NWN Privacy Policy

LAST REVISED: January 10, 2025 

EFFECTIVE DATE: October 8, 2025

Introduction 

This Privacy Policy (“Policy”) describes how NWN Corporation, Carousel Industries of North America LLC Leverage Information Systems, Inc., InterVision Systems, LLC, and affiliates (collectively, “NWN”, “we,” “us,” or “our”) collect, use, and disclose your information when:  

  • You use our website located at www.nwn.ai and any other website or application where this Policy is posted (“Sites”);
  • We provide our technology solutions (“Services”) to our clients and prospective clients, which are generally businesses;  
  • You communicate with us in any manner, including via text, e-mail, or over the telephone; and 
  • When we interact with certain third parties, such as service providers and other vendors.

Please note the following sections that include important disclosures:

  • Nevada Residents. If you are a Nevada resident, please see our Nevada Privacy Notice below.
  • California Residents. If you are a California resident, please see our California Privacy Notice below.
  • US State Privacy Notice. If you are a resident of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, please see our US State Privacy Notice below.
  • Non-US Residents. If you are a resident outside of the United States, please see our Non-US Privacy Notice below. 
  • Cookies, Advertising, and Tracking Technology Disclosures. To learn more about how we use cookies and related technologies, see Automatic Information Collection Technologies below.
  • Your Choices. To learn more about your choices regarding your personal information, see Your Choices below.

What Type of Information Do We Collect?

We may collect the following personal information about you directly from you, automatically using certain technologies, and from third parties with whom we interact (e.g., service providers and vendors):

  • Basic Identifying Information. Full name, business e-mail, phone number, and other similar identifiers.
  • Commercial Information. Information such as the name of your business, industry, and other information relating to your organization relevant to our Services. 
  • Device Identifier and other Unique Identifiers. Information such as your device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, and other unique identifiers.
  • Website Analytics. Web page interactions, referring webpage/source through which you accessed the Site, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Sites. 
  • Audio Information. Information such as videos and recordings of your voice (such as when we record customer service calls for quality assurance).

How Do We Use Automatic Information Collection Technologies?

Our Sites and certain of our communications may include several automatic information collection technologies. Below we explain these technologies and how they are used.

What technologies do we use?

  • Cookies. Cookies are small bits of data that are stored on your browser or device that send information about your activity online to servers. Those servers could be maintained by us (i.e., first-party cookies) or by third parties (i.e., third-party cookies). We use three types of cookies – essential, performance, and advertising. Essential cookies are required for providing the Sites to you, and for remembering your preferences. Performance cookies allow us to understand how visitors use our Sites (e.g., transmitting information about the number of visitors to the Site, what pages visitors view, how long they are on the Sites, etc.). For example, we may deploy Google Analytics (maintained by Google, a third party) to provide analytics about how our Sites are used and are performing. Finally, we use advertising cookies. These cookies help us determine what advertising to delivery to you and other users of our Sites both within our Sites but also on third-party websites and platforms, such as social media.
  • Pixels. Pixels are similar but different than cookies. Pixels are code embedded in a website, video, email, or advertisement that sends information about your use to a server. This may transmit information directly, or it may allow for cookies to be placed on your device or browser. 

How do we use these technologies? 

  • Functionality, Support and Security. We may use these tools to recognize your device, facilitate navigation, display information more effectively, personalize your experience such as recognize you when you leave or return to our Sites, maintain the security of our Sites, manage your account, prevent crashes, fix bugs, save your preferences, and assist with basic Site functions.
  • Targeted Advertising, Marketing Measurements. We may use cookies and pixels to market our Services to you, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates. In addition, we may use the information we have collected from you to enable us to display targeted third-party advertisements on our Sites and on other platforms, such as social media. Some advertisements on the Sites are served by third-party advertisers, ad networks, and ad servers. These third parties may use cookies, alone or in conjunction with pixels or other tracking technologies, to collect information about you. 

How Do We Use Your Personal Information? 

  • Provide our Sites and Services to You. We use your information to provide our Sites and Services to you, including to: (1) facilitate your access and use of our Sites and Services; (2) process and fulfill your orders; (3) send you notifications relating to our Sites and Services; and (4) perform other related business functions. 
  • Communicate with You. We use your information to communicate with you, such as to respond to your requests, inquiries, issues, feedback, and to provide customer service.  
  • Market and Advertise. We use your information for marketing and advertising purposes, including sending marketing, advertising, and promotional communications to you by email, text message, or postal mail. We also use your information to show you advertisements on the Sites, to administer contests, and to send you advertising and marketing through other channels such as through social media.   
  • Conduct Analytics and Personalization. We use your information to conduct research and analytics, including to improve our Sites and the Services we offer. We also use your information to understand your interaction with our Sites, advertisements, and our communications with you. We also use your information to personalize your experience, to save you time when you visit our Sites, to better understand your needs, and to provide personalized recommendations.   
  • Security and Fraud Prevention. We use your information to detect, investigate, prevent, or take action against malicious, deceptive, fraudulent, or illegal activity. We also use your information to enforce our terms, procedures, prevent against security incidents, and prevent harm to other individuals or entities.  
  • Legal Obligations. We use your information to comply with our legal and regulatory obligations, to establish and exercise our rights, and to defend against legal claims. 
  • Business Functions. We use your information to support our core business functions, including to maintain records related to business management, loss prevention, collecting amounts owed, and identifying and repairing errors or problems on the Site.

How Do We Disclose Your Information? 

We may disclose your information:  

  • With Affiliated and Non-Affiliated Third Parties. We may share your personal information with certain affiliated and non-affiliated third parties such as service providers, advertising partners, analytics partners, subsidiaries, parent companies, and other affiliated third parties.
  • With your Employer. We may share your information with your employer relating to your engagement with our Sites and Services. 
  • To Fulfill Legal Obligations. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (i) enforce or apply our agreements; (ii) protect our interests, property, or safety of others; (iii) in connection with claims, disputes, or litigation; and (iv) to protect our Sites and Services. 
  • Business Transfers. Your information may be disclosed to a third party if we undergo a merger, acquisition, bankruptcy or other business transaction in which that third party requires such information to complete or facilitate the transaction. 
  • With Your Consent. We may disclose or share your information with your consent, which may be obtained in writing; online, through “click-through” agreements; when you accept the terms on our Sites; orally, either in person or on the phone; or by other means.

How Do We Secure Your Information?

We deploy and maintain commercially reasonable physical, technical, and organizational safeguards to protect your information from unauthorized access, use, disclosure, or destruction.

How Long Do We Retain Your Information?

We retain your personal information about you for as long as necessary to provide you with our Sites and Services, or to perform our business or commercial purposes, and to comply with applicable law. 

Your Choices

Depending on where you reside, you may have certain legal rights in relation to your information:

  • CA Residents: If you are a resident of California, please see our California Privacy Notice below. 
  • US State Privacy Notice: If you are a resident of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia please see our US State Privacy Notice below. 
  • Nevada Residents: If you are a resident of Nevada, please see our Nevada Privacy Notice below. 
  • Non-US Residents: If you are a resident outside of the US, please see our Non-US Privacy Notice below. 
  • Communications. The following is information about how to opt out of receiving certain communications from us, depending on means of delivery:
    • E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out as set out in the Contact Us section below. 
    • Phone & SMS Text Messaging. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the Contact Us section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the Contact Us section below and specifying you want to opt-out of calls.
  • Cookies and Tracking Technologies. Please be aware that if you disable or remove tracking technologies, some parts of the Sites may not function correctly. 
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. We do not currently monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. Below are links to instructions for managing cookies on commonly used browsers:
    1. Google Chrome: https://support.google.com/chrome/answer/95647    
    2. Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09    
    3. Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox    
    4. Safari (macOS): https://support.apple.com/en-us/H+T201265    
  • Analytics and Interest-Based Advertising.
    1. The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services). To opt out of us using your data for Matched Ads, please contact us as set forth in the Contact Us section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out. You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). 

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

Do We Collect The Personal Information Of Children?

No. We do not knowingly collect or solicit the personal information of children under 16 years of age. If you are a child under the age of 16, please do not attempt to register for or otherwise use the Site or provide us with any personal information. If we learn we have collected personal information from a child under 16 years of age, we will delete that information as quickly as possible. 

California Privacy Notice

California Consumer Privacy Act (CCPA)

Definitions 

  • Personal information. This is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. 
  • Sensitive personal information. This is information such as your social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications you have with us, genetic data, biometric information, health information, or information that concerns your sex life or sexual orientation. 
  • Sell, sale, or sold. This means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration. 
  • Share, shared, or sharing. This means the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. 

Rights

You have the following legal rights under the CCPA with respect to your personal information: 

  • Right to Know. You have a have a right to request that we disclose, subject to certain exceptions, information concerning: (1) the categories of personal information we have collected from or about you; (2) the categories of sources from which we have collected that personal information, and the business or commercial purpose for the collection; (3) the categories of third parties with whom we have shared, sold, or disclosed your personal information, including the business or commercial purpose for said sharing, selling, or disclosure; and (4) specific pieces of your personal information, subject to appropriate exceptions. 
  • Right to Delete. You have a right to request that we delete your personal information, subject to certain exceptions.  
  • Right to Correct. You have a right to request that we correct your personal information, subject to certain exceptions. 
  • Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against under the CCPA.

To submit these requests, please complete our Privacy Form or send an e-mail to nwnprivacy@nwn.ai. Depending on the type of right being exercised, we reserve the right to verify your identity. You may also submit requests through authorized agents. 

Notice of Collection

Notice of Sale / Sharing

We do not sell or share your personal information. We also do not have any actual knowledge of selling or sharing the personal information of any California resident who is 16 years or younger. 

Notice of Processing Sensitive Personal Information

We do not use California resident sensitive personal information for any purpose other than is permissible under the CCPA. Specifically, we do not use sensitive personal information of California residents to derive characteristics about California residents. 

California’s “Shine The Light” Law

We do not disclose California resident personal information to third parties for those third parties’ direct marketing purposes. To request confirmation of this activity, please Contact Us. 

US State Privacy Notice

Certain states outside of California, including Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, have laws in place that may grant you additional rights with respect to your personal information. If such state law applies, then this section sets out your additional rights.  

Notice of Collection 

Legal Rights 

You have the following rights enumerated under the applicable law:  

  • Right to Know and Access. You have a right to request that we disclose what personal information we’ve collected about you, subject to certain exceptions.  
  • Right to Delete. You have a right to request that we delete your personal information, subject to certain exceptions.  
  • Right to Correct. You have a right to ask that we correct the personal information it has about you, subject to certain exceptions.  
  • Right to Opt-Out. You have a right to opt-out of the sale or use of your personal information for targeted advertising or profiling.  
  • Right to Non-Discrimination. You have a right not to be discriminated against for the exercise of your rights described herein. 

To submit these requests, please utilize our Privacy Form. Depending on the type of right being exercised, we reserve the right to verify your identity. You may also submit requests through authorized agents. 

Nevada Privacy Notice

If you are a Nevada resident, you have the right to submit a request directing us not to make any sale of your personal information. To submit these requests, please send an e-mail to nwnprivacy@nwn.ai. 

Non-US Privacy Notice

Role and Data Controller Contact Details 

The European Union’s General Data Protection Regulation (“GDPR”) and related data protection laws around the world distinguish between organizations that process personal information for their own purposes (known as “controllers”) and organizations that process personal information on behalf of other organizations (known as “processors”). 

We act as a controller with respect to personal information collected from you as you engage with our Sites and Services. If you have questions with respect to our processing of your information as a controller, you can contact us at nwnprivacy@nwn.ai.

Lawful Basis for Processing 

Certain non-US privacy laws require a “lawful basis” for processing personal information. Our lawful bases include the following: 

  • To fulfill obligations in the agreement between you, and your organization and NWN. To use our Sites, you agreed to our Terms. To use our Services, your organization engaged with NWN in an agreement. We process your personal information to fulfill these contractual obligations.   
  • To pursue our legitimate interests. Our legitimate interests include, among others, understanding how our Sites are functioning, improving our Sites and Services, developing new Services, preventing fraud, and delivering the Services. Where we rely on a legitimate interest to process personal information, we carry out a balancing test to weigh the legitimate interest against your right to protection of your personal information; however, our processing of your personal information will never override your fundamental rights and freedoms, and you can always exercise your right to object to such processing. 
  • Consent. In certain situations where you provide us with consent, we may process your personal information. 
  • To comply with law. In limited circumstances, we may process personal information in order to comply with legal obligations. To the extent we have received such information from third parties with whom we have agreed to certain contractual requirements or obligations (e.g., standard contractual clauses), we will use our reasonable efforts to dispute the disclosure of personal information, unless legally required to do so. 

Onward Transfer 

If you choose to provide us with your information, you consent to the transfer and storage of that information on our servers located in the United States. The information we collect is subject to state and federal law in the United States. If you are accessing our websites from outside the United States, please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be different or less stringent than the laws of your country. 

If the GDPR applies and your data is transferred outside the relevant jurisdictions to the United States or any other country, we will transfer your personal information subject to appropriate safeguards, such as an adequacy decision by the European Commission on the basis of Article 45 of Regulation (EU) 2016/679 or Standard Contractual Clauses, as provided from time to time by the European Commission. You can receive additional information about where your personal information is transferred and the appropriate safeguards by contacting us. 

Your Data Subject Rights 

You have the right to:  

  • Access, rectify, or erase any personal information we process about you; 
  • Data portability – that is, asking us to transfer your personal information to any third party of your choice; 
  • Restrict or object to our processing of your personal information; and 
  • Where applicable, withdraw your consent at any time for any processing of your personal information. 

To exercise your rights, please send an e-mail to nwnprivacy@nwn.ai. Depending on the type of right being exercised, we reserve the right to verify your identity.  

Complaints 

If you have a complaint about our use of your personal information or our response to your request(s) regarding your personal information, you may submit a complaint to the Data Protection Supervisory Authority in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator and welcome you to first direct an inquiry to us. 

In addition to our contact details set out above, you can also contact our Designated Individual Overseeing Compliance of this Privacy Policy by emailing nwnprivacy@nwn.ai. 

Accessibility 

If you require a copy of this Privacy Policy in an alternative format, please email us at nwnprivacy@nwn.ai.

Contact Information

If you have any questions or comments about this Privacy Policy, please contact us at nwnprivacy@nwn.ai  or by using the contact details below:

NWN Corporation
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

Leverage Information Systems, Inc.
Attn: Legal Department
659 South County Trail
Exeter, RI 02822

InterVision Systems, LLC.
Attn: Legal Department
659 South County Trail
Exeter, RI 02822