General Privacy Notice
Last Updated: 1 April 2024
This Privacy Notice addresses how Nightwing Group, LLC and its affiliates and subsidiaries (collectively, “Nightwing”), may collect and process personal information from you, as an individual, separate, and apart from its websites and mobile applications. The privacy notice for any Nightwing website is on that particular website. For job applicants, please check our Job Applicant Privacy Notice. Employees should refer to the Nightwing Employee Privacy Notice.
Nightwing interacts with individuals in a variety of ways: end users of our products, employees of our business customers and suppliers, and others in our communities. To enable these interactions, Nightwing may need to collect and process personal information. Nightwing has implemented technical, administrative, and physical measures to safeguard any personal information we may collect. As this Notice is intended to cover a variety of situations, some information in this Notice may not apply to you. For example, if you do not have a warranty with a Nightwing company, Nightwing would not be collecting warranty information from you. Also, Nightwing complies with applicable legal requirements and refrains from the collection or use of personal information in a location as prohibited by applicable law.
Nightwing defines personal information as any data that relates to an identified or identifiable person.
What personal information might Nightwing collect?
The personal information that Nightwing collects is subject to applicable legal requirements. Because this Notice covers a wide variety of situations, there may be data elements listed here that do not apply to your specific situation. Please contact Nightwing as described in the “How to Contact Nightwing” section below if you have any questions
| Type of personal information | Outsourced Labor | Personnel of suppliers, vendors, and business customers | Visitors and persons authorized to use Nightwing systems | Shareholders | Consumers and end users of certain Nightwing products | Others* |
| Name, including given, family, middle, any suffix (such as Junior or Senior), and salutation (such as Mr. or Mrs.) | X | X | X | X | X | X |
| Basic identification information, such as date of birth, and gender | X | X | X | |||
| For dependents, relationship to the policy holder | X | |||||
| Emergency contact information | X | X | ||||
| Work contact information, including telephone number, facsimile number, email address, pager number, mailing address, and work location | X | X | X | |||
| Home address, personal email address and home telephone number, including personal mobile telephone number | X | X | X | |||
| Mailing address provided, whether home, work, or both | X | |||||
| Work experience, education and job history, skill categories including language skills, licenses, certifications, authorization to perform a certain job, or memberships to and participation in trade associations or professional organizations | X | X | X | |||
| Information about an individual’s job, including job title, department, job function, and cost center | X | X | X | X | ||
| Information about an individual’s employer, including company name(s), company location(s), company address(es), and country of incorporation | X | X | X | X | ||
| Name of supervisor and/or assistant | X | X | X | |||
| Training, development, and/or performance review information | X | X | ||||
| Nightwing computer, network, and communications information and logs covering the use of company phones, computers, electronic communications (such as email and electronic calendars), and other information and communication technology, including but not limited to username/login identification, passwords, answers to security questions, and other information required to access Nightwing applications, networks, systems, and services as well as information that you store, send, submit, or receive through Nightwing’s networks and systems | X | X | X | X | X | |
| Work assignments and work product that may include a connection to you, such as but not limited to documents and files with you identified as the author and tasks assigned to you | X | |||||
| Military service information as required by applicable requirements and law | X | |||||
| Environmental, health, and safety information | X | X | X | X | ||
| Agreements, programs, and activities in which the individual participates | X | X | ||||
| Payment and invoice-related information, including government identification numbers and bank account numbers | X | X | X | X | ||
| Language and communication preference(s) | X | X | X | X | X | |
| Information collected through a voluntary survey or promotion or through use of a product | X | X | X | |||
| Record of any incident that occurs while on Nightwing premises | X | X | X | X | ||
| Travel and expense information related to work assignments, including visa information, expense details, and supporting bills | X | X | X | |||
| Information that may be collected as part of an assignment, such as time and attendance data, badge information, photographs, audio, video, biometric information (e.g., fingerprint, iris scan, or voice recognition), or geolocation data used for a particular role or assignment, but such collection will be known, transparent, and consistent with applicable law | X | X | X | |||
| Country of birth, citizenships held (past and present), and permanent residency status, as required by applicable law | X | X | X | |||
| Required screenings, such as a medical examination, drug screening, and/or background check information as required by applicable law | X | |||||
| Information that may be required for international trade compliance regulations to permit your access to certain technologies or other information related to a particular assignment or visit as required by applicable law | X | X | X | X | ||
| Government-issued identification numbers (in whole or in part), such as a tax identification number, Nightwing assigned identification number, social security/insurance number, government-issued driver’s license number, visa, passport, or other document number | X | X | X | X | X | |
| Qualifications to serve as a vendor, such as conflicts of interest information | X | |||||
| Visitor information, including time, date, and location of visits, information regarding a vehicle for parking purposes, and information necessary to maintain visitor logs and denied party screening | X | X | X | |||
| Listing of nominal gifts that may have been provided or received | X | X | ||||
| Location information for certain sites that provide location-based services, such as maps, access to printers based on location, or availability of nearby conference rooms, but such collection will be known and transparent | X | X | ||||
| Information provided to facilitate a service or request assistance, such as product use or problem information | X | X | X | X | X | |
| Information required to process a claim or provide requested benefits or services, which may include an independent medical examination, health information, government identification numbers, or other information | X | |||||
| Information provided in the context of exercising rights as a shareholder, such as meeting attendance (including data collected for security purposes for meeting attendees and any recordings of meetings), vote information, and payment of dividends | X | |||||
| Any information that a person chooses to include in a document that is part of an insurance claim and/or legal proceeding involving Nightwing | X |
*Others includes dependents and family members of Nightwing employees, emergency contacts, parties to insurance claims, and individuals who contact us by email (but are not otherwise covered by one of the other categories)
In countries that impose special protections on sensitive or special Personal Information (as defined by applicable law), Nightwing will only collect, process, or transfer your Sensitive Personal Information as required by law or, in circumstances where providing the data is optional, with your explicit consent.
Nightwing will generally collect the personal information from you: when you provide it directly to us; when you use Nightwing applications, networks, systems and services; and via third parties or our employees (such as a visitor registration form). Our collection of your personal information will be consistent with applicable law.
How might Nightwing use the personal information it collects?
| Purpose | Outsourced Labor | Personnel of suppliers, vendors, and business customers | Visitors and persons authorized to use Nightwing systems | Shareholders | Consumers and end users of certain Nightwing products | Others* |
| Conducting regular business operations, including designing and developing products, managing an Enterprise Resource Planning (ERP) system, sending invoices and collecting payment, providing payment, and providing goods and services to customers, which may include sharing limited personal information with customers or other business partners | X | X | X | X | ||
| Providing requested products and services, which may include use of geolocation for certain applications in a known and transparent manner | X | |||||
| Conducting charity campaigns | X | |||||
| Staffing planning, including as that may impact budget and financial planning and reporting | X | |||||
| Responding to situations involving a risk of health or safety, including an emergency | X | X | X | X | X | X |
| Managing communications and notices | X | X | X | X | X | |
| Planning and providing health and safety programs and services, including drug screening and health and safety programs | X | |||||
| Reporting and statistical analyses, including global enterprise headcount, demographics, and reporting required by applicable law | X | |||||
| Managing physical security, including access controls and security, facility access and safety, and disaster preparedness | X | X | X | X | ||
| Managing, maintaining, and securing information technology (“IT”) systems, such as computer networks, email, internet access, Enterprise Resource Planning (“ERP”) systems, and workflows, including: • Access controls and security for computer and other systems • Internet, intranet, email, social media, and other electronic system access • Virus, intrusion, and insider threat scanning and analysis • Creation and analysis of logs for security and helpdesk purposes • Providing helpdesk support and system maintenance activities • Backing up and recovering data and providing disaster recovery services | X | X | X | X | X | X |
| Overseeing location tracking, duration, and other telematics of certain Nightwing assets and applications for management of services provided, security, safety, and efficiency | X | X | X | |||
| Ensuring compliance with import, export, and other international trade controls, including managing registrations and authorizations, determining access to controlled technologies and/or commodities, and screening for sanctioned or restricted countries or parties | X | X | X | X | ||
| Responding to questions or concerns submitted to the Nightwing Ethics and Compliance program (generally this means using the data of the person who submitted the question or concern to respond back) | X | X | X | X | X | X |
| Performing audits and compliance reviews to ensure compliance with applicable policy, regulation, and law | X | X | X | X | X | |
| Conducting and managing internal and external investigations, including Legal, Global Ethics & Compliance, and International Trade Compliance reviews and any resulting disclosures to government agencies | X | X | X | X | X | X |
| Evaluating and reporting conflicts of interest | X | X | X | X | X | X |
| Addressing environmental, health, and safety issues, including injury and damage claims | X | X | X | X | X | |
| Evaluating and administering various types of insurance claims | X | X | X | X | X | |
| Prosecuting and defending claims in litigation, arbitration, administrative, or regulatory proceedings, including but not limited to pre-dispute activity, evidence collection, discovery, litigation holds and e-discovery efforts | X | X | X | X | X | X |
| Responding to law enforcement and other government inquiries | X | X | X | X | X | X |
| Protecting intellectual property rights, including but not limited to patent filings | X | X | ||||
| Business planning, including planning for or executing mergers, acquisitions and divestitures | X | X | X | X | X | |
| Facilitating investor management activities | X | X | ||||
| Documenting participation in professional organizations and provision or receipt of business gifts and hospitality | X | |||||
| Administering of marketing, contract, joint ventures, and other business efforts, including without limitation invoice and payment processing, project management, and customer surveys and promotions | X | X | X | X | ||
| Designing, selling, producing, and improving products | X | X | ||||
| Providing customer service and support | X | X | ||||
| Training and certification of customer, supplier, and vendor personnel | X | X | ||||
| Conducting supplier and vendor due diligence, including risk assessments | X | X | ||||
| Developing and managing budget and financial planning and reporting | X | X | ||||
| Providing benefits and services as requested by either an employee or by a beneficiary or dependent | X | |||||
| Ensuring compliance with applicable laws, regulations, and Nightwing policies concerning business gifts and sponsored travel to third parties | X | X | X | X | ||
| Fulfilling obligations required of public companies, such as holding an annual meeting (including security at such meetings) and maintaining a list of shareholders | X | |||||
| As required or expressly authorized by applicable law or regulation | X | X | X | X | X | X |
With whom might Nightwing share the information it collects?
Nightwing may provide access to or share Personal Information on an as-needed basis with third parties, such as trusted service providers, consultants and contractors who are granted access to Nightwing facilities or systems, and with government agencies and others as required by law. Nightwing will only share your Personal Information outside the Nightwing group of companies to:
- service providers Nightwing has retained to perform services on our behalf. Nightwing will only share your personal information with service providers for the purposes listed above. The categories of service providers with which Nightwing may share your Personal Information include (and only where applicable): contractors assisting with a relevant assignment; denied party screening provider; outsourced digital technology providers; and service providers offering software as a service. Nightwing will only share your personal information with service providers whom Nightwing has contractually restricted from using or disclosing your personal information except as necessary to perform services on our behalf or to comply with legal requirements;
- comply with legal obligations, including but not limited, to complying with tax and regulatory obligations, sharing data with labor/trade unions and works councils, and responding to a court proceeding or a legitimate legal request from law enforcement authorities or other government regulators;
- investigate suspected or actual policy, ethics, or compliance violations or illegal activity;
- prevent physical harm and protect human safety; or
- support the sale or transfer of all or a portion of our business or assets, including through bankruptcy.
If you provide services to a Nightwing business and need to access a customer or end user’s facility, Nightwing may need to provide your personal information to that customer or end user to facilitate your access to the site in compliance with security requirements.
Except where used in support of a contract with you or to fulfill a legal obligation, our use of your personal information will be only for legitimate business interests as set forth above. Nightwing will not sell your personal information.
Where does Nightwing store your personal information?
Nightwing may transfer your information from one legal entity to another or from one country to another in order to accomplish the purposes listed above and may include sharing with our services providers in other countries. We will transfer your personal information consistent with applicable legal requirements and only to the extent necessary for the purposes set forth above.
How long does Nightwing retain Personal Information?
Nightwing retains personal information for the length of time required to fulfill the purpose for which it was originally collected and for any additional period as required by applicable law or regulation, court, administrative or arbitration proceedings, or audit requirements. What choices do you have about how Nightwing uses your personal information? Where possible, Nightwing will provide you with the opportunity to decide whether or not to provide your Personal Information. There may be circumstances in which you will not be provided with a choice, such as IT security practices like virus and malware scanning for individuals with access to Nightwing networks. Depending on the nature of the personal information and the reason that Nightwing may require it, Nightwing may be unable to fulfill your request without collecting and processing your personal information.
You will always have a choice about whether Nightwing uses your personal information for marketing purposes. If you have provided us with your personal information and would now like to request that it is no longer used for marketing purposes, please contact the business from which you are receiving the marketing communications. The communications themselves and the business website will provide you with the contact details. We also encourage you to use the unsubscribe option available in the communication.
What additional information should specific individuals know?
Residents of California: California Shine the Light Law: California residents may annually request and obtain information that is shared with other businesses for their own direct marketing use within the prior calendar year. Nightwing does not share your personal information with other businesses for their own direct marketing use. California Consumer Privacy Act: California residents have the right to:
- request details about the personal information that we have about you, including the categories of information, the purpose for which we use it, with whom we share it, and specific information about what personal information we have about you;
- request that your data be deleted; and
- direct a company not to sell your data, but, since Nightwing does not sell personal information, this does not apply.
If you are a California resident and you would like to exercise your rights, you should contact Nightwing either by calling 1- (833) 840-5111 or visiting nightwing.ethicspoint.com. Please provide your name, a way for Nightwing to contact you (such as an email address or telephone number) so that we can respond to your request, information about the nature of your relationship with us (for example, are you a visitor to our website), and details about the action that you would like us to take. Based on your request, we will investigate to determine if we have any of your personal information. If we do have your personal information (other than that provided in your request), we will seek to verify your identity based on the personal information that we already have; the data we will request will depend on the nature of the personal information we have about you. We will also provide you information about whether there is any reason we cannot comply with your request.
Residents of the United States: Nightwing does not collect Social Security Numbers through nightwing.us. Nightwing does, however, collect Social Security Numbers where required by law, such as tax and payroll purposes for its employees. When Nightwing collects and/or uses Social Security Numbers, Nightwing will take proper care by protecting confidentiality, limiting collection, ensuring access on a need-to-know basis, implementing appropriate technical safeguards and ensuring proper disposal.
How might Nightwing change this policy?
As Nightwing expands and improves this website, we may need to update this policy. If we make any significant changes to the policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements that may apply. We encourage you to review this policy on a regular basis for any changes. The date of the latest version will be identified at the bottom of the policy.
How can you contact Nightwing?
If you wish to access, correct, or update your personal information, or if you have questions about Nightwing privacy practices in general or a complaint, please call 1-833-840-5111. If you wish to contact the local Data Protection Officer, please note that in your call and your inquiry will be directed to the appropriate person.