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Virginia Natural Gas Privacy Policy

This policy explains how we may process your information. It may be amended or updated from time to time, so please check it regularly for updates.

1. SCOPE OF THIS PRIVACY POLICY

Virginia Natural Gas (“VNG”, us”, “we” or “our”) is one of four natural gas distribution companies of Southern Company Gas, a wholly owned subsidiary of Southern Company (NYSE: SO).  Virginia Natural Gas provides clean, safe, reliable and affordable natural gas service to more than 300,000 residential, commercial and industrial customers in southeast Virginia.   This privacy policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, share, safeguard, and retain the Personal Data (defined below) pertaining to individuals with whom we interact in the context of our residential services, whether they be the property owner or a tenant (the “Consumers”). 

2. PERSONAL DATA

Virginia law defines “Personal Data” as any information that is linked or reasonably linkable to an identified or identifiable natural person.  However, Virginia law exempts certain types of information from the definition including, without limitation, publicly available information and information processed about an individual applying for employment with, or employed by, a business.

3. VNG'S PROCESSING AND USE OF PERSONAL DATA

The table below sets forth the categories of Personal Data that VNG processes about consumers and the purpose for which such Personal Data is processed. 

Category of Personal Data Processed

Examples of Data Elements Collected

Processing Purpose

Personal Identifiers

Name

Mailing address

IP address

Email address

Phone numbers

Social Security Number

Driver’s License Number

Passport number

Other government identification information

  • Providing services to Consumers
  • Maintaining and servicing Consumer accounts, providing customer service, processing or fulfilling transactions, verifying information
  • Responding to Consumer inquiries and requests
  • Delivering content and informing Consumers about our services
  • Detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity
  • Performing short-term, transient internal use
  • Responding to or defending against subpoenas, court orders, or other legal process
  • Establishing or exercising our legal rights
  • Complying with applicable law
  • Maintaining our website
  • Better understanding our website visitors
  • Tracking performance and optimizing website performance
  • To identify website visitors in order to serve to individuals 

Commercial Data

Records of services purchased

  • Providing services to Consumers, maintaining or servicing Consumer accounts, providing customer service, verifying information, processing payments
  • To respond to Consumer inquiries and requests Auditing interactions and transactions
  • Short-term, transient internal use
  • To respond to or defend against subpoenas, court orders, or other legal process
  • To establish or exercise our legal rights
  • To otherwise comply with applicable law

Electronic Network Activity

IP address

Device brand, model and name, browser information, operating system, platform version, screen resolution and preferred language

Performance data and interactions information (e.g., where a website visitor clicks, scrolls, moves in between pages, time spent per visit, cumulative time spent across all usage, frequency of usage, features used, buttons clicked, actions taken and frequency of each)

Ad tracking codes

  • For bug and performance tracking and to optimize VNG’s website
  • Internal research for technological development
  • Better understanding our website visitors
  • Detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity
  • Short-term, transient internal use
  • To respond to or defend against subpoenas, court orders, or other legal process
  • To establish or exercise our legal rights
  • To otherwise comply with applicable law
  • To identify website visitors in order to serve to individuals

Audio Data

With consent, audio and video recordings of interviews

  • Providing services to Clients
  • Performing short-term, transient internal use

Inferences

Virginia Natural Gas uses Personal Data listed to draw inferences about your characteristics, behaviors, attitudes, and aptitudes.

  • Providing services to Consumers

Sensitive Personal Data

Biometric Data

Precise Geolocation Data

  • Providing services to Consumers
  • Complying with applicable law

Other Personal Data

Social Security Number

Date of birth

Driver’s License Number

Passport number

Other government identification information

Financial account information

Credit card information

VNG website username and password

Information concerning an individual’s health

Gender

Other characteristics of protected class status

  • Providing services to Consumers
  • Facilitating Consumer’s payment on accounts
  • Complying with applicable law
  • Detecting security incidents, protecting against malicious, deceptive fraudulent or illegal activity
  • To establish or exercise our legal rights 

Personal Data We Collect about Website Visitors:

Information Website Visitors directly provide:  When a Consumer visits our website, they may (but are not required to) submit information to us through our various service request forms.  The information collected through such forms includes some of the information listed in the table above.  Virginia Natural Gas uses the Personal Data that website visitors provide through our web forms in order respond to their inquiry or request. We do not use the information for any other purposes.  We do not sell or share this information and we do not provide this information anyone other than our vendors in the context of their performing services for us.

Occasionally, VNG may invite website visitors to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us better serve website visitors and improve the usefulness of our website and services. In conducting these surveys, we may ask you for some of the Personal Data listed in the table above.

Information collected via cookies and similar technologies:  When website visitors visit VNG’s website, our goal is to make the experience simple and effective.  To that end, we use text files, known as cookies, to track information about the use of our website.  A cookie is a text file that a website stores on a visitor’s computer to enable recognition of that visitor’s computer each time they return.  In addition, certain website pages contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). As a website visitor navigates through and interacts with our website, the web beacons and cookies automatically collect certain information about the website visitor’s equipment, browsing actions and patterns using these cookies. This may include information about: (i) their IP address and browser information; (ii) the general location from which they access our website, (iii) the pages accessed on our website and time spent on our website, and; (iv) how the website visitor reached our website (e.g., web searches, directly using our website URL, or third party referrals or hyperlinks.) 

We use log files to store the data that is collected through web beacons. Virginia Natural Gas also uses third party web beacons to help manage online advertising. These web beacons are provided by our ad management partners and enable our partners to recognize a website visitor’s web browser, which in turn enables us to learn which of our advertisements bring users to our website.

Please refer to VNG’s Cookie Policy for more information on the specific cookies we use, the purpose for such cookies and how you can indicate your choices regarding placement of cookies.

Please note that VNG utilizes Google Analytics 4 (“GA4”), including the following GA4 Advertising Features: Remarketing and Search Console.  GA4 Advertising Features allows Google Analytics to collect data about website visitor traffic via Google advertising cookies and identifiers.  Virginia Natural Gas uses this information to understand which of our ads are drawing people to our website and to segment website visitors based on various factors.  If you want to learn more about how Google uses the information transmitted from VNG’s website, please review Google’s Privacy Terms  and Google’s My Ad Center Help.  If you want to prevent your Personal Data from being used by Google Analytics, visit the Google Analytics Opt-out Browser Add-on Download Page at https://tools.google.com/dlpage/gaoptout.

4. PERSONAL DATA VNG SHARES WITH THIRD PARTIES

Virginia Natural Gas shares the Personal Data we collect about Consumers with trusted entities to improve, protect and support our business. For instance, VNG may disclose Personal Data: (i) to service providers (e.g., technology providers, payment processors, collection agencies, consumer authentication providers, business advisors, auditors, etc.); (ii) to potential investors in the business, and; (iii) if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation (e.g., government agencies); (b) protect and defend our rights or property; or (c) protect the rights, property, or safety of others. Virginia Natural Gas requires our service providers to process Personal Data strictly in accordance with our instructions. We bind those service providers to whom we disclose Personal Data to contractual privacy and security obligations consistent with this Privacy Policy and applicable laws.

The table below sets forth the categories of Personal Data that VNG shares with third parties and the categories of third parties with whom the Personal Data is shared.

Category of Personal Data

Is the Personal Data Shared with Third Parties

Categories of Third Parties with Whom Shared

Personal Identifiers

Commercial Data

Electronic Network Activity

N

Audio Data

Inferences

Sensitive Personal Data

Other Personal Data

5. CONSUMER RIGHTS

Virginia law gives Virginia Consumers certain rights as it relates to the Personal Data that a business processes about them. Those rights may be exercised free of charge, up to twice annually, and include the following:

  • Right to Know What Personal Data Is Processed and Right to Access: Virginia Consumers have the right to confirm whether or not VNG processes Personal Data about them and to access that Personal Data. Before providing such Personal Data to you, VNG must verify your identity.
  • Right to Correct Inaccurate Personal Data: Virginia Consumers have the right to request that VNG correct any inaccuracies in their Personal Data. Before correcting Personal Data in response to your request, VNG must verify your identity.
  • Right to Request Deletion of Personal Data: Virginia Consumers have the right to request that VNG delete any Personal Data provided to us by the Consumer or otherwise obtained about the Consumer. Before deleting Personal Data in response to your request, VNG must verify your identity.
  • Right to Receive a Portable Copy of Personal Data: With respect to Personal Data that the Consumer previously provided to VNG that VNG processes by automated means, and to the extent technically feasible, Virginia Consumers have the right to obtain a portable copy of such Personal Data in a format that allows the Consumer to transmit the Personal Data to another entity without hindrance. Before providing such Personal Data to you, VNG must verify your identity.
  • Right to Opt Out of the Processing of Personal Data: Virginia Consumers have the right to opt out of VNG’s processing of their Personal Data for the following purposes:  (i) targeted advertising; (ii) for sale; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects on the Consumer.  An example of a decision that produces significant effects is one that results in the denial of a loan, housing, or education enrollment.

Method to Submit Requests
If you wish to exercise your right to delete, correct and / or know (as described above), you may do so by calling VNG at the following toll-free telephone number, +1 ________________, by submitting a request form at https://www.virginianaturalgas.com/company/virginia-consumer-data-protection-policy/consumer-data-privacy-form.html or by emailing us at ______________________.  A legal guardian of a Consumer may invoke these rights on behalf of the Consumer.

Virginia Natural Gas will confirm receipt of your request within 45 days of receiving your request.  In the event we need additional time to respond, VNG will inform you of that within the initial 45-day period. 

Process to Appeal
If VNG refuses to take action on your Consumer request, we will notify you of that fact and you may appeal our decision within a reasonable period of time after receiving notice.  An appeal can be submitted at the following toll-free telephone number, +1 866-229-3578, by submitting an appeal form at _______________________________or by emailing us at ______________________.  Within 60 days of your appeal, VNG will inform you in writing of any action taken or not taken in response to the appeal.  You then have the right to file a complaint Virginia Attorney General at: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

6. VNG’S RETENTION OF PERSONAL DATA

Virginia Natural Gas retains Personal Data in accordance with our record retention policies.  Generally speaking, VNG retains Personal Data as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

7. CHILDREN’S PRIVACY

The services VNG’s offers are not directed to children under the age of 17 and we do not knowingly collect Personal Data from children under the age of 17. If we become aware that we inadvertently received Personal Data about an individual under the age of 17, we will delete the information from our records.

8. HOW WE PROTECT PERSONAL DATA

Virginia Natural Gas maintains administrative, technical and physical safeguards designed to protect against unauthorized access to, disclosure, use, alteration or destruction of the Personal Data we collect. We update and assess our security controls on a regular basis.  We also make our personnel aware of the importance of confidentiality, security and privacy and limit our personnels’ access to Personal Data to only those employees who require access based on their job duties.  Virginia Natural Gas stores electronic information on the systems of an enterprise third party cloud provider in the United States.

Unfortunately, no transmission over the Internet or method of electronic storage is guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of such information, and any such information provided by or through our website is at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.

9. UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our  business practices. The “Effective Date” at the beginning of this Privacy Policy reflects the last date on which the Privacy Policy was updated.   We recommend that you periodically review the Privacy Policy to stay informed of changes. We will ask for your consent to such changes if required by law.

10. LINKS TO THIRD PARTY WEBSITES

Virginia Natural Gas’ website contains links to third party websites (e.g., LinkedIn and Meta).  These third party websites publish their own privacy statements, which disclose the manner those third parties process Personal Data.  Virginia Natural Gas recommends that you review those third party statements when visiting any linked website.  Virginia Natural Gas is not responsible for the content of linked websites or the processing Personal Data by the companies that own and manage such websites.

11. CONTACT DETAILS

If you have any questions about this Privacy Policy or how VNG handles your Personal Data, please contact us at https://www.virginianaturalgas.com/company/virginia-consumer-data-protection-policy/consumer-data-privacy-form.html  or + 1 866-229-3578.

Mail address:
The United States of America

Request Your Data

You can request a copy of your personal information collected in the past 12 months including where it is disclosed, or request to delete your personal information, subject to exclusions under the law.

How to Contact Us

If you would like to make a request with regard to the personally identifiable information we hold about you, please use the following link

You may also call us at the following toll-free number: 866-229-3578