Pipeline Safety Management System 

Data Privacy Policy 

Effective September 20, 2021 

Welcome to the Northeast Gas Association (“NGA”) Pipeline Safety Management Systems (PSMS) Resource Center. This site has been developed to enable the sharing of information about PSMS and operational lessons learned to foster an environment of continuous improvement. In furtherance of our mission, we offer learning resources, courses, and discussion forums related to education and training, technology research and development, operations, planning, and increasing public awareness of natural gas on our website, ngapsms.com (collectively with its sub-websites at ngapsms.com, the “Website”) (collectively, the “Services”). Additionally, NGA’s affiliates may offer services for purchase through the Website. 

NGA recognizes the importance of our members’ privacy and takes steps to protect your privacy. This Privacy Policy describes the information we gather, use and disseminate from the contact that we have with you, such as by mail, email, telephone, the Internet, mobile applications, and otherwise, and your choices about how we may disseminate that information. 

Personal Information We Collect 

For purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. 

NGA endeavors to limit the type and amount of Personal Information that we collect and process to only information necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect and process the following types of information: 

A. Information You Provide to Us 

We may collect and process Personal Information from and about you when you visit the Website, register for, or subscribe to any Services, communicate with us, post information or content to message boards in the Services, and otherwise interact with the Website or Services. For example, when you create an account on the Website, we may collect your name, contact information (including email address, work or home address, and phone number), username or e-mail address in combination with a password or security question, employer, job title and duties, and the course you enroll in. Additionally, if you communicate with other users through the Services, we may collect the contents of those communications. You can choose not to provide us with certain information, although that may affect the functionality of the Website and Services. 

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B. Information Collected Automatically 

When you use our Services, certain information is passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses and cookies. These are described in more detail below: 

• IP Addresses. The Services use IP addresses. An IP address is a number assigned to your device by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user’s device). 

• Cookies are small text files that are placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. We may collect the following information via cookies when you visit the Website or interact with the Services: aggregate statistical information, information related to your use of our Services (including your password, the links you click on, your movement around the Website and Services, the pages you visit, the number of times you open a page, and which information is consulted), period of use, your geographic location, your IP address, your device, your operating system, and your browser type. You may be able to change the preferences on your browser or mobile device to send “do not track” signals or to prevent or limit your computer or device’s acceptance of cookies, but this may affect the functionality of the Services or prevent you from using parts of the Services. If you click on a link to a third-party website or portal, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

C. E-mail and Other Communications 

We may communicate with you by email or other means. When we do this, in addition to the information contained in the email, we may collect a confirmation when you open email or click on links in the email. This confirmation helps us improve our service. If you do not want to receive email or other mail from us, please indicate your preference by visiting our email preference page. Please note that, if you do not want to receive legal notices from us, those legal notices will still govern your use of the Website and Services, and you are responsible for reviewing such legal notices for changes. 

D. Information Obtained from Third Parties 

In some situations, you may use the Services as part of your employer’s membership with NGA (each a “Member Employer”), through which we provide the Services to its employees. When that occurs, we may receive the following Personal Information about users from the Member Employer: name, contact information (including phone number, work address, and email address), job title and duties, and authority to submit reports on behalf of the Member Employer. NGA may purchase marketing and business development leads from direct marketing lead generation services. This information may include names, contact information, and professional background. 

What we do with Personal Information 

NGA collects and uses Personal Information: 

• To operate, maintain, develop, and grow NGA; 

• To respond to inquiries and comments; 

• To fulfill your requests concerning the Website and the Services; 

• To contact you with administrative communications and changes to this Privacy Policy, the Terms of Use, and our other policies; 

• To provide you with information about products or services that we believe will interest you; 

• To tailor content, recommendations, and advertisements we and third parties display to you on the Website, through the Services, and elsewhere online; 

• To operate, develop, maintain, and improve the Website and Services; 

• To conduct market research; 

• To analyze how visitors use the Website and Services; 

• To investigate and resolve disputes and security issues; 

• To comply with regulatory and legal obligations; and 

• For any other lawful, legitimate business purpose. 

NGA 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 the Website or Services to better understand our users and their behaviour and to improve the user experience of the Website and Services. 

We may also share certain Personal Information with third parties, including Member Employers as applicable (as described in this section and in the next section below). 

Sharing of Personal Information 

We share Personal Information with third parties as described below. 

A. Agents and Service Providers 

We employ other companies and people to perform tasks on our behalf and may need to share Personal Information with them to provide products and services to you. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. 

B. Member Employers 

If you have received access to the Website and/or Services pursuant to your employer’s membership in NGA, we may share Personal Information with your employer to fulfill our obligations and continue to provide access to you. 

C. Business Transfers 

We may choose to buy or sell assets. In these types of transactions, Personal Information is typically one of the business assets that is transferred. Also, if we (or all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred or acquired. 

D. Protection of NGA and Others 

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe necessary to comply with law or court order, enforce or apply our Terms of Use or other agreements, or protect the rights, property, or safety of NGA, our employees, our users, or others, including exchanging information with other organizations for fraud protection and credit risk reduction. 

E. With Your Consent 

Except as set forth above, you will be notified when your Personal Information may be shared with third parties and will be able to prevent the sharing of this information. 

How to Remove your Name from Our Mailing, Sharing or Email List 

To not receive future communications from us, not receive further communications from us, and not share your information with third parties, you can do any of the following: 

1. You may send an email to mgallinaro@northeastgas.org, send mail to 75 Second Avenue, Suite 510, Needham Heights, MA 02494-2859, or call (781) 455-6800, and instruct us to remove you from our mailing, sharing and email lists. You may also use this email, address, and telephone number to request that we correct any information we have about you. 

2. If available, you may use the “opt out” or “unsubscribe” option included in an email that you receive from us. 

Children’s Privacy 

We do not knowingly collect or solicit, and expressly instruct you not to provide, any Personal Information from anyone under the age of 18. If and to the extent we learn that we have collected Personal Information from a child under age 18 without verified parental consent, we will delete that information, except as provided below. If you believe that we might have any information from or about a child under age 18 without verified parental consent, please contact us immediately us at mgallinaro@northeastgas.org, (781) 455-6800, or 75 Second Avenue, Suite 510, Needham Heights, MA 02494-2859. 

External Links 

If any part of our website links you to other websites or mobile applications, those websites and mobile applications do not operate under this Privacy Policy. We recommend that you examine the privacy statements posted on those other websites and mobile applications to understand their procedures for collecting, using, and disclosing Personal Information. 

How To Contact Us 

If you have any questions or concerns about the privacy or security of your information, you may contact at mgallinaro@northeastgas.org, (781) 455-6800, or 75 Second Avenue, Suite 510, Needham Heights, MA 02494-2859. 

Changes to this Privacy Policy 

We may update this Privacy Policy in the future, either with or without notice.