This website, www.NORDAM.com (the “Site“), is owned and operated by The NORDAM Group LLC (“NORDAM,” “we,” “us,” or “our“). NORDAM takes very seriously our role in protecting the privacy of individuals who visit and use this Site. This Privacy Policy (this “Policy“) informs you about how we use, maintain, protect, and disclose certain information we may collect from you or that you may provide when you visit this Site.
The Site may include links to other websites, plug-ins, services, or applications. Clicking on those links or enabling those connections may allow the owner of such properties to collect or share information about you. We do not control these properties, and we encourage you to read the privacy notice or policy of each one that you visit. This Policy applies only to information we collect on this Site. It does not apply to information collected by any third party or any of our affiliates or subsidiaries on their websites, services, or applications.
Please read this Policy carefully to understand our policies and practices for processing and storing your information. By using this Site, you accept the terms of this Policy and consent to the collection, use, disclosure, retention and other practices described in this Policy. This Policy may change from time to time. Your continued engagement with our Site after any such revisions indicates that you accept and consent to them, so please check the Policy periodically for updates.
Please note that, for users located in the European Economic Area (“EEA“) and for California residents, section 11, entitled “Jurisdiction-specific information,” provides additional information regarding our privacy practices with respect to your personal information and supplements the other terms of this Policy. In the event of any inconsistency between the statements made in rest of this Policy and the terms under section 11, the terms under section 11, to the extent applicable, will take precedent.
This Policy is divided up into the following sections:
We collect several types of information, which varies depending on the particular activities carried out on the Site, but may include: (i) contact information, including your name, title, employer, email address, phone number, and postal address (“contact information“); (ii) technical information, including internet protocol (IP) addresses, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site, as well as usage information, including information about how you use the Site (“technical and usage information“); (iii) profile information, including information about your communication preferences, feedback and survey responses, and any information you may give us when making an inquiry on the Site and/or in feedback or contact forms (“profile information“); and (iv) background information, including date of birth, and information regarding work experience, compensation, qualifications, memberships, references, education, and your right to work (“background information“).
Except in connection with the recruitment process (as explained below), we do not collect on the Site any special categories of sensitive information, such as information about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data, or information about criminal convictions or offenses (“special category information“). NORDAM may ask for certain special category information in connection with our recruitment process, which may include information about race, ethnicity, and gender, information about disabilities for accommodation purposes, and information about criminal convictions or offenses.
To the extent that any information that we collect relates to an identified or identifiable person, such information will be considered “personal information” for purposes of this Policy. If we combine or connect non-personal information with personal information so that it directly or indirectly identifies an individual, we will treat the combined information as personal information.
For users located in the EEA, please see section 11.1 for more information on the types of personal information we may collect when you access and use the Site and how we use that information (as well as the legal bases on which we rely on to process such information).
For California residents, please see section 11.2 below for more information on the categories of personal information we have collected from consumers within the last 12 months (as those terms are defined under the California Consumer Privacy Act of 2018, as amended (Cal. Civ. Code §§ 1798.100 to 1798.199), and any related regulations or guidance provided by the California Attorney General (“CCPA“)).
We use different methods to collect information from and about you, including through direct interactions, automated technologies or interactions, and from third parties or publicly available sources, including through the methods below.
You may give us or our service providers information about you by filling in forms or by corresponding with us or our service providers on the Site. This includes information you provide when you submit inquiries through the Site or otherwise correspond with us, when you apply for a job on the Site, and/or when you request information, resources, materials, or updates about NORDAM.
As you interact with the Site, we may automatically collect technical and usage information about your equipment, browsing actions and patterns. We collect this information, which may be considered personal information in applicable jurisdictions, by using cookies and other similar technologies. Please see section 5 (Cookies and automatic data collection technologies) below and our Cookie Policy for more information about the cookies and/or similar technologies we use on our Site.
We may receive personal information about you from various third parties, such as business partners, subcontractors, and analytics providers, including technical and usage information from analytics providers and contact information from providers of technical services, which may be based in the United States. We may also collect personal information about you from third parties for recruitment purposes, such as references supplied by former employers and information from criminal records checks to the extent permitted by law. You may also choose to provide us with access to certain personal information stored by third parties such as job-related social media sites (for example, LinkedIn). By authorizing us to have access to this information, you agree that we may collect, store and use this information in accordance with this Policy.
For users located in the EEA and for California residents, please see sections 11.1 and 11.2, respectively, for more information on how we collect personal information.
We use and disclose personal information to provide our Site, products and services, communicate with you, provide customer service, and to conduct other business operations, such as to improve and personalize your experiences on the Site and with our services, and for recruitment purposes. Examples of how we may use and disclose the personal information we collect include to:
When you apply for a job with NORDAM, we will use the personal information you provide for recruitment purposes, including for: (i) recruitment, selection, evaluation and appointment; (ii) general human resources administration and management; (iii) carrying out satisfaction surveys; (iv) application analysis such as verification of references, background checks and related assessments; (v) compliance with corporate governance and legal requirements; and (vi) communication purposes, including for application status updates and to inform about future opportunities (“recruitment purposes“).
We will not use your personal information for direct marketing purposes, and will not disclose your personal information to third parties for direct marketing purposes, without your explicit consent.
We reserve the right to use non-personal information for any business purpose.
Please see section 4 below for examples of parties with whom we may share your personal information.
For users located in the EEA and for California residents, please see sections 11.1 and 11.2, respectively, for more information on how we collect and disclose personal information.
We may share your personal information with:
We may also share personal information to fulfill any purpose for which you provide it and/or with your consent, and we may share non-personal information without restriction.
For users located in the EEA and for California residents, please see sections 11.1 and 11.2, respectively, for more information.
Cookies are pieces of data stored on your browser or device that enable the cookie provider to recognize the device when it visits websites or uses online services. Our Site may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. In addition to cookies, we may also use web server logs to collect data for metrics purposes.
While we may automatically use some cookies and/or similar technologies that are strictly necessary to provide the services you request or enable communications, we request your consent for any other cookie uses where required by applicable law. You may manage data collection and use by our analytics provider by visiting http://tools.google.com/dlpage/gaoptout and you may withdraw consent for our cookie uses that are not strictly necessary by sending an email to info@nordam.com, provided you accompany such a request with sufficient information that allows us to reasonably verify you.
The cookies and similar technologies we use may process, store, or transfer personal information in and to a country outside your own, with privacy laws that provide different, possibly lower protections. You consent to this transfer, storing, or processing when you consent to our cookie use. We are based in the United States. Please review the third-party cookie provider’s policy to learn more about its location.
Please review our Cookie Policy and section 6 (Choices about how we use and disclose personal information) to learn more about how we use cookies and similar technologies, and the methods we may provide to make and manage cookie use preferences.
As noted in section 5, you may manage information collection and use by our analytics provider by visiting http://tools.google.com/dlpage/gaoptout and you may withdraw consent for our cookie uses that are not strictly necessary by sending an email to info@nordam.com.
You may also send us an email at info@nordam.com to request access to, correct or delete personal information that you have provided on our Site and we will comply within practical and legal limits with your requests. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Please note that if you delete, or if you request that we delete, your personal information, copies of your personal information may remain viewable in cached and archived pages or might have been copied or stored by other Site users or other third parties. Please also note that, if we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract.
Like many other websites, our Site does not respond to browser Do Not Track signals at this time.
For users located in the EEA and for California residents, please see sections 11.1 and 11.2, respectively, for more information about your choices with respect to how we use and disclose personal information.
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse and unauthorized access, use, alteration or disclosure. Unfortunately, the transmission of information via the internet is not completely secure. As such, we cannot guarantee the security of your personal information transmitted to our Site and any transmission of personal information is at your own risk.
This Site is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site or on or through any of its features, use any of the interactive or public comment features of the Site, if any, or provide any information about yourself. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@nordam.com.
We may update this Policy from time to time and so you should review this page periodically. When we change this Policy in a material way, we will update the “Last modified” date at the top of this Policy. Changes to this Policy are effective when they are posted on this page.
11.1 Supplemental information for users located in the EEA
The following terms apply to the extent we process personal data of data subjects in the EEA or data that is otherwise subject to the EU General Data Protection Regulation (2016/679) (“GDPR“) and laws and regulations implementing or supplementing the GDPR (“EU Data Protection Law“). The following terms explain how we collect and process data subjects’ personal data as a data controller. We process such personal data in accordance with EU Data Protection Law, to the extent applicable.
Processing of personal data under this section 11.1 means processing of personal data of persons who are in the EEA in any of the following cases: (i) if related to the offering of goods or services to such data subjects; or (ii) if related to the monitoring of a data subject’s behavior as far as their behavior takes place within the EEA.
As used in this section 11.1, the terms, “European Commission,” “controller,” “data subject,” “Member State,” “personal data,” “processing,” “process,” “processes,” “processor” and “Supervisory Authority” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.
11.1.1 Legal basis for processing your personal data
When we use your personal data, we rely on various different legal bases depending on what personal data we process and why. The legal bases we may rely on include: (i) where you have given us clear consent to process your personal data for a specific purpose (consent); (ii) where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract (contract); (iii) where our use of your personal data is necessary for us to comply with the law (not including contractual obligations) (legal obligation); and/or (iv) where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests) (legitimate interests).
Please see below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we rely on to process your personal data where more than one legal basis has been set out in the table below.
| Purposes/activities | Types of data | Legal basis for processing |
| Manage our relationship with you, including notifying you about changes to our Site, products, or services, and otherwise to provide customer service | Contact information
Technical and usage information Profile information |
Performance of a contract with you
Necessary to comply with a legal obligation Necessary for our legitimate interests (to maintain a record of types of services, questions and resources our users request or require so that we can keep our services and the Site relevant, and to keep our records updated and to study how users use our Site and services) |
| Fulfill the purposes for which you provided the information or that were described when it was collected, provide you with support, and process and respond to your requests and inquiries, including to provide you with the information, services and support that you request from us, to address your concerns, and to monitor and improve our responses. If you share your contact information to request a quote or ask a question about our services, for example, we will use that personal information to respond to your inquiry | Contact information
Technical and usage information Profile information
|
Performance of a contract with you
Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business, to study how users use our Site and services, and to develop them and grow our business) Consent (in some circumstances) |
| Provide, operate, develop and improve our Site, products, and services, and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes | Contact information
Technical and usage information Profile information |
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to maintain a record of types of services, questions and resources our users request or require so that we can keep our services and the Site updated and relevant, to run and develop our business, for providing administration, IT services, network security and to prevent fraud, and to study how users use our Site and services, and to better understand how users use, value and respond to our information and advice so that we can improve content) Consent (in some circumstances) |
| Meet our obligations and enforce our rights arising from any contracts with you, including to resolve a dispute and to enforce this Policy or other policies | Contact information
Technical and usage information Profile information Commercial information |
Performance of a contract with you
Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise) |
| Comply with any court order, law, or legal process, including to respond to any government or regulatory request, to prevent, detect, mitigate and investigate fraud, security breaches or other potentially prohibited or illegal activities, and to otherwise protect our Site, employees, users or operations | Contact information
Technical and usage information Profile information |
Necessary to comply with a legal obligation
|
| Recruitment purposes | Contact information
Technical and usage information Profile information Background information Special category information (information about race, ethnicity, and gender, information about disabilities for accommodation purposes, and information about criminal convictions or offenses) |
Performance of a contract with you
Necessary for our legitimate interests (management of recruitment process in relation to employment) Necessary to comply with a legal obligation Necessary to carry out obligations and exercise specific rights in relation to employment |
| Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NORDAM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NORDAM about our Site users is among the assets transferred | Contact information
Technical and usage information Profile information Background information Special category information (information about race, ethnicity, and gender, information about disabilities for accommodation purposes, and information about criminal convictions or offenses) |
Necessary for our or a third party’s legitimate interests
Necessary to comply with a legal obligation Necessary to carry out obligations and exercise specific rights in relation to employment |
As discussed in section 5 (Cookies and automatic data collection technologies) above, you may manage data collection and use by our analytics provider by visiting http://tools.google.com/dlpage/gaoptout and you may withdraw consent for our cookie uses that are not strictly necessary by sending an email to info@nordam.com, provided you accompany such a request with sufficient information that allows us to reasonably verify you. We cannot respond to your request if we cannot verify your identity or authority to make the request. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see section 5 above or our Cookie Policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@nordam.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
11.1.2 More information about how we disclose your personal data
We may share your personal data with the parties set out in section 4 (Disclosures), some of which may be located in the United States, for the purposes set out in the table in section 11.1.1 above.
We require our corporate group and third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside the data subject’s country of residence – to disclose personal data. We may also disclose personal data if we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our internal regulations, investigate fraud, or protect our operations or users.
11.1.3 International transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring certain safeguards are implemented in compliance with applicable law, such as: (i) specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses); or (ii) we may also transfer data to US parties if they are part of the EU-US Privacy Shield or Swiss-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
11.1.4 Your rights under EU Data Protection Law
Under certain circumstances, you may have certain rights under EU Data Protection Law in relation to your personal data, including to:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month; however, it may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will notify you and keep you updated.
11.1.5 Complaints
We hope that we can resolve any query or concern you raise about our use of your information. EU Data Protection Law also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you normally live or where any alleged infringement of data protection laws occurred.
11.2 Supplemental privacy notice for California residents
This section 11.2 supplements the information contained in sections 1 through 10 of the Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you“). We adopt this notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this section 11.2.
11.2.1 How we collect personal information of consumers
Our Site collects personal information, which includes information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, our Site has collected the following categories of personal information from consumers within the last 12 months:
We obtain the categories of personal information listed above from the following categories of sources: (i) consumers (directly, such as through online forms, and indirectly, such as from observing actions on our Site); and (ii) service providers, business partners, contractors, and other third parties used to support the business, such as data analytics providers.
Please note that, under CCPA, personal information does not include: (i) publicly available information from government records; (ii) de-identified or aggregated consumer information; or (iii) information excluded from the CCPA’s scope, such as: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), or clinical trial data; or (b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Please note that the following information may also be exempt from certain CCPA requirements: (1) personal information about a natural person acting as a job applicant to, employee of, owner of, officer of, or contractor of NORDAM to the extent such personal information is collected and used solely in those contexts; and/or (2) personal information reflecting a written or verbal communication or a transaction between us and you or the organization on whose behalf you’re acting, within the context of conducting due diligence or providing or receiving a product or service.
11.2.2 How we use personal information of consumers
As discussed in section 3 (How we use and disclose personal information) above, we may use or disclose the personal information we collect for one or more of the following purposes: (i) to manage our relationship with you, including notifying you about changes to our Site, products, or services, and otherwise to provide customer service; (ii) to provide, operate, develop and improve our Site and services, and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes, and to enable your participation in the Site’s interactive or other similar features; (iii) to fulfill the purposes for which you provided the information or that were described when it was collected, provide you with support, and process and respond to your requests and inquiries, including to provide you with the information, services and support that you request from us, to address your concerns, and to monitor and improve our responses; (iv) to meet our obligations and enforce our rights arising from any contracts with you, including to resolve a dispute and to enforce this Policy or other policies; (v) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, to prevent, detect, mitigate and investigate fraud, security breaches or other potentially prohibited or illegal activities, and to otherwise protect our Site, employees, users or operations; (vi) to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NORDAM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NORDAM about our Site users is among the assets transferred; and (vii) for recruitment purposes.
NORDAM will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
11.2.3 How we share personal information of consumers
NORDAM may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: service providers, business partners, contractors, and other third parties used to support the business, such as data analytics providers.
In the preceding 12 months, NORDAM has disclosed the following categories of personal information for a business purpose: (i) identifiers; (ii) California Customer Records personal information categories; (iii) commercial information; (iv) Internet or other similar network activity; and (v) professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties: service providers, business partners, contractors, and other third parties used to support the business, such as data analytics providers.
In the preceding 12 months, NORDAM has not sold personal information.
11.2.4 Consumer rights and choices under California law.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; and (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
11.2.5 Exercising rights under CCPA
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either calling us at (+1) 918-401-5195 or emailing us at info@nordam.com.
Only you, or someone legally authorized to act on your behalf, 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (which may be up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Questions, comments and requests regarding this Policy and our privacy practices are welcomed and should be addressed to info@nordam.com.