NORTH AMERICAN INTERCONNECT, LLC. WEBSITE PRIVACY POLICY

Introduction

North American Interconnect, LLC. and its affiliates (collectively, “NAI,” or “we,” “us,” “our”) respect your concerns about personal data protection and value our relationship with you. This Website Privacy Policy (the “Policy”)  applies solely to personal data collected through NAI web sites, web pages, portals, gateways, interactive features, applications, telephone support lines, e-mail, widgets, blogs and their respective contents in addition to our Twitter, Facebook or other social networking sites, and their respective contents (collectively, the “Website”), whether accessed via computer, mobile device or other device (collectively, “Device”) .

This Policy describes the types of personal data we collect through the Website and how that personal data may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your contact information, access and control the use of the personal data we collect in connection with our marketing communications and activities, or get answers to questions you may have about our privacy practices at the Website. Please read this Policy carefully, because by using the Website you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Use, which governs your use of the Website and any content you submit to the Website.

Definitions

Except as otherwise defined in this Policy, capitalized terms have the meanings set forth herein.

“Identifiable natural person” means a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

“Personal data” or “personal data” means any information about an identified or identifiable natural person.

Compliance with Local Laws

This Policy is meant to guide NAI with respect to personal data collected from or about you at this Website.  While this Policy applies to personal data generally, the local laws, rules and regulations of jurisdictions that are applicable to NAI (“Local Laws”) may require standards which are stricter than this Policy and, in such event, NAI will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.

Collection and Use of Personal Data

The privacy and security of the personal data that NAI collects from you is a priority for NAI.  Generally you can visit the Website without providing personal data, unless otherwise mentioned in the Website itself. However there may be circumstances when you may be asked or choose to provide personal data that could reasonably be used to contact you or to identify you personally such as your name, home or business address, telephone number, or e-mail address through the Website. By submitting personal data to NAI at this Website, you hereby consent to NAI’s collection, use and disclosure of such personal data. 

NAI collects and uses personal data for the following purposes:

  • NAI may collect and use personal data that you submit at our Website to communicate with you, better understand your needs, and to provide you with better service.  For example, when you visit our websites, or send e-mails to NAI, you are communicating with us electronically and may be submitting personal data to NAI.  We may use this personal data to communicate with you either electronically, by e-mail, or using other means. 
  • By way of example, NAI may collect and use personal data that you submit at our Website when you (1) register with NAI for the customer gateway, (2) register your e-mail address with us, (3) opt-in to receive newsletters, (4) send e-mail messages or feedback, submit forms or transmit other information by e-mail, or (5) complete a survey.  If you elect to engage in such activities, we may ask that you provide us personal data, such as your first and last name, mailing address (including zip code), company name, e-mail address, telephone and facsimile numbers, and other personal data.  If you do not provide certain personal data with respect to a particular activity, you will not be able to engage in that activity.
  • We may also use your personal data that you submit to provide you with a more efficient and customized experience, process your orders, improve our marketing and promotional efforts, statistically analyze Website use, improve our service offerings, and enhance our Website’s content, layout, and services.  We may contact you regarding administrative notices and/or send you occasional e-mails or regular mail regarding our services, and special offer that may be of interest to you.  If you do not wish to receive this information, please click on the “Unsubscribe” link shown on all our e-mails and electronic newsletters to you or contact us at the address or telephone number listed herein and we will remove your name from our mailing lists. 
  • To help NAI improve your experience on our Website NAI may also track your use of our Website.  We may collect certain non-personally identifiable information about you based upon how you search and interact with our Website, including which pages you view while visiting our Website.  For system administration and statistical analysis purposes, this information is compiled and analyzed on both a personal and an aggregated basis.  This information may include a website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, general geographic location, device type, what browser you are using, Internet service provider, date/time of visit information, operating system, and your Internet Protocol (“IP”) address, which tells us the country and state you are searching our Website from.  A URL is the global address of documents and other resources on the World Wide Web.
  • We also collect, or enlist a third party service provider to collect, store, process and manage certain non-personally identifiable information to diagnose problems with our servers and software, administer our Website, connect you to the credit card payment platform and gather and analyze demographic and other statistical information.  Our third party service providers may also provide us with summary, but not individual, reports that will tell us how our Website is being used.  We may also share such aggregate statistical and demographic information with select third parties, such as our partners; however, these reports do not contain any personal data.
  • Any information you give us through this Website may be transmitted to servers outside the country where the information is entered, and may be used, stored, and processed outside the country where it was entered.  As you browse our Website, our servers may collect information about your visit. For example, to help us better serve you and improve our Website, we may monitor statistics such as how many people visit our Website, which pages people visit on our Website, and which browsers people use to visit our Website. 

NAI also may use and disclose your personal data:  (1) to the extent required to respond to a legal or ethical obligation, (2) to the extent necessary to meet national security, public interest or law enforcement obligations, and (3) to the extent expressly permitted by an applicable law, rule or regulation.

Of course, you may choose not to provide NAI with personal data.  However, this choice may prevent NAI from providing you with the product, service, or other information you requested or that could be offered to you.

NAI may use your personal data as set forth in this Policy (or any other NAI policy, as applicable), and for any other purposes for which your consent is required under applicable law so long as NAI obtains your consent. 

Additionally, where NAI is permitted to do so under applicable law, NAI may share your personal data with its affiliates, employees, contractors, consultants and other parties who assist NAI including, without limitation, parties that provide information technology and data processing services to NAI with respect to the operation of its businesses. 

Where NAI is permitted to do so under applicable law, NAI may transfer or provide your personal data to affiliates or third parties both in and outside of the nation where you reside.

Additionally, your personal data may be disclosed as required by applicable law, to comply with a court order, subpoena, warrant or other legal process, or where the personal data is publicly available (unless otherwise restricted by applicable law).

Cookies

Like many websites, NAI uses “cookies” and similar tools on the Website to improve its performance and enhance your user experience.

What are Cookies?

A cookie is a small text file which is placed on your Device. Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain cookies may contain personal data – for example, if you click to “remember me” when logging in, a cookie may store your username. Most cookies won’t collect personal data that identifies you, and will instead collect more general information, such as how users arrive at and use our Website, or a user’s general location.

What do we use Cookies for?

NAI may place cookies or similar files on your Device for security purposes, to tell us whether you have visited the Website before, to remember your language preferences, if you are new visitor or to otherwise facilitate site navigation, and to personalize your experience while visiting our Website. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our Website and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Website. Cookies may enhance your online experience by saving your preferences while you are visiting a particular Website. Overall, cookies help us provide you with a better Website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your Device or any information about you, other than the data you choose to share with us.

What kinds of Cookies do we use?

Generally, the cookies that are used on the Website can be broken down in to the following categories:

  • Session Cookies - These cookies are used 'in-session' each time you visit and then expire when you leave a Website or shortly thereafter: they are not stored on your Device permanently, do not contain any personal data and help by minimizing the need to transfer personal data across the internet. These cookies can be deleted or you can refuse to allow their use, but this will hamper the performance and your experience in using the Websites. These cookies also take time stamps that record when you access a Website and when you leave a Website.
  • Tracking Cookies - These cookies enable us to recognize repeat visitors to our Website. By matching an anonymous, randomly generated identifier, a tracking cookie keeps track of where a user of our Website came from, what search engine they may have used, what link they clicked on, what keyword they used and where they were in the world when they accessed a Website. By monitoring this data, we can make improvements to our Website.
  • Persistent Cookies - This type of cookie is saved on your Device for a fixed period (sometimes for a few hours, sometimes for a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to remember who you are for more than one browsing session. For example, this type of cookie can be used to store your preferences, so that they are remembered for the next visit to a Website.
  • Performance or Analytical Cookies - Performance cookies are used to analyze how the Website is used and to monitor its performance, which allows us to improve your experience in using the Website. These cookies help us to tailor the content of the Website to reflect what the Website users find most interesting and to identify when technical issues with the Website arises. We may also use this data to compile reports to help us to analyze how a Website is used, what the most common issues are and how we can improve the Website.

Can the Cookies be blocked?

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Website may not work properly because we may not be able to recognize and associate you with your NAI account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Instructions for blocking or allowing Cookies in Popular Web Browsing Software

  • Internet Explorer 7 and 8
  • Firefox
  • Google Chrome
  • Apple Safari
  • AboutCookies.org

Opting-out

Even after you have consented to NAI’s collection and use of your personal data and submitted personal data to NAI at this Website, you may opt-out of having your personal data collected or used by NAI by contacting NAI.  Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any products or services you request. You may contact NAI by sending us a letter at:

North American Interconnect, LLC.
7975 N. Hayden Road
Suite D-105
Scottsdale, AZ 85258
Attention:  Privacy Officer

Or by e-mail to: privacy@nai-group.com

Or by telephone at: (480) 556.6066

Or by facsimile at:  (480) 556.9471

General Principles for the Processing of Personal Data

Personal data will be collected, stored, processed and transmitted in accordance with NAI’s established policies and applicable federal, state, local and foreign laws, rules and regulations. 

The principles of NAI with respect to the processing of personal data are as follows:  (1) personal data will be processed fairly and lawfully, (2) personal data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal data collected by NAI will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) personal data collected by NAI will be accurate and, where necessary, kept up to date to the best of our ability, and (5) personal data collected by NAI will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal data was collected.

If NAI engages in the processing of personal data for purposes other than those specified in this Policy, NAI will provide notice of these changes, the purposes for which the personal data will be used, and the recipients of personal data.

Transfers of Personal data

NAI may transfer your personal data in connection with a merger, consolidation, or reorganization of the assets of NAI or affiliates, or other transaction, or by way of assignment (whether by operation of law or otherwise) in connection with any such or similar transaction or in connection with the administration of a bankruptcy estate.  However, your personal data will continue to be protected by any pre-existing privacy policy of NAI, unless you agree otherwise.  Your personal data may become the property of the successor and, subject to your agreement, will be subject to the successor’s privacy policies.

We do not sell any of your personal data (including your name, mailing address, or e-mail address)  to any companies or third parties.  We may provide some of our services through contractual arrangements with affiliates, service providers, and other third parties that require us to share your personal data with  them in order to deliver those services.  We  require our service providers to adopt and post privacy policies consistent with this Policy. 

Linking to and Privacy Policies of Third Party Sites

This Policy applies to information collected from this Website by NAI.  Once you click on a link to another website (the “Linked Site”), you are no longer on this Website.  This Policy does not apply to the content or privacy practices of any Linked Site.  We encourage you to read the privacy statements of each and every website or Linked Site that collects personal data.  You should contact advertisers, other websites or Linked Sites directly if you have any questions about their privacy policies or their use of the information they collect.

Miscellaneous Privacy Issues

NAI is committed to protecting the privacy of children.  Our policy is that we do not knowingly collect, use or disclose personal data about visitors that we know are under 13 years of age.  This Website is not directed in any respect to children under the age of 13. 

You should be aware that when personal data is voluntarily disclosed (e.g., your name, e-mail address, etc.) in any public areas on this Website (such as a message board) – that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties.  Such activities are beyond our control and this Policy does not apply to such information.  Any submissions to public areas on this Website are accepted with the understanding that they are accessible to all third parties.  If you do not want your comments to be viewed by third parties, you are advised not to make any public submissions.

Use Registration and Password

Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information.  To ensure effectiveness of your password, we recommend that you do not disclose your user identification or password to anyone.  Please be careful and responsible whenever you are online.

Security

NAI will take reasonable steps to protect the personal data in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction, and will take useful precautions with regard to the nature of the data and the risks of the processing, to preserve the security of the data and, in particular, prevent its alteration and damage or access by non-authorized third parties. NAI has put in place appropriate technical, physical, and organizational procedures and security measures to safeguard and secure the personal data from destruction, loss, alteration, unauthorized access or disclosure, or other forms of unauthorized or unlawful processing commensurate with the risks posed by the particular type of processing, the nature of the personal data and in accordance with applicable law and applicable guidelines, and taking into consideration the cost of implementing such measures. 

Accuracy

It is your responsibility to provide NAI with accurate personal data.  Except as otherwise set forth in this Policy, NAI shall only use personal data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you.  To the extent necessary for these purposes, NAI shall take reasonable steps to ensure that personal data is accurate, complete, current and relevant to its intended use.

Access

Upon request by you, NAI will grant you reasonable access to your personal data.  Except where your rights are limited by applicable law (e.g., where necessary to safeguard national security, defense, or public security, for the prevention and detection of crime, or to safeguard an important economic or financial interest of the nation in which you reside, the employee, or the rights and freedoms of others, for the purpose of scientific research or statistical purposes, provided that the data is not used for making decisions that relate to a particular individual), such access will include: (1) confirmation as to whether or not your personal data is being processed and, if so, information as to the purposes of the processing, the categories of personal data processed, and the recipients (or categories of recipients) of the personal data; (2) communication in intelligible form of the personal data undergoing processing and information as to its source; and (3) details of the logic involved in any automatic processing of the personal data.  NAI will permit you to correct, amend or delete inaccurate or incomplete personal data, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. 

Subject to the above, you may change any of the personal data you have provided to us on this Website by Website by clicking on “Customer Gateway” (if access has been granted), or by writing us at:  North American Interconnect, LLC North American Interconnect, LLC.  7975 N. Hayden Road, Suite D-105, Scottsdale, AZ 85258 Attention:  Privacy Officer, or by e-mail at privacy@nai-group.com.  Please include your name, address, and/or e-mail address when you contact us. 

We will only keep your personal data as long as we need it for the reasons it was originally collected from you.  When we no longer need your personal data for our purposes, we will destroy, delete or erase that information or convert it into an anonymous form in accordance with our standard data retention and destruction policies.  You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this Website.  In addition, it may be impossible to completely delete your information without some residual information because of backups.

Compliance

NAI will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal data has been processed or disclosed in violation of this Policy, NAI encourages you to raise any concerns using the contact information provided in this Policy.  NAI will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal data. 

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of applicable law. A notice will be posted by NAI on this Website when this Policy is changed.