New Privacy Notice / Your Privacy Rights
Effective: 1 Jan 2023
Date Published: July 2023
You may also request a copy or otherwise obtain disability access assistance by calling 888-342-4934.
This Privacy Notice applies to individuals in the United States unless otherwise noted herein. If you are a resident of the EU or UK, please click here for the GDPR Notice.
DNOW L.P., together with its affiliates, parents, and subsidiaries (collectively, "DNOW," "Company," "us," "we," or "our"), provides services to business customers, such as energy and industrial solutions/products, engineered equipment packages, and related services. As such, we usually handle only limited personal information about the personnel of our customers and other partners along with website visitors. This Privacy Notice ("Notice") contains details about how we collect, use, and disclose to third parties Personal Information (defined below) that we obtain from and about you. Please read this Notice carefully.
Applicability: This Notice does not apply to information about job applicants or our employees, which is subject to separate privacy notices, if applicable, that we will make available to such individuals.
Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that your interactions and exchanges comply with applicable data protection laws. You shall have sole responsibility for any violation of applicable laws as a result of a failure to obtain any necessary consent from such individual.
Changes: We may update this Notice from time to time. The current Notice will be effective as of the Effective Date set forth above. Please check this Notice periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on this website. When required under applicable law we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Notice under which it was collected.
Your California and Nevada Privacy Rights: California and Nevada residents have certain privacy rights detailed here. To the extent that there is a conflict between this Privacy Notice and the state privacy notices, the state privacy notice will control as to residents of such states.
1. Sources of Personal Information
“Personal Information” or “PI” is any information relating to an identified or identifiable natural person or household.
We may collect Personal Information about you from the following sources:
A. Directly From You. We may collect Personal Information you provide to us directly, such as when you contact us through our website, interact with us at our networking events that we either host or sponsor, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
B. Cookies and Other Tracking Technologies. We may collect information about how you use our website or otherwise interact with us automatically, such as information about your device, internet usage, and website activity.
C. From Third Parties. We may collect Personal Information from third parties, such as service and content providers, business partners, public sources, companies that provide or sell lists of potential business customers, or from others interacting with us.
D. From DNOW Affiliates. We may receive information about you from our family of affiliated companies, which includes parents, subsidiaries, or other companies that share common ownership with DNOW.
We may combine information that we receive from the various sources described in this Notice, including third party sources, and use or disclose it for the purposes identified below.
2. Types of Personal Information We Collect
We may collect the following types of Personal Information:
A. Identifiers, such as your first and last name, email address, physical address, telephone number, company name, device identifiers (e.g., cookie IDs and IP address), or other similar identifiers.
B. Customer records, such as signatures.
C. Protected class and demographic information, such as age (including birthdates) and gender.
D. Commercial information, such as purchase information, credit-related information, and other financial information.
E. Internet or other electronic network activity information, such as your browsing history, search history, and information regarding your interactions with and use of the website.
F. Geolocation data, limited to your address.
G. Audio, electronic, visual, or other sensory information, such as video recordings / photos of our premises, call center recordings, or customer support chat logs.
H. Professional or employment-related information of our business contacts, such as job title, organization, professional licenses, credentials, specialty, professional affiliations, or other professional information.
I. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences.
In addition, we may collect the following types of sensitive Personal Information(“SPI”):
J. Government issued identification numbers, such as social security, driver’s license, state identification card, or passport number.
K. Account log-in, such as username and password to online account with Company.
L. Financial data, such as a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
M. Precise geolocation, which is any data that is derived from a device and that is used or intended to be used to locate a consumer w/in a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.
3. How We Use Personal Information
We may use Personal Information for the following purposes:
A. To provide you with products and services, such as to register and administer accounts; provide products and services requested; provide customer support; enable you to participate in prize drawings, competitions and/or surveys we may administer; diagnose, repair and track service and product quality issues; communicate with you about your product or service; authenticate account users; to respond to requests, complaints, and inquiries; and to otherwise facilitate your relationship with us.
B. For our own internal business purposes, such as to evaluate or audit the usage, performance and safety of our products and services; evaluate and improve the quality of our products and services and design new products and services; operate our website and customize the content; internal research and analytics purposes; display or evaluate the effectiveness of our advertising or marketing efforts; or maintain internal business records.
C. For legal, safety or security reasons, such as to comply with legal requirements; protect our and our users' safety, property or rights; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
D. For marketing, such as to market our products or services or those of our affiliates or other third parties. We may use Personal Information we collect to send you newsletters, surveys, questionnaires, promotions, or information about events or to entertain our customers at sporting events.
E. Corporate transactions, in order to comply with requests of a prospective or an actual purchaser interested in our companies and other assets, or in relation to a prospective or actual purchase of companies or assets by us.
F. In an anonymized, de-identified, or aggregated information format for any purpose, as permitted by applicable law. We do not treat deidentified data or aggregate consumer information as Personal Information and we reserve the right to convert, or permit others to convert, your Personal Information into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as Personal Information. We will not attempt to reidentify data that we maintain as deidentified.
G. For any other purposes for which you provide consent.
4. How We Share Personal Information
We may disclose your Personal Information to the categories of recipients described below:
A. Affiliates and subsidiaries, such as within our group of companies, which includes parents, corporate affiliates, subsidiaries, and other companies that share common ownership for the purposes described above.
B. Service providers, such as with those working on our behalf in order tofacilitate our interactions with you or request or support our relationship with you, such as hosting service providers, IT providers, operating systems and platforms, internet service providers, analytics companies, marketing providers (e.g., we may disclose your email address with our outbound email marketing provider), payment processors, shipping companies, and logistics providers.
D. In connection with a corporate transaction, such as if we sell/acquire some or all of our assets or merge or are acquired by another entity, including in connection with a sale, merger, change of control, bankruptcy, or similar transaction, or due diligence related to such transactions, we may disclose your Personal Information to that entity.
E. Entities to which you have consented to the disclosure.
We may also de-identity, anonymize, or aggregate Personal Information to disclose it third parties for any purpose, as legally permitted.
5. Cookies and Other Tracking Technologies
We also collect information (or permit third parties to directly collect information on our website), via cookies, web beacons, pixels, tags, session replay tools, or other tracking technologies (“Tracking Technologies”), such as your Internet Service Provider and IP address, device identifier, browser type, operating system, the date and time you access our website, the pages you accessed while visiting our website, and the Internet address from which you accessed our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content. These cookies and other technologies may be used to track you across time, devices, and services.
You may choose whether to receive some interest-based advertising. The Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI") provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and optout.networkadvertising.org. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, you subsequently erase your cookies, or you use a different device or web browser, your DAA/NAI browser-based opt-out may not, or may no longer, be effective. We are not responsible for the effectiveness of these or any other third-parties’ opt-out options or programs.
Some browsers have incorporated Do Not Track ("DNT") preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser's Help instructions to learn more about how to manage cookies and the use of other Tracking Technologies.
6. Data Security
We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure or use.
7. Children's Privacy
Our website is intended for individuals 18 years of age and older. The website is not directed at, marketed to, nor intended for, children under 18 years of age. We do not knowingly collect any information, including Personal Information, from children under 18 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 18, please contact us set forth in Section 10 below, and we will use reasonable efforts to delete the information.
8. External Links
Our website may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy statements of those third-party services for details.
10. Contact Info/Your Choices
If you have questions regarding this Notice, please contact us at:
PHONE: (888) 342-4934
11. State Privacy Notices
A. California Privacy Rights Notice
In some instances, we may collect information about certain California residents subject to the California Consumer Privacy Act including as amended by the California Privacy Rights Act (collectively the “CCPA”). However, this CCPA Notice does not apply to the following information:
Information about individuals who are not California residents.
Information about our own employees, contractors, agents, and job applicants. Such information is subject to a separate privacy notice that we will make available to the applicable individuals.
In the circumstances when we collect information about California residents subject to this CCPA Notice, below is a summary of the Personal Information we collect, the sources from which we collect the Personal Information, the business or commercial purpose for which we collect Personal Information, and the categories of third parties with whom we disclose Personal Information to. The section references relate to the sections above in this Notice.
Sources of Your Personal Information
The categories of sources of Personal Information are detailed in Section 1 above and are summarized as follows: (a) directly from you; (b) from cookies and other Tracking Technologies; (c) from third parties; and (d) from DNOW affiliates.
Use of Your Personal Information
The business and commercial purposes for which we collect personal information are detailed in Section 3 above and are summarized as follows: (a) to provide you with products and services, (b) for our own internal business purposes; (c) for legal, safety, or security reasons; (d) for marketing; (e) for corporate transactions; (f) in an anonymized, de-identified, or aggregated information format for any purpose; and (g) for any other purposes for which you provide consent.
Disclosure of Personal Information and SPI:
We disclosed all the categories of Personal Information and SPI listed in the chart below for a business purpose in the past 12 months. We do not believe that we have "sold" or “shared” (as such is defined under the CCPA) your Personal Information or SPI in the past 12 months. We do not knowingly sell or share any Personal Information or SPI of minors under the age of 16.
|Categories of PI We Collect||Categories of Recipients|
Disclosures for Business Purposes:
Protected Class and Demographic Information
|Internet or other electronic network activity information and device information||
Audio, electronic, visual, or other sensory information
Professional or employment-related information of our business contacts
|Categories of SPI We Collect||
Categories of Recipients
|Government issued identification numbers||
Retention of PI. Because there are numerous types of PI in each category of PI, and various uses for each PI type, our retention periods vary for each of the categories of PI described above. The length of time for which we retain each category of PI depends on the purposes for our collection and use in addition to applicable laws. In no event do we retain your PI for any longer than reasonably necessary to achieve the purposes for which it was collected or processed. The criteria used to determine the retention period of PI includes the nature and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of the PI, as well as applicable laws (such as applicable statutes of limitation).
California Privacy Rights and How to Exercise Them. California residents also may have certain rights, subject to legal limitations and our identity verification standards, regarding the collection, use, and disclosure of their PI. California residents may exercise the following rights regarding PI collected by submitting this Your California Privacy Choices form or at our toll-free privacy number: 888-342-4934.
- Right to Know Categories. You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, selling, or sharing the Personal Information, the categories of third parties with whom we have disclosed your Personal Information, a list of the categories of Personal Information disclosed for a business purposes and, for each, the categories or recipients, or that no disclosure occurred, and a list of the categories of Personal Information sold or shared about you and, for each, the categories of recipients, or that no sale or share occurred ("Categories Report").
- Right to Know Specific Pieces. You may also request information about the specific pieces of Personal Information we have collected and maintainabout you and to obtain a transportable copy, subject to applicable request limits ("Specific Pieces Report").
- Right to Delete. Except to the extent we have a basis for retention under applicable law, you have the right to request that we delete Personal Information that we have collected from you.
- Right to Correct. You may bring inaccuracies you find in your Personal Information that we maintain to our attention, and we will act upon such as required by applicable law.
- Automated Decision Making/Profiling. We do not engaged in automated decision making or profiling.
- Sensitive Personal Information. We only process sensitive Personal Information for purposes that are exempt from consumer choice under the CCPA.
- Do Not Sell/Share. We do not “sell” or “share,” as those terms are defined by the CCPA, any of the categories of PI described in section 2 of this Notice.
Non-discrimination/non-retaliation. In accordance with applicable law, we will not discriminate or otherwise retaliate against you for exercising these rights.
Please be aware there might be circumstances where we will not honor you request, as permitted under the CCPA. For example, if we are not able to verify your identity and that you are a California resident, we may not honor your access, deletion, or correction request. Additionally, we may not delete your personal information if an exception under the CCPA applies to your deletion request.
Verification. When you submit a request, we will initially ask you to provide the following verifying information: your full name, business name (if applicable), e-mail, phone number and/or mailing address. We will review the information provided and may request additional verifying PI via e-mail or other means to ensure we are interacting with a California resident and the correct individual. We will not honor your request unless you provide sufficient information for us to verify, with a reasonable or reasonably high degree of certainty, that you are the California resident about whom we collected PI.
We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose.
We verify each request as follows:
- Right to Know Categories of P): We will verify your request by matching at least two (2) data points you provide with data points we maintain, which we have determined to be reliable for the purpose of verifying you.
- Right to Know Specific Pieces of PI: We will verify your request by matching at least three (3) data points you provide with data points we maintain, which we have determined to be reliable for the purpose of verifying you. You will also be required to provide a signed declaration under penalty of perjury that you are the individual whose PI is the subject of the request.
If you fail to provide at least three (3) data points and the signed declaration, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a request for access to the categories of PI we maintain about you. Because of the need for a signed declaration, we will be unable to complete a request for specific PI exclusively via the toll-free number.
- Right to Delete: We will verify your request by matching at least two (2) or three (3) data points you provide with data points we maintain with the number of data points contingent upon the sensitivity of the PI and the risk of harm posed by an unauthorized deletion.
- Right to Correct: We will verify your request by matching at least two (2) or three (3) data points you provide with data points we maintain with the number of data points contingent upon the sensitivity of the PI and the risk of harm posed by an unauthorized correction.
If you fail to provide the number of data points specified above, we will be unable to verify you sufficiently to honor your request.
Authorized Agents. Authorized agents may exercise rights on behalf of California consumers, but we reserve the right to also verify the Consumer’s identity directly as described above. Authorized agents may submit CCPA requests on behalf of a consumer, including required documentation, by submitting this Your California Privacy Choices form, or at our toll-free privacy number: 888-342-4934 and by submitting supporting documentation to email@example.com. We require the agent to demonstrate authority to act on behalf of the consumer by providing, for example, evidence of the agent’s identity, proof of registration with the California Secretary of State (if the agent is a business), and at least one of the following evidencing proof of the agent’s legal authority to act on the behalf of the individual consumer:
- Presenting a Power of Attorney granted under the Probate Code that we can reasonably verify; or
- Signed permission by the consumer. We may also require the consumer to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.
Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing PI about another individual, you represent that your interactions and exchanges comply with applicable data privacy laws. You shall have sole responsibility for any violation of applicable laws as a result of a failure to obtain any necessary consent from such individual.
Timing and Response. We will respond to requests to delete, requests to know, and requests to correct within 45 days, unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.
We will not charge a fee to respond to your privacy rights requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining the basis for such a decision including a cost estimate before completing any such request.
In protecting and maintaining the confidentiality of your PI, we will never provide your account log-in password, or security questions or answers in response to a privacy rights request.
California Shine the Light. We do not disclose personal information subject to California Civil Code § 1798.83 (the “Shine the Light law”) with third parties (other than our affiliates) for their direct marketing purpose. California residents may request information about our compliance with the Shine the Light law, and obtain a disclosure of third parties we have shared information with inaccordance with the law for their direct marketing purposes absent your choice (i.e., DNOW affiliates) and the categories of information shared, by contacting us at firstname.lastname@example.org. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mail address.
B. Nevada Privacy Rights Notice
We do not believe we “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, and until such time as we change this policy by updating this Notice, and provide a method to opt-out of sale under the Nevada Revised Statutes, we will treat covered information collected under this Notice as subject to a do not sell request as relates to the Nevada Revised Statutes.