We do not intend to, and do not knowingly, process Personal Information about individuals who are minors in the jurisdictions where they reside (Children). Individuals who are Children should not provide any Personal Information to us, and individuals should not provide Personal Information to us about Children. If we discover or are informed that we have Personal Information about Children, we reserve the right to delete that Personal Information from our systems.
Data Privacy Officer and Security Policy
For questions about NEMO’s processing of your Personal Information or this Policy, please contact our Data Privacy Officer as follows:
Phone Number: 800-977-9301
Email Address: firstname.lastname@example.org
NEMO manufactures and sells outdoor gear such as tents, sleeping pads, sleeping bags, and other equipment and accessories for outdoor adventures (Products). NEMO sells its Products to a variety of wholesalers and retailers in the United States, Canada and European Union (Retailers), and end users and consumers (Customers) may purchase Products from Retailers. From time to time, we may also offer certain other functionalities, features, surveys, media, and content in connection with our product testing, research, development, manufacture, sale, survey, and other information gathering services (Services).
In the course of providing Products and Services, NEMO receives from Customers, itself collects, and processes Personal Information, which may include the following: (1) Contact Information, such as name; physical address; age; date of birth; email address; and phone number; (2) Commercial Information, such as purchases, products purchased; price paid; order history; returns; products complaints; product reviews; and warranties; (3) Information about your Product and Service preferences and interests; (4) Geolocation Information, when certain information is provided to NEMO; and (5) Payment and Credit Information, such as your credit or debit card information; banking information; and information about your payment transaction, provided however that NEMO does not store any Payment and Credit Information and uses a third-party payment processor to process all such payments.
NEMO may anonymize or aggregate Personal Information it collects. It may also use that information and other non-Personal Information it collects when you use or interact with NEMO or the website to better understand Customers, and improve the user experience of the website and our Products and Services.
NEMO may administer certain promotional events and give-aways from time to time. If you choose to participate, we will collect certain Personal Information from Customers pertinent to those promotional events and give-aways. Although you are not obliged to provide that information to us, you will not be able to participate if you decline to do so. Personal Information that you provide to us for promotional events and give-aways may be disclosed to, shared with, and sold to our affiliates and third party marketing partners to communicate with and market to you related products and products similar to NEMO Products and Services. When you provide Personal Information to us to participate in promotional events or give-aways, you consent to the disclosure, sharing and sale of that Personal Information for that purpose.
NEMO has collected Personal Information in the last twelve months and processed it for the purposes described in this Policy.
Sensitive Information Processed
Except as otherwise explained below with respect to Dealers, NEMO does not intend to, and does not knowingly, process Personal Information that is of a sensitive nature (Sensitive Personal Information). If we discover or are informed that we have Sensitive Personal Information, we reserve the right to delete that Sensitive Personal Information from our systems.
NEMO allows Dealers to open credit accounts with NEMO for the purchase and sale of Products and Services by completing credit applications and other submitting other documentation. When dealers do so, NEMO collects certain financial and other Personal Information and Sensitve Personal Information necessary for the processing and evaluation of a dealer’s credit application, as well as facilitating the purchase and sale of Products and Services. This information may include a dealer’s name, phone number, physical address, billing address, taxpayer identification number, bank account number, bank account details, social security number, and financial statements. NEMO has collected such Sensitive Personal Information for such purposes in the last twelve months and processed it for purposes described in this Policy.
NEMO complies with the Telephone Consumer Protection Act (TCPA) with respect to sending you marketing-related communications via text messages. If and to the extent required by TCPA, NEMO obtains prior express consent from Customers before sending marketing-related communications via text messages, at the telephone number(s) you provide. If and to the extent we rely on your consent to send you marketing-related communications via text messages, you may revoke this consent at any time by opting-out of receiving any marketing-related communication via text messages by completing and submitting the Privacy Rights Request Form on this Site. NEMO does not send marketing-related text-messages to any telephone number registered with the National Do Not Call Registry (Registry). For additional information on the Registry, or to register your telephone number(s) with the Registry, please see Federal Trade Commission’s National Do Not Call Registry webpage. In addition, NEMO maintains its own internal Do Not Call List that includes telephone numbers and emails of Customers who have opted out of receiving marketing-related communications via text-messages or email, and updates this list regularly. Please note that not all of our communications via text messages or email are for marketing purposes, and you may continue to receive service messages for your Products and Services (like bills, transactional notices, customer service, etc.) despite you opting-out of receiving marketing-relating communications from NEMO.
Legal Bases for Processing Personal Information
NEMO processes Personal Information to perform our contractual and other commercial, business, and legal relationships with and obligations to provide Products and Services to Retailers and Customers. As a result, Customers provide Personal Information to NEMO and NEMO collects and processes Personal Information for Customers in order to provide Products and Services to Customers and Retailers. In addition, NEMO seeks and obtains consent from Customers for the use of Personal Information. NEMO may process your Personal Information to (1) fulfill orders and provide Customers with Products and Services; (2) test, research, and develop Products and Services; (3) personalize Customer experience with our website and our Products and Services; (4) provide support and respond to Retailer and Customer requests, questions and feedback; (5) communicate with Retailers and Customers about Products and Services; (6) facilitate any promotional events and give-aways; (7) maintain the safety, security, and integrity of our Products and Services; (8) comply with legal and regulatory obligations, and (9) establish, enforce, and otherwise exercise our rights and defend against claims. Those are the legal bases for NEMO to process Personal Information.
Disclosure of Personal Information
Except as necessary or appropriate to provide Products and Services to Retailers and Customers, NEMO does not disclose Personal Information about a Customer to other Customers or unaffiliated third party, provided that we may disclose Personal Information for the following purposes and in the following circumstances.
- If directed to do so by the Customer from whom we received the Personal Information
- If directed to do so by the Customer about whom such Personal Information pertains, or that Customer’s legal representative
- If required to do so by Data Privacy Law, any other law, rule, or regulation, legal process or warrant, or order of any court or governmental agency or authority
- To third parties, such as financial institutions or credit bureaus, that help us with processing and evaluation of requests by dealers for credit, payment processing, shipping, and other business operations as necessary or appropriate to provide the Services or Products
- To professional service providers, including attorneys, accountants, tax professionals, and financial advisers, if doing so is necessary or appropriate to obtain professional services from them
- In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of NEMO
- To entities that perform marketing, advertising or market research on our behalf
- If we determine that doing so would be in the public’s interest
Depending on the Personal Information that NEMO has about you, and depending on the manner in which we process your Personal Information, you may have the following privacy rights related to our processing of your Personal Information.
- Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected
- Be informed about whether and how your Personal Information being processed is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties
- Access or receive a copy of your Personal Information
- Rectify, update or correct inaccurate or incomplete Personal Information about you
- Erasure or deletion of certain of your Personal Information
- Object and opt-out of processing of your Personal Information
- Limit processing of your Personal Information
- Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties
- Opt-out of receiving marketing-relating communications from us via text messages, or email, or both
- Portability of your Personal Information in a commonly used format
- Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of NEMO’s use of your Personal Information before such withdrawal
- Non-discrimination for exercising your privacy rights
To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on this Site. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.
Please be aware there may be valid reasons to refuse a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain requests may limit or prevent us from providing Services to you. In those situations, we will notify you in writing within 30 days. You may also contact our Data Privacy Officer for help with those situations.
NEMO will not discriminate against you if you exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying goods or services to you, not providing a different level or quality of goods or services to you, and not suggesting that you will receive a different level or quality of goods or services.
Selling, Share, Trading, Exchanging and Brokering Personal Information
Except as otherwise disclosed in this Policy, NEMO does not sell, share, trade, or exchange Personal Information (including as those terms are defined and used in Data Privacy Laws) in any way, including for itself, or any unaffiliated third party. If and to the extent any unaffiliated third party sells, shares, trades, exchanges, or brokers your Personal Information, that unaffiliated third party is solely responsible, to the extent required by Data Privacy Law or otherwise, to notify you and obtain your consent for such sale, sharing, trading, exchanging or brokering of your Personal Information.
If and to the extent you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please complete and submit the Privacy Rights Request Form on this Site, and we will address such requests as described in the foregoing section of this Policy.
Automated Decision Making
NEMO does not use automated decision making or profiling in the processing of your Personal Information, and does not make decisions that affect you based on automated decision making or profiling using your Personal Information.
Duration of Retention
Because the Products and Services that NEMO provides to Retailers and Customers vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Products and Services that NEMO provides to particular Retailers and Customers, the duration and depth of NEMO’s relationship with particular Retailers and Customers, and the nature of Personal Information in question. NEMO endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate.
When you visit the Site, NEMO may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the Site for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the Site. Using cookies, we may also collect a variety of other information regarding your usage of the Site, including your Internet protocol address, username, session identification, browser you are using, web pages you view and referring web pages, when you access the Site, and general online behavior for performance and marketing purposes.
Changes to Policy
NEMO reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.
Questions or Concerns
For questions or concerns, please contact our Data Privacy Officer as follows:
Phone Number: 800-977-9301
Email Address: email@example.com
Last Updated: October 11, 2023