Privacy Policy

This Privacy Policy explains how Northwatt Colocation LLC ("Northwatt", "we", "us", or "our") collects, uses, discloses, and protects personal data in connection with our website at northwattcolo.com, our enquiries and communications, and our business relationships. Please read it together with our Cookie Policy.

We act in two distinct roles. For personal data we collect through the Site, our enquiries, our onboarding and verification of customers, and the administration of our business relationships, we are the controller and this policy applies. For personal data that a customer processes on its own equipment hosted with us, or that we process on a customer's documented instructions in the course of providing the Services, we act as a processor or service provider, and that processing is governed by the Service Agreement and any data processing agreement between the parties, not by this policy.

We do not seek to collect special categories of personal data through the Site. [PLACEHOLDER: confirm analytics tooling.]

Where the EU or UK GDPR applies, we rely on performance of a contract or steps prior to a contract, compliance with a legal obligation, our legitimate interests in securing and improving the Site and protecting our business balanced against your rights, and consent where required such as for non-essential cookies, which you may withdraw at any time.

As part of onboarding and on an ongoing basis, we and our identity verification provider may verify your identity and your organization's standing and beneficial ownership, and screen you and your payments against sanctions and restricted party lists, consistent with the Service Agreement. This may involve checks against public and commercial databases. [PLACEHOLDER: name the provider and link its notice.]

We do not sell your personal data. We disclose it only to:

• service providers and processors acting on our behalf, such as hosting and infrastructure, email, analytics, identity verification, and payment and banking providers, under appropriate confidentiality and data protection terms;
• professional advisors, such as legal, accounting, and insurance advisors;
• authorities, courts, or other parties where required by law, regulation, legal process, or a governmental request;
• a successor in connection with a merger, acquisition, financing, or sale of assets, subject to this policy.

We are based in the United States, and our providers may process data in the United States and other countries. Where personal data of individuals in the EEA or UK is transferred outside those areas, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK Addendum, or another lawful mechanism. [PLACEHOLDER: confirm the mechanism.] You may request information about these safeguards using the contact details below.

We keep personal data only as long as necessary for the purposes in this policy, after which it is deleted or anonymized.

We maintain technical and organizational measures designed to protect personal data against unauthorized access, loss, alteration, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

EEA and UK. Subject to applicable law, you may request access to your personal data, correction, erasure, restriction of or objection to processing, and portability, and you may withdraw consent where processing is based on consent. You may also lodge a complaint with your local supervisory authority.

United States, including California. Depending on your state of residence, you may have the right to know what personal information we collect, use, and disclose, to access or delete it, to correct inaccuracies, and to not be discriminated against for exercising your rights. We do not sell personal information and we do not share it for cross-context behavioral advertising as those terms are defined under California law. You may use an authorized agent where permitted, and we will verify requests as required by law.

To exercise any right, contact us using the details in section 15. We will respond within the period required by applicable law and may need to verify your identity.

If we receive a subpoena, court order, warrant, or other binding legal process, or a governmental or regulatory request, we may comply to the extent legally required. Where not prohibited by law or by the terms of the process, we will limit our compliance to what is required. This mirrors our approach under the Service Agreement.

The Site is not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has provided us personal data, contact us and we will delete it.

We may update this policy from time to time. The updated version is indicated by a revised "Last updated" date and takes effect when posted.

For privacy questions or to exercise your rights, contact abuse@northwattcolo.com, use our contact form, or write to Northwatt Colocation LLC. If you are in the EEA or UK and are not satisfied with our response, you may complain to your local supervisory authority.