Alameda Municipal Power’s Account Management Tools
Privacy, Information Security & Energy Usage Data Policy
This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle yourPersonally Identifiable Information in accordance with our Account Management Tools Portal.
As used in thisPolicy, “we,” “our” and “us” refers to Alameda Municipal Power (AMP) and our ServiceProviders. By registering at or using the Site, you (as defined below)agree to this Policy (without change by you) on your own behalf.
Definitions. The following definitions also apply to this Policy:
- By “Aggregate Data”, we mean Account Management Tools data or Personally Identifiable Information (PII) from which personally identifying information has been removed such that, under applicable laws or in the ordinary course of business, (a) you reasonably cannot be identified, and (b) the Smart Meter service location or the appliances or devices in it reasonably cannot be identified as being yours. An example of Aggregate Data is data about total use of electricity for all residences, or for all businesses in a geographic area. You acknowledge that Aggregate Data is not protected or private data and is not covered by the protections in this Policy.
- By “Disclose” we mean all of this: using, accessing (or barring access), processing, fulfilling, disclosing, receiving, displaying, sharing, transmitting, transferring, storing, retaining, combining, investigating, verifying, proving, enforcing and otherwise dealing with, voluntarily or involuntarily, Account Management Tools data.
- By “Account Management Tools Data” we mean: (i) information about usage of electricity that we may provide from time to time; (ii) other information referenced in this Policy that is obtained by us via the Smart Meter; and (iii) all information deriving from or added to the collected information.Account Management Tools Data also includes information (now or later) relating to installation, billing, maintenance or update of the Smart Meter. It also includes other information identified in this Policy as Energy Usage Data. Account Management Tools Data does not include Aggregate Data.
- By “Personally Identifiable Information” or “PII,”we mean, to the extent required by law and in the ordinary course of business ,the following: information (1) that personally identifies you, (2) that relates to you in a way which reasonably would identify you or a device only used by you (like your computer, phone or tablet); (3) that we already have about you(e.g., for your AMP account); or (4) that we collect on or through the Smart Meter or the Site. PII does not include: (a) any of the foregoing information that is in public records or that is otherwise available to the general public; (b)Aggregate Data; or (c) Account Management Tools Data that doesn’t meet the definition of PII.
- By “ServiceProviders” we mean (collectively) third parties that provide services to us or help us perform (or perform for us) contracts or obligations, including subcontractors, agents, and other entities or individuals with whom we work from time to time, including but not limited to companies that install Smart Meters or provide management or other services relating to them. “Service Providers”also includes service providers to our Service Providers (i.e., third parties who provide services to them).
- By “Site”, we mean the website where you can access Account Management Tools Data associated with your service account and other available Smart Meter services.
- By “SmartMeter”, we mean a device that is installed by us (or on our behalf) that measures energy consumption of a location (such as a residence or business).This energy consumption information is called Account Management Tools Data. Unlike a traditional mechanical meter, smart meters can record energy consumption in shorter intervals and then communicate that information back to the utility using two-way radio communications.
- By “you”, we mean an individual or an entity (i.e., residential or commercial) who is shown on our records (as they change over time) as the customer who has an obligation to pay for, or a right to receive, AMP services involving an installed Smart Meter(“Customer”), or any other user of this Site who is authorized to use the Site by us or by Customer. No other persons are authorized to use thisSite.
1. Information That You Affirmatively Provide To Us
When you visit the Site you may be asked to provide information in connection with particular things you request or do.
To register for a Site user account you will be asked to provide the name and account number associated with your AMP service account along with your phone number or other details. You will also create a login and password which you agree to keep confidential.
Other information that you may provide us includes: billing and payment information used to pay your energy bill, including financial information; information you provide to determine eligibility or participate in certain energy programs or services; and information you fill out in any form on our Account Management Tools portal, mobile applications, or otherwise, such as signing up for outage alerts and bill notifications.
2. Information That We Get From Your Use of the Account Management Tools Portal orMobile App
In order to access theAccount Management Tools Portal, you need a service account with AMP and a smart meter installed on your residence or business. We associate your personally identifying information(PII) with your web portal account (see No. 1 regarding any policies regarding that account information).
We automatically collect Account Management Tools Data from the Smart Meter in order to support our Smart Meter services (including this Site), billing and other operations. Examples of data that we automatically collect from your Smart Meter includes: register read data, load profile data, event and alert data, and other data available now or later via the Smart Meter that we let you know about in or with your billing statement, your use of the Site, in an AMP newsletter or in another notice from us.
We also collect information about visits to our web portal and mobile applications, such as the number of visitors and the number of users that click on certain links or use certain services. This information is used to improve the web portal design and usability, to identify system performance issues, or for other internal purposes.
3. How We Use Information
AMP uses, stores and processes the information that you provide or make available for the following purposes:
- to authenticate and confirm your identity when you access your AMP account,
- to analyze it in order to optimize services, provide more accurate billing, restore power more quickly during outages,
- to provide for system, power grid, or operational needs (including but not limited to doing things like addressing outages and load balancing),
- to provide new or required services,
- to plan, implement, or evaluate demand response, energy or efficiency programs,
- to conduct system load analysis or rate case analysis. The data used for these analytics are tied to a Smart Meter or service location and no account or private customer information is used for data analytics, and
- to send you messages related to your energy services, administrative messages, technical notices, updates, alerts, and other information that you request.
4. How Long We Keep Information
Account Management Tools aata collected by the Smart Meter will be stored by AMP for a minimum of three years; thereafter, AMP will archive the data for seven years.
5. Other Information You Provide to ThirdParty Websites; Links.
The Site may contain links to websites of third parties that we do not control (except for links to another site of ours, such as our main site for AMP). We provide the links merely for your information or convenience. When you choose to click on a link, you will leave the Site and this Policy will no longer apply. Instead, Acceptable Use Agreement and privacy policies (if any) created by the third-party website will apply, so do not use third-party sites unless you agree with those rules and policies.
6. How We Disclose Personal Information or Other Account Management Tools Data
In general, we Disclose Account Management Tools Data to operate our business as required or allowed by law and to fulfill our mission and goals as a utility. We have already described some Smart Meter Disclosures, but we also disclose it for the following purposes:
- To provide and manage the Site and our business: We also disclose Account Management Tools data to create, manage and bill your account. We may Account Management Tools data to install and operate the Smart Meter, to provide the Site and its services and customer support, and otherwise to operate our business. We may also use Account Management Tools data attempt to prevent potentially illegal or harmful activities and to enforce our contracts and policies, including this Policy and the Terms andConditions Agreement.
- To communicate with you: We may disclose Account Management Tools data to contact you or to respond to your requests of us from time to time. For example, we may contact you about your utility account or Account Management Tools data or to help you and/or us (such as to suggest different rate or energy consumption plans as they become available, special programs, or generic or tailored energy management tips).
- When authorized byyou: We may use and Disclose Account Management Tools Data when authorized by you.
- To enable ServiceProviders to provide services to you: We may work with Service Providers to do things we may do. We may disclose Account Management Tools data to them and they may disclose Account Management Tools data to us and theirService Providers, subject to applicable law.
7. What We Will Not Do With Account Management Tools Data.
As described in Nos. 3 and 6, there are many reasons we will disclose Account Management Tools data. However and regardless of the foregoing, we will endeavor not to disclose PII or Account Management Tools data to third parties for their use in marketing their products or services to you.
8. Security
We implement what we believe to be the most stringent administrative, technical and physical safeguards to protect Account Management Tools data from unauthorized access, destruction, use, modification or disclosure. Our Service Providers provide assurance that theSmart Meter system components underwent rigorous cyber-security design, build, and testing. Additionally, our Service Providers follow all industry standards and provide best-in-class security includingNISTIR (NIST Interagency Report) 7628, NERC CIP 002-009, OpenSG AMI-SEC, andDOE Interoperability and Cyber Security Plan. However, we do not guarantee security. If applicable law imposes any non-disclaimable duty on us about security, you agree that the standard used to measure our compliance with that duty will be will full misconduct.
You are part of security. You agree not to share your account credentials (like your user name, password or answers to challenge questions etc.) with anyone. If you do share them, the person you share with, and any person they share with, will be able to access your Account Management Tools data. You assume all risks, for yourself and others in the building served by a Smart Meter, by sharing your credentials. You also agree that we may treat all use of your access credentials as a use authorized by you.
9. Your Consent to Electronic Notification of PII Breach Incidents
If your Personally Identifiable Information (PII) is compromised we will (a) post the notice on the Site and email you notice that we have done so, or (b) simply send you the notice by email. We may send the email to any email address that we have in our records for you, and you agree to maintain a functioning email account.
10. Accessing and Managing Your Information
Most customers have secure access to information about them through their monthly bills or their online account on our web portal. To help protect your privacy and provide you with quality service, we rely on you to provide us with complete and accurate information. If you think the information we have about you is inaccurate or outdated, please contact us to update or correct the information.
We offer certain choices about how we communicate with you and what information you provide to us. In some cases, you have the right to limit, or opt out of, the information you provide to us.
- Your Account: As a customer, you may sign up for online access to your account to get instant access to your bill, make payments, view your energy usage, and receive important alerts. If you choose to sign up for online access, you will be asked to provide your email address. You have the right to decline to provide your email access; however, you will not be able to take advantage of our online services such as electronic billing and payments as well as outage or bill notifications.
- Email notifications and text alerts: If you have opted in to receive email communications or text alerts from us, you can opt out of receiving these emails or alerts at any time by following the unsubscribe process in the footer of the email or by texting “STOP” in response to a text message. You can also opt out by updating the preferences section on your account in the Account Management Tools portal.
11. Requesting Correction of Account Management Tools data; Identity Theft
You may access Account Management Toolsthat we make available by logging into your Site account. Typically, Account Management Tools data may not be corrected (for example, you may not change the amount of energy you used). Of course, billing errors and the like may be corrected through our ordinary business procedures.
- If you Move orSell, etc. If you move from or sell the property where aSmart Meter was installed (“Previous Location”), we may automatically terminate your Site account. You may re-register for a new Site account that is associated with any Smart Meter at your new location (assuming it is one of AMP’s meters and that you sign up for service at the new location in our service area).You will no longer be able to access Account Management Tools Data relevant to your usage at the Previous Location nor the usage of the new occupants. The new occupants of your Previous Location will only be able to access Account Management Tools data effective of their date of move in.
- Identity Theft. If you believe that you are a victim of identity theft, you may be entitled by law to request information from us. You can do this by writing us at our address in“Contacting Us.” After we receive all the information we need to process your request, we will provide without charge, the information that we still have and that we are required by law to provide (without waiving any of our rights or defenses).
12. Amendments
None at this time.
13. Enforcement of Our Policy
We have procedures for taking appropriate action against those who violate this Policy when they are required to follow it. For example, we might discipline an employee who will fully violates thisPolicy (subject to applicable law).
As noted, this Policy is part of and supplemented by AMP’s Acceptable Use Agreement, including but not limited to terms regarding governing law and forum, arbitration, disclaimers, exclusions of and limitations on damages. If there is a conflict between the Acceptable UseAgreement and this Policy, the latest version of this Policy will control. As a contract, we and you are bound by this Policy, and there are no third-party beneficiaries of this Policy, including anyone (other than you) that visits, lives or works in the location served by the Smart Meter.
14. Contacting Us
We are Alameda Municipal Power (AMP) and our contact information for matters relating to this policy is below. Use this address when sending a notice required under this Policy (such as for correction of PI or a request for information regarding Identity Theft).
Alameda MunicipalPower
2000 Grand Street
Alameda, CA94501-0263
Effective Date: July 1 2017