Online Privacy

The privacy of your personal information is respected by NW Natural.

NW Natural - Privacy Policy

This Privacy Notice describes the privacy practices of Northwest Natural Gas Company and its gas company affiliates (“NW Natural”, “we”, “our”, or “us”), which do not include NW Natural Water Company, LLC and its subsidiaries. Please refer to the NW Natural Water operating company web sites for the privacy notices that describe the privacy practices applicable these companies. This Privacy Notice also does not apply to personal information collected and used in relation to our community coalition advocacy activities, which are conducted separately from our regulated utility services. Please refer to the relevant web sites at NW Coalition for Energy Choice, Eugene for Energy Choice, and Milwaukie for Energy Choice for the privacy notices that describe the privacy practices applicable these activities.

This Privacy Notice applies to the personal information that we collect and use relating to consumers, customers, and website users (“consumer” or “you”). 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”).

NW Natural Gas Company operates as a regulated utility in Oregon and Washington. However, some of our customers and website users may reside outside of these states. Each state has different laws and regulations governing how we collect, use and share personal information. This Privacy Notice describes NW Natural’s general privacy practices related to personal information. It also contains information specifically required by states whose laws may apply to us. This information may or may not be applicable to you depending upon your state of residency. If you choose to link to any third-party websites or services NW Natural has provided for your convenience, NW Natural’s privacy practices and security protections do not apply. 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, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Personal Information categories listed in ORS 646A.602 and RCW 19.255.005	Name in combination with Social Security number, driver's license or state identification card number, student, military, or passport number, known traveler number, financial account or bank account number, credit card number, debit card number, full date of birth, mental or physical condition or diagnosis. Some personal information included in this category may overlap with other categories.
Characteristics, including protected classification characteristics	Age, gender, race, ethnicity, marital status, veteran status, language spoken in home. We may collect additional characteristics incidentally as part of our business processes, such as ancillary details contained within driver's licenses or identification cards.
Commercial and Account information	Records of personal property, products or services purchased, obtained, or considered, and consuming tendencies such as energy usage information or other purchasing or consuming histories or tendencies.
Payment and Financial Information	Bank account, credit card or debit card information, or payment history may be collected by us to establish your ability to pay for our services or to process payments for our products and services. Payments from our customers are processed through third-party payment processors, and your personal information will be governed by the privacy policies of those third-party processors.
Location Information	Premise address, meter location, or geolocation, including information to identify and maintain our utility infrastructure and to provide notice regarding safety or utility outages.
Energy Usage Information	Usage information and history obtained from metering devices.
Sensory Information	Audio information, such as voicemails or calls recorded for quality assurance purposes.
Sensitive Information	Racial or ethnic origin, mental or physical health condition or diagnosis.
Professional or employment-related information	Current or past job history or employment status and income.
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 Google Analytics.

Personal information throughout this Notice does not include:

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

Children’s Privacy
Our services are not directed to children under 16 years of age, and NW Natural does not knowingly collect any information from any individual under 16 years of age unless required by applicable law or regulation. If you are under 16 years of age and using our services or this website, please do not give us any personal information. If you need help, please ask a trusted adult. If you believe a child under 16 years of age has provided us with personal information, please contact us at info@nwnatural.com 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 consumers or their agents. For example, from forms that you provide to us when you sign up for a new account or otherwise engage us to provide products and services to you, or from information we collect through your interactions with us (for example, when you call customer service, make a claim against us for damages, or when you participate in or request to receive information about offers, programs, and promotions that do not directly relate to managing your natural gas account).

Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.

From third-parties that interact with us in connection with the services we perform and the products we provide. For example, from government agencies (including via public records), energy efficiency providers, or community action agencies when we provide services related to tariffed programs or prepare regulatory reports for projects that require governmental approval.

From our utility meters and other equipment. For example, energy usage data is collected by our metering systems.

From service providers that interact with us in connection with the services we perform, the products we provide, and the marketing of those products and services to you. For example, payment processors, 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 service your account and provide you with the products or services that you request from us, including enrollment, customer service, billing, and payment processing.
To communicate with you regarding our products, services, and programs (for example, through our newsletter), or other products, services, or programs that may be of interest to you, or to notify you about updates, changes, or alerts.
To provide you with alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To operate our business and maintain safe, secure, and reliable public utility services and equipment under NW Natural’s obligation to serve you as a regulated public utility, including managing, maintaining, improving, repairing, and developing plans for our services and systems, and developing plans for renewable natural gas and energy conservation programs.
To perform marketing activities such as notifying you about and administrating offers, promotions, and available products and services, providing advertisements, conducting market research and customer surveys, and creating customer prospect lists.
To improve our websites and present their contents to you, including through the evaluation of user interactions with the website and analytics.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our customers, or others.
To respond to law enforcement requests and as required by applicable law, valid warrant, subpoena, court order.
To exercise or defend legal claims, or otherwise comply with our legal or governmental regulations.
As otherwise set forth in this Notice or according to our mandated responsibilities as a regulated utility (see Sharing personal information section below).
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 obtained 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	NW Natural 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, NW Natural may conduct profiling to draw inferences regarding your preferences or tendencies. You may opt out of profiling in furtherance of decisions that produce legal effects via the webform available at https://www.nwnatural.com/online-privacy/OCPAform
Targeting Advertising	NW Natural does not conduct “targeted advertising” as that term is defined by Oregon law. However, as described under the ‘Information we collect’ section of this Privacy Notice, NW Natural websites and mobile applications may use cookies, web beacons and other similar tracking technologies for data analytics and marketing purposes. Refer to the tab 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	NW Natural does not sell or share your personal information for monetary consideration. However, under some circumstances a transfer of personal information to a third party, or within our NW Natural family of companies, without monetary consideration may be considered a “sale” under Oregon or California law. Refer to the tab 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, a regulatory purpose, or other purposes described below. For example, we may disclose private consumer information to a service provider to perform work on our behalf or to our energy efficiency partners that provide services pursuant to our regulated or required programs.

Categories of third parties with whom we may share personal information

Law Enforcement and Governmental Authorities Pursuant to Legal Requirements—NW Natural 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.
Low Income Service Providers—NW Natural may disclose personal information to agencies providing low-income weatherization or low-income assistance services on behalf of NW Natural and funded through NW Natural’s Oregon Schedule 301, Public Purpose Funding Surcharge or provided under Washington Schedules I or J. Customer participation in these programs is considered consent to share personal information.
Other Utilities for Establishing Credit for Utility Service—NW Natural may disclose personal information to other utilities when such request is in accordance with OAR 860-021-0200(a).
Third Party Service Providers and Contractors—NW Natural may disclose personal information to third party service providers, or contractors performing work or providing services to or on behalf of NW Natural. This may include, for example, cloud services providers, marketing service providers, software-as-a-service providers, metering service providers, professional advisors, and gas line installation and repair contractors. 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.
Financial Services Providers—NW Natural may disclose personal information to financial institutions, credit agencies, and other financial services entities that provide financial and auditing support services for our public utility programs and services.
Regulatory Agencies and Industry Associations—NW Natural may disclose personal information to public utility commissions that regulate us. We may also disclose personal information to the following agencies and organizations:1) Federal or State agencies, and municipalities; 2) industry organizations; and 3) building and site owners when there are five or more accounts (or fewer accounts if written releases are provided by the account holder) related to the building or site.
Energy Efficiency Providers—NW Natural discloses personal information to Energy Efficiency Service Providers (including Energy Trust of Oregon) (the “EE Providers”) to the degree information sharing is required by a regulatory agency, tariff, a contract between NW Natural and the EE Provider, or if NW Natural determines that personal information is necessary for the EE Provider to determine the technical potential for demand side management in NW Natural’s service territory. The EE Provider must execute a contract that describes the purpose of the disclosure and requires the recipient to both keep that personal information confidential.
Analytics Providers—NW Natural uses 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.
To Other Parties—Personal information may also be disclosed in limited situations if NW Natural’s Corporate Secretary and General Counsel both determine that sharing of personal information is in the best interest of NW Natural and its customers for a substantial public policy reason, such as promoting energy efficiency or equitable access.
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
Personal information categories listed in the ORS 646A.602
Characteristics
Commercial and Account information
Payment Information
Location Information
Energy Usage Information
Sensory Information
Sensitive information
Professional or employment-related information
Inferences Drawn From Other Personal Information
Internet or other similar network activity
Cookies and Tracking Technologies

Security

NW Natural wants you to be comfortable knowing that protecting your personal information is a priority for us. 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.

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.

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 applies.

We may deny your deletion request if retaining the information is subject to an exception under applicable law, including circumstances where it is necessary for us or our service providers to:

Provide a product or service that you specifically requested from us, or perform a contract that your entered into with us, including fulfilling the terms of warranties or recalls.
Protect any person’s health and safety.
Comply with applicable laws and regulations, government inquiry, investigation, or subpoena, or cooperate with law enforcement related to activities that may violate law.
Investigate, establish, initiate, or defend legal claims.
Prevent, detect, or respond to and investigate security incidents, identify theft, fraud, or deceptive activity, preserve the integrity and security of systems, or identify and repair technical errors that impact functionality.
Conduct internal research to develop, improve, or repair products, services, or technology
Perform internal operations that are reasonably aligned with your expectations, that you may anticipate based on our relationship with you or that are otherwise compatible with the products and services that you requested from us.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Completing the webform at https://www.nwnatural.com/online-privacy/OCPAform
Calling us at 800-422-4012

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 choices” tab.

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 by telephone to 800-422-4012 or in writing via email to info@nwnatural.com 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 choices and opt-out rights (Do Not Sell or Share My Personal Information)

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. NW Natural does not sell your personal information for monetary consideration, as described in the tab regarding Use of Personal Information. 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 by calling 800-422-4012 or via the webform available at https://www.nwnatural.com/online-privacy/OCPAform

Do Not Sell or Share My Personal Information (CA) – California residents also have the right to opt-out of the sale or sharing of their personal information by NW Natural to third parties. NW Natural does not sell or share your personal information for monetary consideration. However, a transfer of personal information to a third party without monetary consideration may also be considered a “selling” or “sharing” as those terms are defined under California law. You may opt-out by calling 800-422-4012 or via the webform at https://www.nwnatural.com/online-privacy/OCPAform

Interest-based Advertising - NW Natural does not conduct “targeted advertising” as that term is defined by Oregon law. However, you may opt out of certain interest-based advertising via https://www.nwnatural.com/online-privacy/OCPAform 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

"Do Not Track" signals are used by some web browsers to attempt to limit tracking related to your visits to a website. Not all browsers offer a "Do Not Track" option and "Do Not Track" signals are not yet uniform. To the extent that your browser broadcasts a "Do Not Track" signal, our website is not currently designed to recognize "Do Not Track" signals.

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 homepage.

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 NW Natural Gas Company at:
Phone:
800-422-4012
Website:
nwnatural.com
Email:
info@nwnatural.com
Webform:
https://www.nwnatural.com/online-privacy/OCPAform
Postal Address:
NW Natural
Attn: Customer Service
250 SW Taylor Street
Portland, OR 97204

Last updated: 7-1-2024

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