This Privacy Policy (the “Privacy Policy“) both (i) governs how we collect, use, and treat personal information that you provide to NWM (“NWM,” “we,” “our“, or “us“) through our website at nwmriskmanagement.com (the “Website” or “Site“), while using the services and information available via the Site, or that you otherwise provide to us, and (ii) establishes certain rights and obligations with respect to your personal information and use of our Platform.

1.1  CONSENT BY USER ACTING IN A REPRESENTATIVE CAPACITY.

If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization“), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.

1.2     RIGHT TO WITHDRAW CONSENT.

You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Choices Regarding Your Personal Information; Opting Out).

2. THE INFORMATION WE COLLECT.

The information that we collect about you falls into certain categories as further described in this Section 2 (The Information We Collect). This information consists of the following:

2.1      PERSONAL INFORMATION.

We collect certain information that identifies you as an individual (collectively, “Personal Information“). The Personal Information we collect may include the following:

• Your name, email address, and password;
• Your other contact information including a physical address, phone number, and fax number;
• Any information or feedback you provide in communications with us through our Website or via social media, email or our customer call center; and

2.3      ANONYMOUS INFORMATION.

Our Platform also collects, processes, and/or uses information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information. We use Anonymous Information for our business operations, for example, to engage in marketing and other activities in a manner that protects our customers. Since Anonymous Information does not include Personal Information, it is outside the scope of this Privacy Policy.

2.4      TREATMENT OF COMBINED INFORMATION.

To enable us to better understand the characteristics of our users and/or to provide Services tailored to your needs, we may link your Personal Information with Online Activity Information associated with you or other Anonymous Information. If we combine or associate Online Activity Information or other Anonymous Information with your Personal Information, then we will treat the resulting combination as Personal Information..

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

3.2      CONTACTING NWM.

You can contact us with questions or comments. In order to communicate with us, you must provide certain Personal Information.

3.4      REQUESTING A QUOTE.

You can request a quote directly from NWM via the Site. To do so, you must provide certain Personal Information, such as your name, the agency or organization that you represent, your mailing address, other specified contact information, and a description of the product for which you are requesting a quote.

3.5      NEWSLETTERS AND SPECIAL OFFERS.

You can provide us with Personal Information so that we can send you (i) newsletters about NWM, our Services, and information about issues that we believe may be of interest to you, and (ii) special offers about our products and Services.

3.8      COOKIES.

A cookie is a small amount of data that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services. Cookies alone are typically Online Activity Information.

3.9      CLICK-THROUGHS.

We may send email messages or display links that use a “click-through URL” linked to our Platform or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information, including Online Activity Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

4. HOW WE USE THE INFORMATION WE COLLECT.

We use the information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with the terms of this Privacy Policy. More specifically, we use the information we collect for the following purposes:

• To provide you with the Services you request (on the Website, by phone, or otherwise), including use of our Website, to create and manage Registered User accounts, and to communicate with you regarding our Services;
• To respond to your inquiries;
• To customize and enhance your use of our Website and Services, such as by personalizing your experience with us;
• To provide communications that might interest you, including marketing messages and to inform you of products and services that we think would be appealing to you, whether the products or services are provided by us or by others, and whether the products or services are available via our Site or via a third party;
• To verify your identity and to securely process your purchases or other requests for Services;
• To perform analytics, quality control, market research, and to determine the effectiveness of our Site, promotional campaigns, to improve our current products, Services, and Site, and develop new products and services;
• To perform internal administration, auditing, operation, and troubleshooting for our Site and Services; and

In addition to the uses specifically identified above, there may be instances where you request information and Services from us that are not described in this Privacy Policy. In our discretion, we can use information that you submit in order to provide such information and Services.

8. HOW WE SAFEGUARD THE INFORMATION WE COLLECT.

We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law.

9. OUR RETENTION OF DATA.

We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

10. ACCURACY AND MINIMIZATION OF DATA.

We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

11. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION; OPTING OUT.

11.1    UNSUBSCRIBING TO MARKETING COMMUNICATIONS.

If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, you can opt out of this Service by either (1) following the “unsubscribe” instructions located near the bottom of each email message, or (2) contacting us as provided in Section 17 (Contact Us).

11.3.1    COPY OF PERSONAL INFORMATION.

You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you.

11.3.2    DELETION OF PERSONAL INFORMATION.

You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes 

11.3.4    SUBMISSION OF REQUESTS.

You can submit any of these requests by clicking here or by contacting us at 800.796.3060. You may authorize another person (your “Agent“) to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it. Please be advised that these requests are unrelated to an opt-out of marketing communications, which can be done as provided in Section 11.1 (Unsubscribing to Marketing Communications) above.

11.3.5    RESPONSE TO REQUESTS.

Please be advised that NWM will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please contact us as provided in Section 17 (Contact Us).

11.4    ANONYMOUS INFORMATION.

We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.

12. ADVISORY REGARDING PARTICIPATION BY CHILDREN AND TEENS.

Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.

14. NOTICE OF PRIVACY RIGHTS TO CALIFORNIA RESIDENTS.

The following provisions of this Section 14 (Notice of Privacy Rights to California Residents) apply if you are a California resident.

14.1    SHINE THE LIGHT LAW.

California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.

14.2         CALIFORNIA CONSUMER PRIVACY ACT.

NWM makes the following disclosures regarding the California Consumer Privacy Act:

14.2.1    NO FINANCIAL INCENTIVES.

NWM does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. NWM does not offer financial incentives to deter consumers from making such requests. NWM will not discriminate against any consumer for exercising their privacy rights, including those provided by applicable law.

14.2.2    CONSUMER REPORTING.

NWM will endeavor to report consumer request metrics when they become available.

14.2.4    QUESTIONS.

If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 17 (Contact Us).

15. FEEDBACK.

We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 17 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.

16. CHANGES TO THIS PRIVACY POLICY.

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in applicable law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Platform and/or notifying you of the change via the Platform, email, or other methods. Your continued use of the Platform following such notice constitutes your agreement to follow and

19. EFFECTIVE DATE.

The effective date of this Privacy Policy is February 19, 2024.