Privacy Policy

This Privacy Notice describes the privacy practices of Eugene Residents for Energy Choice, a community coalition formed by Northwest Natural Gas Company (the “coalition”, “we”, “our”, or “us”) and applies to the personal information that the coalition collects and uses relating to consumers and website users (“consumer” or “you”). The coalition is a collaboration with named partners and is not paid for by NW Natural Gas customers.

Personal information is information (data, derived data, or any unique identifier) that is linked to or is reasonably linkable to a consumer or device (that identifies, is linked to or is reasonable linkable to one or more consumers in a household) (“personal information”). Personal information does not include:

Information from government records or through widely distributed media.
Information we understand to have been made publicly available by you.
De-identified information that cannot be used to infer information about, or otherwise be linked to, an identifiable consumer or device.

This Privacy Notice does not apply to personal information collected and used by NW Natural Gas Company in relation to providing services and products as a regulated utility in Oregon and Washington, which are separate from our community coalition advocacy activities. Please refer to nwnatural.com for the privacy notice that describes the privacy practices applicable these activities. These privacy practices and security protections also do not apply to any third-party websites or services we have provided for your convenience. We encourage you to check the privacy and security provisions of those websites before you use them.

Personal information we collect

We collect the following categories of personal information from consumers:

Category	Examples
Personal Identifiers	A real name, alias, postal address, phone number, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
Characteristics, including protected classification characteristics	Age, gender, marital status, income, political affiliation.
Location Information	Approximate geolocation of your device, such as from your IP address.
Inferences Drawn From Other Personal Information	Profile reflecting a person's preferences or tendencies.
Internet or other similar network activity	Browsing history, IP address, website session log data, search history, Device ID, referring URL, operating system, browser type, information regarding your interaction with our website, including interactions with specific web pages.
Cookies and Tracking Technologies	Information from cookies, pixels, web beacons, and other similar tracking technologies to enable essential features or for data analytics and marketing purposes. This includes the use of social media tracking technologies and Google Analytics.

Children’s Privacy

Our advocacy activities are not directed to children under 16 years of age, and we do not knowingly collect any information from any individual under 16 years of age. If you are under 16 years of age, please do not use this website or give us any personal information. If you believe a child under 16 years of age has provided us with personal information, please contact us at the email in the Contact information section and the end of this privacy notice with a brief description of your concern.

How we collect personal information

We obtain the categories of personal information listed above from the following categories of sources:

Directly or indirectly from you. For example, from forms that you provide to us during our canvassing activities, from information you provide when you opt-in to receipt of communications from us, or when you otherwise engage with us regarding our coalition advocacy activities.
Directly and indirectly from activity on our website. For example, from website usage details collected automatically via cookies and online tracking technologies.
From third-parties and service providers that we interact with in connection with our community coalition advocacy activities. For example, from government agencies (including via publicly available records), data analytics providers, market researchers, or marketing providers.

Use of personal information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided.
To provide you with alerts, event registrations and other notices via email, direct mail, phone, SMS, or text, concerning our coalition advocacy activities, or events or news, that may be of interest to you.
To perform marketing activities such as notifying you about our advocacy activities, providing advertisements, conducting market research and surveys.
To create prospect lists to support our coalition advocacy activities.
To improve our websites and present their contents to you, including through the evaluation of user interactions with the website and analytics.
As otherwise set forth in this Notice or (see Disclosure of personal information section below).
To exercise or defend legal claims, or otherwise comply with legal or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
For any purpose for which we obtain your consent.

We will not use the personal information we collected for purposes that are not reasonably necessary for and compatible with the purposes listed above without obtaining your consent.

Profiling, Sale, and Targeted Advertising

Purpose	Description
Profiling	The coalition does not conduct profiling in furtherance of “decisions that produce legal effects or effects of similar significance” as that term is defined under Oregon law. However, the coalition may conduct profiling to draw inferences regarding your preferences or tendencies.
Targeting Advertising	We use social media sites such as Facebook to communicate with you about our advocacy activities. These sites may allow us to present specific advertisements to you based on the personal information that both we and the social media sites collect and maintain about you through the use of cookies and online tracking technologies. . In addition, as described under the ‘Information we collect’ section of this Privacy Notice, our websites and mobile applications may also use cookies, web beacons and other similar tracking technologies for data analytics and marketing purposes. Refer to the section regarding Your Consumer Rights and Choices for how you may opt out of Google analytics and interest-based advertising. You may also remove cookies through your browser’s “Options” or “Preferences” screen. However, removing cookies may reduce performance or prevent use of some features on our websites.
Sale of Data	We do not sell or share your personal information for monetary consideration. However, under some circumstances a transfer of personal information to a third party without monetary consideration may be considered a “sale” under Oregon law. This includes the sharing of your personal information with social media sites for the purpose of providing you with these customized ads. Refer to the section regarding Your Consumer Rights and Choices for how you may opt out of these transfers.

Disclosure of personal information

We may disclose your personal consumer information to a third party for a business purpose, or other purposes described below.

Categories of third parties to whom we may disclose personal information

Law Enforcement and Governmental Authorities Pursuant to Legal Requirements - The coalition will disclose personal information to the extent disclosure is legally required. This includes but is not limited to responding to requests by law enforcement officers, subpoenas, and requests during regulatory proceedings, and circumstances where a law, regulation, or tariff requires disclosure. To respond to law enforcement requests and as required by applicable law, valid warrant, subpoena, court order.
Third-Party Service Providers and Contractors - We may disclose personal information to third party service providers, or contractors performing work or providing services to or on behalf of the coalition. This may include, for example, cloud services providers, marketing service providers, software-as-a-service providers, and professional advisors. Third party service providers and contractors must execute a contract that describes the purpose of the disclosure and requires the recipient to both keep that personal information confidential.
Advocacy Campaigns - We may disclose personal information to other organizations, campaigns, groups, or causes that we believe have similar advocacy viewpoints, principles, or objectives or share similar goals and with organizations that facilitate communications and information sharing among such groups.
Analytics Providers - We use selected third parties to collect information about how you interact with our website and apps. This information may be used to, among other things, improve the functionality of our website and services.
Other Disclosures with your Consent - You may authorize other companies or persons to receive your personal information from us.

Categories of Personal Information Shared

Identifiers

Characteristics

Location Information

Inferences Drawn From Other Personal Information

Internet or Other Similar Network Activity

Cookies and Tracking Technologies

Your consumer rights

Oregon and other state laws provide consumers with specific rights regarding their personal information. This section describes the rights of Oregon residents, explains how they may exercise those rights, and extends to residents of states with laws that also provide these consumer rights to the extent those laws apply to us. This information may or may not be applicable to you depending upon your state of residency.

Access to Specific Information and Portability Rights

Oregon residents have the right to request that we disclose certain information to them about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you the information you requested, which may include:

Confirmation as to whether we have processed your personal information.
The categories of personal information we have processed about you.
To whom we may have disclosed personal information.
A copy of your personal data that we have processed (also called a data portability request).

Correction and Deletion Request Rights

Oregon residents have the right to request that we correct or delete personal information that we collected and retained from consumers, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception provided under applicable law applies.

Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by completing the web form at https://ow.ly/Iyjg50SQFko .

Only you 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.

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 agent.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Opt-out Rights

You or another person submitting a verifiable request on your behalf (an “authorized agent”) may submit a request to opt out of the processing or your personal information as described in the “Your opt-out rights” section.

Verification

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

Response Timing and Format

We will respond to a verifiable consumer request within 45 days of its receipt, delivering our written response by mail or electronically, at your option. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable. You have the right to appeal a denied request as described below. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity.

Fees

We do not charge a fee to process or respond to one verifiable consumer request in any 12-month period. If we determine that any second or subsequent request warrants a fee, we will provide you with a cost estimate before completing your request.

Appeals

If we deny your consumer request, you have the right to appeal our decision. Within a reasonable period of time following the receipt of our decision, please submit your appeal in writing via email to [email protected] or postal mail to the contact information provided at the end of this notice. We will review your appeal and respond in writing within 45 days of receipt, informing you of any actions taken or the reasons for not taking action in response to your appeal. If we deny your appeal, you may contact the Oregon Attorney General Consumer Protection Division to submit a complaint.

Your opt-out rights

Coalition communications – You may opt-out of receiving direct informational or promotional communications from us, such as SMS messages, via https://ow.ly/YWRt50SQFm9.

Sale of Personal Information - Oregon and other state laws require businesses to provide a method for consumers to opt out of the “sale” of their Personal Information. We do not sell your personal information for monetary consideration, as described in this Privacy Notice. However, under some circumstances a transfer of personal information to a third party without monetary consideration may be considered a “sale” under Oregon law. You may opt-out via https://ow.ly/8xS950SQFlw .

Interest-based Advertising - You may opt out of certain interest-based advertising via https://ow.ly/BWHr50SQFlh or by using the following resources:

(a) You may opt-out of having your activity on our websites and services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser. You may also opt-out of Google Analytics advertising features by visiting Ad Settings in your Google Account and following the instructions to adjust your ad settings, including opting out of personalized ads and data collection.

(b) You can remove cookies through your browser’s “Options” or “Preferences” screen. However, removing cookies may reduce performance or prevent use of some features on the websites.

(c)You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

(d) You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

Do Not Track and Universal opt-out signals

"Do Not Track" or Universal opt-out signals are used by some web browsers to attempt to limit tracking related to your visits to a website. To the extent that your browser broadcasts a "Do Not Track" or Universal opt-out signal, our website is not currently designed to recognize these signals.

Security

We take reasonable and appropriate measures designed to protect your personal information and our systems and strive to comply with laws applicable to securing personal information. To accomplish this, we have implemented administrative, technical, and physical security safeguards to help protect your personal information from unauthorized access, loss, destruction, misuse, or alteration, which we update regularly. Despite these measures, you should be aware that no method of transmission over the Internet or method of storing data is 100% secure, and we cannot guarantee security.

Changes to our privacy notice

We may update this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website.

By providing us with personal information and using our websites, you agree to the practices described in this Privacy Notice and to the updates to this Notice posted here from time to time. To make sure you stay informed of all changes, you should check this Notice periodically. Updates will be referenced by the “Last Updated” date shown at the end of this Notice.

Contact information

If you have any questions or comments about this Privacy Notice, please do not hesitate to contact us at:

Email: [email protected]

Webform: https://ow.ly/qIwh50SQFjv