This Privacy Notice discloses the practices of NWN Corporation and Carousel Industries of North America, LLC (collectively, “NWN Carousel” or “we”) concerning information we obtain by and through your use of the NWN Carousel websites (collectively, the “Website”) and our technology solutions (collectively, the “Services”). When we process information about you that was collected from our Website, we are typically acting as a data controller– meaning NWN Carousel 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 Carousel processes the information under the direction of our Clients.
Regardless of whether NWN Carousel 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 Carousel 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.
- How We Collect Information About You
- How We Use Information About You
- How We Protect Your Information
- How Long We Keep Your Personal Information
- Storage and Processing of European Personal Information Outside the EEA
- Disclosures to Third-Parties
- Links to Third-Party Websites
- Information About Children
- Do Not Track
- Your Choices and Rights
- Nevada Residents
- California Residents
- Notice Changes
- 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 Carousel 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.
Access to certain parts of our Website requires a username and password, including the Experience 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 Carousel 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.
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.
The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted and retained for 180 days. The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires (there’s a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag).
Demandbase Cookie (https://support.demandbase.com/hc/en-us/articles/360000463206-Cookie-based-identification-FAQs). The Demandbase cookies are retained for thirteen months on Demandbase systems.
Adobe Dynamic Chat Cookies collect content such as name, contact information and free text for the purposes of marketing our services to users of Dynamic Chat and is retained until a user requests their data be deleted.
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.
3. 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 Carousel 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 Carousel 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.”
4. 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.
5. 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.
6. 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 Carousel and its data controller Client, other certification mechanism approved by the European Union.
7. 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 Carousel requires these third parties to:
- only process the PII for limited and specified purposes consistent with your consent;
- 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
- notify NWN Carousel 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 Carousel. 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.
8. 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 Carousel 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.
9. Information About Children
Neither NWN Carousel’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 firstname.lastname@example.org.
10. 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.
11. 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 by submitting your request at: https://nwnit.service-now.com/gdpr_privacy_request.
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 email@example.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, downloads you may request via email, 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 Carousel as indicated below regarding the company’s use or disclosure of your PII. Unless NWN Carousel 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 Carousel 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 Carousel’s processing of your personal data based on NWN Carousel’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 Carousel 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 by submitting your request at: https://nwnit.service-now.com/gdpr_privacy_request. 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.
12. 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 firstname.lastname@example.org.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.
13. California Residents
In addition, if you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit NWN Carousel’s CCPA Privacy Notice.
14. Notice Changes
To improve the services it can offer you, NWN Carousel 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 Carousel 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.
15. Questions or Feedback
If you have any questions or comments regarding our Privacy Notice and practice, please contact us at the following email address: email@example.com or by using the contact details below:
Attn: Legal Department
659 South County Trail
Exeter, RI 02822
Carousel Industries of North America, LLC
Attn.: Legal Department
659 South County Trail
Exeter, RI 02822
Last modified: April 21, 2023