Who we are

Our website address is: https://www.nwnit.com/.

NWN Corporation Privacy Notice

This Privacy Notice discloses the practices of NWN Corporation (“NWN” or “we”) concerning information we obtain by and through your use of the NWN website (“Website”) and our technology solutions (“Services”).  When we process information about you that was collected from our Website, we are typically acting as a data controller– meaning NWN determines how and why the information is being processed.  However, our Services are primarily directed to our clients (“Clients”) and prospective clients, which are generally businesses.  When we process information about you that was collected through your use of our Services, we are typically acting as a data processor– meaning NWN processes the information under the direction of our Clients.

Regardless of whether NWN is acting as a data processor or data controller though, we are committed to respecting your privacy and takes seriously its task in providing appropriate protection and management of your information. The purpose of this Privacy Notice is to explain the types of information NWN obtains about visitors to our Website and users of our Services, how the information is obtained, how it is used, and your choices and rights regarding your personal information.

Topics:

  1. How We Collect About You
  2. Cookies
  3. How We Use Information About You
  4. How We Protect Your Information
  5. How Long We Keep Your Personal Information
  6. Storage and Processing of European Personal Information Outside the EEA
  7. Disclosures to Third-Parties
  8. Links to Third-Party Websites
  9. Information About Children
  10. Do Not Track
  11. Your Choices and Rights
  12. Notice Changes
  13. Questions or Feedback

 

  1. How We Collect Information About You

The information we collect through your use of our Website and Services generally falls into two categories: Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”).  If we combine Non-PII with PII, the combined information will be treated as PII for as long as it remains combined.

Personally Identifiable Information (PII)

PII refers to information that lets us know the specifics of who you are.

PII Collected Through Website. The PII we collect through our Website generally relates to your identity and contact information, such as, your name, company name, job title, company address, e-mail address and phone number. We may request PII when you register on the Website, purchase or utilize Services that we offer, or when you request or receive information regarding our Services.  We collect PII only when you voluntarily provide it to us so if you do not want us to use or collect this information, please do not provide us with it.  If you choose not to provide the information we request, you may be unable to use or access certain content on our Website.

PII Collected Through Services. The PII we collect through your use of our Services generally relates to your identity and contact information, such as, your name, company name, job title, company address, e-mail address and phone number.  Our processing of this information is subject to agreements NWN has with our Clients, who control whether and to what extent our Services process your PII.

Non-Personally Identifiable Information (Non-PII)

Non-PII refers to information that does not by itself identify a specific individual. The Non-PII we collect when you visit our Website may include the Uniform Resource Locator (“URL”) of the Web site that you came from before visiting our Website, which pages you visit on our Website, which URL you go to next, which browser you used to come to our Website, your Internet Protocol (“IP”) address, your device ID, and any search terms entered on our Website.  Our Website may automatically collect Non- PII, including the web page from which a visitor enters our Website, which pages a visitor visits on our Website, and how much time a visitor spends on each page, etc.

Passwords

Access to certain parts of our Website requires a username and password, including the Enterprise Management Platform. A username and password permit us to track certain information, such as software license operations. You are responsible for any action connected with the use of your password, and you should not share your password with anyone. To request a new password, please follow the instructions on the relevant Website login page.  NWN customers with a current maintenance agreement may request customer support via our Website. For customer support, a customer will generally be required to submit his/her name, Organization ID and contact information, such as phone number, email address and/or facsimile number.

 

  1. Cookies

A cookie is a small piece of data that your internet browser places on your device so that it can be recognized when it returns in the future. We use cookies and similar technologies to secure our Website, remember your preferences, and personalize content for your future visits.

Some of the most common cookies, along with their primary purposes, that we use on our Website are listed below:

Google Analytics (_ga, _gid). In order to market to anonymous visitors, we use Google Analytics to support digital advertising using data collected from Website visitors as they anonymously browse the Websites. We use the data from Google Analytics to ensure that our marketing is targeting the appropriate Website visitors. Website visitors may use the Ads Settings to opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by going to https://www.google.com/settings/ads. Google Analytics’ currently available opt outs are available at https://tools.google.com/dlpage/gaoptout/. Third-party vendors, including Google, may show our ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics Cookie) and third-party cookies (such as the Double Click cookie) together to inform, optimize, and serve ads based on your past visits to the Websites.

TechTarget (TS01fac3f6). TechTarget cookies may be used to build a profile of your interests in order to show you advertisements that may be relevant to you on other sites.

Drift (driftt_aid, driftt_sid, DFTT_END_USER_PREV_BOOTSTRAPPED). Drift uses cookies to enable tracking on our Website in order to provide enhanced functionality and personalization of your experience.

Third-parties may also set cookies when you visit our Website.  For example, NWN hires companies to provide us with various business services, such as Website analytics, place cookies when you visit our Website.  In addition, companies that deliver content to our Website, such as videos or ads, set their own cookies.  Some of the most common third-party cookies, along with their primary purposes, that we use on our Website are listed below:

Pardot (“visitor_id” plus a unique identifier).  Pardot session cookies is a Salesforce service and composed of a unique visitor ID.  They are used to track visitors and visitor preferences, such as form field values.

New Relic.  New Relic cookies sets one or more cookies in your browser in order to measure the technical performance of our web.

These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across various platforms.

Most browsers automatically accept cookies, but you can usually refuse cookies, or selectively accept certain cookies, by adjusting the preferences in your browser.  If you turn off or refuse cookies, there may be some features of our Website that will not be available to you, and some portions of the Website may not display properly or be less personalized.

  1. How We Use Information About You

Our primary goals in collecting information from and about you are to provide a customized experience on our network of sites, including personalization services, interactive communications, business transaction information, and other types of services.  Specifically, we use your information for the following purposes:

Provide You with Services You or Our Clients Request.  Communicate with you regarding our Services, including responding to your questions and concerns.  For example, we may need to use your contact information for customer support purposes.

Marketing Messages.  Communicate with you about additional Services that may be of interest to you, and other marketing communications.  For example, we may use your email address to communicate with you regarding our Services or Services that you use or request, or to provide you with information that may be of interest to you relating to NWN Services, events, or topics in our industry.  Please see the section entitled “Your Rights and Choices” for an explanation of your choices related to these communications.

Personalize Your Website Experience.  Provide you with the all features and functions of the Website, and provide all users a smooth, efficient, and personalized experience while using our Website.

Compliance Investigations.  We may use the information you provide during registration with us to monitor the proper usage of our Website, including detecting, investigating and preventing activities that may violate our policies or applicable laws.

Market Research.  We may use your information to improve our existing Services and the content of our Website, and research and develop new offerings. Unless otherwise specified and agreed to, most of these research and development activities will only use anonymous and aggregate data and not your PII.  In circumstances in which your PII will or may be used for research or development purposes, we will ask for your explicit consent to do so.

Cookies.  Perform activities described in the section entitled “Cookies.”

The Lawful Basis for Processing European Personal Information

When we collect information about you through our Website, the lawful basis on which we process your personal information is our legitimate interests, namely, to provide you with information marketing our Services.  We do not disclose your contact information to third-parties for their marketing purposes.  When we collect information about you through your use of our Services, the lawful basis on which we process your personal information is because it is necessary to perform contractual obligations to you or our Clients (i.e. processing the data is necessary in order for us to provide you or our Clients with Services).  In addition, we may process your personal information in order to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements and for the establishment, exercise or defense of legal claims.

No Sale of Personal Information for California and Nevada Residents

NWN does not sell your personal information under California or Nevada law, which defines certain disclosures of personal data for monetary or valuable consideration as “sales.”

  1. How We Protect Your Information

We use reasonable, standard industry technological and physical safeguards to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration and destruction.  We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.  Transactions, access to transactional records, or access to account information occurs over a server that has safeguards such as secure server software (SSL) which encrypts information before transmission. You can confirm that pages are encrypted, and we urge you to do so before submitting or transmitting sensitive information, by viewing the lock icon on the bottom of most browsers.  However, no safeguards are infallible.

  1. How Long We Keep Your Personal Information

In general, we will only retain your information for the time necessary to realize our legitimate business purposes and to comply with the law.  However, we may continue to store anonymous or anonymized information, such as Website visits without identifiers, in order to improve our services.

  1. Storage and Processing of European Personal Information Outside the European Economic Area (EEA)

If you are located in the EEA, please note that as part of our service, we may transfer your personal information to other regions, including to the United States.  We protect our transfers out of the EEA with approved legal safeguards that may include Standard Contractual Clauses and other contract terms executed between NWN and its data controller Client, other certification mechanism approved by the European Union.

  1. Disclosures to Third-Parties

Generally speaking, we do not share your PII with third-parties unless those third-parties are providing you with a service on our behalf or we have otherwise partnered with those third-parties.  NWN requires these third-parties to:

  1. only process the PII for limited and specified purposes consistent with your consent;
  2. provide the same level of protection for PII as is required by the law applicable to such information, including, as applicable, the privacy principles of the General Data Protection Regulation (“GDPR”) and similar laws and regulations; and
  3. notify NWN and cease processing PII (or take other reasonable and appropriate remedial steps) if the company determines that it cannot meet its obligation to provide the same level of protection for PII as is required by applicable law.

We do not disclose your PII to third-parties for their direct marketing purposes.

In certain circumstances, we may share your information with third-parties, including the following:

Service Providers, Affiliates, Agents and/or Business Partners.  We may use other companies to perform certain services including, without limitation, facilitating some aspects of our Website or Services, such as processing credit card transactions and/or sending emails, as well as hosting and maintenance, billing, customer relationship services, database storage and arrangement, and direct marketing campaign services.  We share your information with these service providers only as necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third-parties to maintain the privacy and security of your data.

Special Circumstances.  We also may disclose your information, including PII, in the following circumstances:

  • Required by Law. In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency or as otherwise required by applicable law.
  • Protect the Rights and Property of NWN. To establish or exercise our legal rights and/or to defend against legal claims.
  • Maintain Security. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
  • Enforce our Website Policies. To enforce our Website’s terms and conditions or other agreements or policies.
  • Corporate Transaction. In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy.

 

If we anticipate disclosure of your information to any third-party other than those set forth above, you will be given an opportunity to opt out of disclosure of your information.  However, you cannot opt out of disclosure of your personal information if required by lawful order.

 

  1. Links to Third-Party Websites

Our Website may contain links to third-party sites, over which we have no control (for example, social media platforms like Facebook, Twitter, LinkedIn, or YouTube).  NWN is not responsible for the content on, or information collected by, third-party websites that can be reached through links from our Website.  You access these third-party sites and services at your own risk and when your leave our Website, we encourage you to read the privacy statements of any linked site or integrated service before disclosing any personal information on such site and/or through such service. This Privacy Notice applies solely to information collected by a Website on the domains owned and controlled by us.

  1. Information About Children

Neither NWN’s Website nor its Services is intended for use by children, particularly those under age 16, and we do not knowingly collect information from children.  If we become aware that a child under 16 has provided us with their PII, we will delete such information as quickly as possible.  If you believe that we might have collected any information from a child, please contact us at nwnprivacy@nwnit.com.

  1. Do Not Track

Your browser may allow you to set a “Do Not Track” preference. We currently do not respond to “Do Not Track” or similar signals.

  1. Your Choices and Rights

You have several choices regarding the use and disclosure of your information.

Information You Provide.  With respect to the collection of your information, if you do not want your PII collected, please do not submit it to us. If you have already submitted information and would like to review, correct or remove it from our records, please contact us at nwnprivacy@nwnit.com.

Marketing Messages.  We may send you marketing communications, about our Services that may interest you.  You can opt out of our marketing communications at any time by selecting the “unsubscribe” link in the e-mail or contacting us at nwnprivacy@nwnit.com. Please note that some non-marketing communications are not subject to general opt-out, such as communications relating to Services we are providing you or our Client, sales transactions, software updates and other support related information, patches and fixes.

Cookies.  If you wish to disable cookies, you can set your browser not to accept cookies as described in the section entitled “Cookies.”

Information Shared with Third-Parties.  You may also choose whether your PII may be used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. You may contact NWN as indicated below regarding the company’s use or disclosure of your PII. Unless NWN offers you an appropriate choice, we use PII only for purposes that are materially the same as those indicated in this Privacy Notice.

Rights for European Economic Area (“EEA”) Residents

In addition, if you are a resident of the EEA, you have the following rights:

  • Right of Access. Find out if we use your personal data, access your personal data and receive copies of the PII that we collect and retain about you.
  • Right to Rectification. Access your personal data and have it corrected or amended if it is inaccurate or incomplete.
  • Right to Erasure. Request your personal data be deleted or restricted under certain circumstances.  For example, if NWN is using your personal data on the basis of your consent and has no other legal basis to use such, you may request your personal data be deleted when you withdraw your consent.
  • Right to Restriction of Processing. If you believe your personal data is inaccurate, unlawful, no longer necessary for our business purposes, or if you object to our processing of your personal data, you also have the right to instruct us to restrict the processing of your data pending our investigation and/or verification of your claim.
  • Right to Data Portability. Obtain a transferable copy of some of your PII which can be transferred to another provider when the personal data was processed based on your consent.
  • Right to Object. Object to NWN’s processing of your personal data based on NWN’s legitimate interest or legal and regulatory obligations as further set out the section entitled “The Lawful Basis for Processing European Personal Information,” which NWN will review as to whether we have a prevailing interest or legal and regulatory obligations in processing your personal data.

In addition, if we process any of your personal data based on your consent, you have the right to withdraw your consent at any time without penalty.

If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal data, please contact us at nwnprivacy@nwnit.com. If you are not satisfied with our response, or believe we are processing your personal data in violation of the law, you have the right to lodge a complaint with your local data protection authority.

Rights for Nevada Residents

Under a Nevada privacy law (SB 220), certain Nevada residents may opt out of the sale of certain categories of PII.  As of the effective date of this Privacy Notice, we do not sell PII covered by that law.  However, if you are a Nevada resident who would like to opt-out of any future sale of your information in the unlikely event we change our practices, you may do so by contacting us at nwnprivacy@nwnit.com.

Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact you if needed to verify your identity and the authenticity of the request.

  1. Notice Changes

To improve the services it can offer you, NWN may opt to expand its capabilities for obtaining information about users in the future or may change the ways in which it collects, uses, processes or shares information.  NWN will update this Privacy Notice continually to ensure that you are aware of developments in this area.  We will post those changes here so that you will always know what information we collect online, how we use it, and what choices you have.  Please be sure to check this page before proceeding to use our Website or using our Services.  Any material changes will be communicated via notice on the Website.

  1. Questions or Feedback

If you have any questions or comments regarding our Privacy Notice and practice, please contact us at the following email address: nwnprivacy@nwnit.com or by using the contact details below:

NWN Corporation

Attn: Legal Department

271 Waverley Oaks Road
Waltham, MA, 02452

Last modified: March 30, 2020

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