Privacy Policy

Effective date: May 1, 2024

1. Who we are and scope

MF Center, LLC, a company registered in Florida doing business as Florida Submeters (“FSM”), operates floridasubmeters.com and its submetering and accounting platform. Privacy contact: [email protected].

This policy describes how we handle data about visitors, Customers and Unit Users in connection with our websites, accounts, services, connected devices and communications. A Customer is the building owner or the condominium property manager who contracts FSM; a Unit User is the tenant, owner or authorized person linked to a unit.

FSM manages information for its own business relationships, accounts and security. It also processes resident and property information on behalf of Customers in order to provide the service. The role of each party depends on the specific processing and the applicable law. The Customer is responsible for its decisions about billing, occupants and the use of data under its control.

2. Information we may process

Depending on the features used and the data actually provided or generated, the information may include:

• Identification and contact: name, email, phone, address and details of the entity represented.
• Account and authorizations: identifiers, protected credentials, roles, and associated properties and units.
• Property and occupancy: service address, unit, number of occupants, and the dates or changes of association needed for management.
• Submetering: equipment identifiers, readings, consumption, dates, connectivity status, technical equipment data (such as battery level or signal strength) and available alerts.
• Billing and accounting: invoices, charges, balances, adjustments, transactions, references and payment statuses.
• Payment data: transaction references and, depending on the payment gateway, limited card details such as the brand and last digits. Full card details are entered directly into the authorized third-party payment gateway; FSM does not receive or store them.
• Usage and security: IP address, browser or device information, access events, change history and technical logs actually generated by the system.
• Sales inquiries: the data sent through the website’s contact form, such as name, email, phone, property type, number of units, service of interest, water provider, pipe material and message.
• Support: inquiries, communications and files sent to handle requests.

This list illustrates categories related to the service; it is not a statement that all of them are collected for every person, nor an authorization to collect data unrelated to the purposes described.

3. Sources of information

We may receive information directly from the User, including through the website’s contact form; from the Customer or its authorized manager; from meters, readers and gateways linked to the service; from interaction with the platform; and from providers involved in the contracted features, such as the payment gateway.

A Customer may add a Unit User’s information before that person creates an account. The Customer must have the authority, and provide any required notices, to do so.

4. Purposes

We use the relevant data to enable accounts and permissions; link people to their units; display readings and consumption; generate and maintain billing and accounting records following the Customer’s instructions; facilitate payments and reflect their status; respond to sales inquiries and prepare proposals; handle support requests; send operational communications; investigate errors; protect the service; and comply with applicable legal obligations.

Retention after account closure is carried out for the accounting and traceability purposes described below. Access to those records must be limited to authorized purposes.

We do not sell personal data or use it for targeted advertising or to train artificial intelligence models. We may produce aggregate, anonymous statistics that do not identify anyone, in order to improve the service.

5. Who we share with or allow access

• Customer (the building owner or condominium property manager) and its authorized staff: information about its units and Unit Users needed to manage consumption, invoices, payments and claims, according to their permissions.
• Authorized Unit Users: information about the unit for the periods during which they were linked to it. The unit owner may also view the information for their tenants’ periods.
• Authorized FSM personnel: information needed for operations, support, accounting and security.
• Service providers: cloud infrastructure and hosting providers, communications delivery providers and providers of the meter communication network, as well as the authorized third-party payment gateway. They process the data needed for the functions they perform, subject to the applicable agreements and obligations.
• Authorities or other legally appropriate recipients: when necessary to comply with a valid obligation or to exercise or defend rights, subject to applicable limitations.

We do not sell or trade personal data, or share it with third parties for advertising.

6. Payments

Utility payments are made to the Customer through an authorized third-party payment gateway; FSM facilitates the process and its accounting record, without holding or retaining those funds. The processing of data by banks and the payment gateway is also governed by their own policies and obligations.

When the Customer contracts billing management, the FSM agent accesses the Customer’s bank account and the transaction data needed to manage collections and payment to the main provider, solely for that purpose.

Not holding funds does not mean that FSM does not process transaction data: we keep transaction references and the data needed for accounting records. Full card details are received directly by the payment gateway; FSM does not have access to them.

7. Cookies and similar technologies

The website does not use its own cookies. The platform stores a session identifier in the browser, which is needed to keep you signed in. We do not use analytics or advertising tools.

Some pages load third-party resources, such as fonts or style sheets, and the payment page loads the payment gateway, which may use its own cookies to prevent fraud. Our infrastructure providers may also use technical cookies needed for the site’s security. These third parties may receive technical data, such as your IP address, under their own policies.

8. Retention and account deletion

During the service relationship, we retain the data needed for the applicable features and purposes.

When a Customer or Unit User deletes their account, we retain the relevant records for two years from the date of deletion by that User, for accounting and traceability purposes.

The retained records may include, depending on the case, invoices, transactions, readings, change history, technical logs and associated contact details. Retention does not mean keeping all account data in full, nor necessarily keeping every category listed.

Deleting an account disables its access according to the closure procedure, but does not immediately erase all records related to the property. Authorized FSM personnel and the Customer that remains authorized to view its Unit Users’ records may access the retained information for the stated purposes. Retention does not automatically extend the permissions of former administrators or enable marketing uses.

At the end of the two years, the records will be effectively deleted or anonymized, unless a legal obligation or documented legal need justifies keeping certain data for longer. The exception will be limited to that data and to the time necessary. If a record is linked to several accounts, it is kept until the period of the last of them expires.

9. Requests and rights

You may write to [email protected] to request information about your data, its correction or deletion, or to exercise the rights granted to you by applicable law. We may verify your identity and authority through proportionate means before disclosing or changing information.

When the request involves information that FSM processes on behalf of the Customer, we will coordinate with the Customer as appropriate, without limiting the requester’s legal rights. Deleting data does not cancel a valid debt, nor does it allow information to be kept indefinitely without justification.

Users may close their account from the platform settings. We respond to requests within a maximum of 30 days. If you disagree with our response, you may write to us again so that we review it.

10. Security and communications

FSM applies reasonable administrative and technical measures to protect information and limit access by role. No system guarantees absolute security. Incidents will be handled and notified where required by law and the applicable agreements.

Operational communications are sent by email and may include account notices, invoices, overdue balance notices and service notices. We do not send promotional messages or SMS; if we do so in the future, we will request any required consent and provide a simple way to unsubscribe.

11. Children and processing location

The service is intended for people authorized to manage or view unit accounts and is not designed for children under 13 to create accounts. If information improperly obtained from children is detected, FSM will investigate and take appropriate action.

We provide the service mainly in Florida, although it may also be used outside that state. Our providers may store or process data in the United States and in other countries where they operate, subject to their agreements and obligations.

12. Updates and contact

We will publish the current version with its date and notify material changes through appropriate channels. When consent is required for a new use of data, it will be requested beforehand; a change to this page will not replace that consent.

Contact: MF Center, LLC — Florida Submeters, [email protected].