CCPA – Privacy Notice for California Residents

Privacy Notice for California Residents

Effective Date: October 13, 2020
Last Reviewed on: April 21, 2023

This Notice supplements the information contained in NWN Carousel’s Privacy Policy, available at https://nwncarousel.com/privacy-policy/, and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Notice.

1. Information NWN Carousel Collects

As detailed in NWN Carousel’s Privacy Policy, we collect different personal information from you depending on how you want to engage with NWN Carousel.  We do not collect sensitive personal information, including:

• Government identifiers (social security, driver’s license, state identification card, or passport number);
• Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password); 
• Precise geolocation;
• Religious or philosophical beliefs;
• Union membership;
• Genetic data;
• Mail, email, or text messages contents not directed to us;
• Unique identifying biometric information; and/or
• Health, sex life, or sexual orientation information

We have collected personal information from the categories of personal information listed on the table below from consumers within the last twelve (12) months.  The table also lists, for each category, our expected retention period. 

Personal Information Category	Collected	Examples	Expected Retention Period
Identifiers.	YES	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.	Perpetual as we continually use this information for marketing our products/ services to  website visitors.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	NO	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	N/A
Protected classification characteristics under California or federal law.	NO	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	N/A
Commercial information.	YES	products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Perpetual as we use this data to market new services to website visitors.
Biometric information.	NO	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	N/A
Internet or other similar network activity.	YES	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Perpetual as we use this data to market our services to website visitors.
Geolocation data.	NO	Physical location or movements.	N/A
Sensory data.	NO	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A
Professional or employment-related information.	NO	Current or past job history or performance evaluations.	N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N/A
Inferences drawn from other personal information.	NO	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes..	N/A

We will not sell the personal information we collect. We also will not share it with third parties for cross-context behavioral advertising. 

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

To review how we obtain the categories of personal information listed above and to review what information we share, and with whom, read the “How We Collect Information About You” and “How We Use Information About You” sections of our Privacy Policy.  We will not collect additional categories or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

2. Sharing Personal Information

We may disclose your personal information to third-parties for a variety of business purposes.  In the preceding twelve (12) months, NWN Carousel has disclosed the following categories of personal information for a business purpose:

• Identifiers.
• California Customer Records personal information categories.
• Internet or other similar network activity.
• Geolocation data.

We may disclose your personal information to a third-party service providers for a business purpose.  For more information on how we may share and disclosure your personal information, read the “Information About You” section of our Privacy Policy.

In the preceding twelve (12) months, NWN Carousel has not sold any personal information.

3. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Your Right to Know and Receive Copies of Your Personal Information

You have the right to know certain information about our collection and use of your personal information over the past twelve (12) months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, selling, or sharing that personal information.
• The categories of third parties to whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Your Right to Request We Delete Your Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, unless retaining the information is necessary for us or our service provider(s) to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Your Right to Correct Your Personal Information

You have the right to ask us to correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

How To Exercise Your California Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either: 

• Calling us at 877-342-8207
• completing your request at: https://nwnit.service-now.com/gdpr_privacy_request

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) months period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us.  However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receiving the request.  If we need more time (up to 90 days), we will tell you how much additional time we need and explain the reason in writing.

If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the twelve (12) months period preceding our receipt of the verifiable consumer request. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

4. Non-Discrimination

We will not discriminate against you, deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA rights. Unless permitted by the CCPA.