission received from any linked third party website or advertising. If We provide these links to You, it is done simply as a convenience to You and inclusion of any link herein shall in no way be construed as an endorsement by Us of the website(s).
Opt Out, Unsubscribe, Access, Questions And Further Information
At Your request, and where required by law, We will confirm, and/or update the personal data We hold about You. We may have to verify Your identity first.
If You do not want to receive marketing information from Us, You may “opt out” by writing, emailing or calling Us using the contact information listed below. If You opt out, You may still receive information from Us but only if it is necessary to provide You with Our products and services, including administrative messages or satisfaction surveys.
California Privacy Notice and Rights
We do not share personal information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes. Our Websites do not currently respond to browser do-not-track signals.
California consumers have the right to request:
• the deletion of the personal data We have about them
• additional information about whether and how We have collected, used, disclosed, and sold personal data about them
• the specific pieces of personal data We have about them during the prior 12 months
California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.
When You make a request, we may require that You provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request You make. We will match the information that You provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask You for additional information to help us verify your request.
Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide Us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request, and We will additionally require the authorized agent to verify his/her own identity and We will confirm the agent’s authority with the California consumer about whom the request was made.
You may submit a privacy rights request to Us by:
• Visiting homeserve.com/sc/dataprivacy
• Calling Us toll-free at 833-950-0094 (during business hours)
We are not currently selling Your personal data and have not sold Your personal data since January 1, 2020, the date the California Consumer Privacy Act (CCPA) went into effect. We do not have actual knowledge of selling the personal data of minors under 16. As a California consumer, You have the right under the CCPA to opt out of the sale of Your personal data.
Privacy Rights of Nevada Residents
If You wish to update Your personal data, or have any questions, comments or complaints about this Policy, or if You wish to opt out of receiving marketing information from Us, please contact Us at:
HomeServe USA Corp.
ATTN: Privacy Officer
601 Merritt 7, 6th Floor,
Norwalk, CT, 06851
You may also update Your online account information by visiting Our Website and logging into Your account.
Our Website is designed and intended for those who have reached the age of majority (18 years of age). By using Our Website, You affirm that You are at least 18 years of age. We are not liable for any damages that may result from Your misrepresentation of age.
No one under the age of 13 is authorized to submit any information, including Personal Information, on Our Website. Under no circumstances may anyone under the age of 13 use Our Website. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf. We will not knowingly collect any Personal Information from children under the age of 13.