Privacy Policy

Southwest Gas Corporation Online Services Privacy Policy

Southwest Gas Corporation (also referred to as "we", "us", “our”, “Southwest Gas”, or "the Company") takes individuals' privacy seriously and is committed to preventing unauthorized use of, or access to, personally identifiable information. Southwest Gas protects personally identifiable information through processes and procedures intended to detect, prevent and mitigate the unauthorized use or disclosure of any identifying information. This Online Services Privacy Policy (“Privacy Policy”) explains how we collect, share, use, and protect information collected when you visit or use Southwest Gas’ website, mobile application, Southwest Gas-branded social media, and/or text message alert service (collectively, our “Online Services”). Please read the following to learn more about our Privacy Policy. By using Southwest Gas’ Online Services, you agree to be bound by this Privacy Policy.

What Our Privacy Policy Covers

This Privacy Policy covers the Company's treatment of personally identifiable information that may be collected when you are using, visiting, or have signed up for our Online Services.

This Privacy Policy does not apply to the practices of companies that Southwest Gas does not own or control or to people that Southwest Gas does not employ or manage.

Links to Third-Party Sites

While using our Online Services, you may encounter hypertext links which redirect you to third-party websites that are owned, maintained, or operated by parties other than Southwest Gas. These third-party websites are not under the control of Southwest Gas, and Southwest Gas is not responsible for the contents, links or any changes or updates to these websites. Further, the inclusion of any hypertext links in any of Southwest Gas’ Online Services does not imply endorsement by Southwest Gas of the related third-party website, the website's contents, or any association or affiliation with its operators. These third-party websites may send cookies, log your IP address, and otherwise collect data or solicit personal information from you. Southwest Gas is not responsible for data collected by these third-party websites or any related unauthorized access to your data or use of services as a result of browsing these sites, even if such use was not authorized by you. Southwest Gas does not control and is not responsible for how these websites handle or use your personally identifiable information.

Information Collection

You may be asked by the Company to submit personal information such as company account number, name or business entity, email address, birth date, address, zip code, phone number, social security number or tax identification number, driver’s license/identification card information or passport information, when requesting our Online Services. Additionally, we may request third-party information including the name of landlord/property manager or contact information of a caretaker or other representative when applicable. You may also be asked to submit additional personal or financial information, including household annual income, number of members of household, to use certain specific services offered by the Company.

In addition to the aforementioned personal information that may be collected, Southwest Gas may track information such as monthly payment history and preferred payment method which may include account numbers, routing numbers, and return item code (if applicable).

Information Collected Automatically

Like many companies, Southwest Gas automatically collects certain anonymous information (e.g. date and time site visited, pages visited, links clicked to route to website, Internet Service Provider used, and Internet Protocol address from which our website was accessed) while customers use our Online Services. We currently use various analytics platforms to perform web measurement and analytics. The information collected may be used for things such as compiling statistics about our Online Services and measuring Online Service activity so that we may update our Online Services to better meet users' needs and interests.

Security

In areas of our Online Services where personal information is acquired, the Company uses industry-standard security technology - Secure Sockets Layer (SSL) - to safeguard the confidentiality of your personal and financial information. Your browser must be capable of supporting SSL.

Cookies

Cookies are small text files placed on your computer's hard drive by web page servers. When you visit the website or mobile application, Southwest Gas Corporation may utilize "session" cookies, which allow us to verify when you travel from page to page within our online service applications.

Additionally, Southwest Gas uses retargeting tools to better understand customer preferences and to determine the effectiveness of our outreach campaigns. Retargeting is a cookie-based technology that uses Javascript code to “follow” visitors when they leave our website. We use retargeting to operate energy education, public safety and informational campaigns in partnership with third-party vendors. As part of our campaigns, we place pixel tags on individual web pages within our Site to track interest in certain types of web content. These tags are used to obtain information about the computer being used to view Web pages, including the IP address, the user’s operating system, and browser type. Pixel tags provide Southwest Gas and our vendors with information about topics and activities of interest to Site visitors, and the digital advertisements or articles that referred visitors to our Site. Retargeting enables our third-party advertising partners to show you ads about our programs and activities, based on your interests, on other websites.

Data on website and mobile application usage that we collect using cookies or retargeting is not tied to your personally identifiable information and is only used in aggregate form.

Information Use

a. The personal information that you provide us enables you to access various customer services offered through our Online Services. We may use this information to contact you regarding customer services, including but not limited to, responding to an inquiry or a request for services that you send to the Company, sending notifications via email regarding construction and maintenance updates, activities pertaining to our programs or services, providing surveys to help improve our customer service, notifying customers of special events, sharing energy and safety education information, and providing offers related to our products and services that may be of interest to you. If you choose to communicate with the Company by Email, then Email from the Company to you will be considered to be sent with your consent and will be accessible to anyone who has access to your Email.

b. In order to provide you with services offered through our Online Services, or to complete transactions or requests initiated by you using our Online Services, we may transfer you to websites operated by third parties that help us provide services to you. In such cases, we will have agreements with those parties under which they will agree to maintain confidentiality of your personally identifiable information and to use it only for the purpose of helping us serve you.

c. The Company does not and will not collect nor sell your personal information for commercial purposes to third parties nor disclose your personal information to third parties for the purpose of telemarketing, email or direct mail solicitation. To submit a formal request to opt out of any potential future sale of personally identifiable information the Company has collected or will collect about you, please send an email including your full name (as it appears on your SWG account), service address, and your full account number to optout@swgas.com

d. Other than as set forth herein, the Company will not disclose your personal information to third parties without your written consent (which consent may be obtained electronically, such as by Email) unless we reasonably believe that the disclosure is essential to the conduct of the Company's business, including but not limited to:

• Compliance with the law, legal process, or our regulators
• Collection of unpaid bills
• Enabling the Company's employees or consultants to provide service to you and to otherwise perform their duties
• Resolving customer disputes or inquiries
• Obtaining and providing credit reporting information

e. The Company may use customer data such as demographics, premises data, payment history, channel preferences/interactions, and participation in programs and offers, to assist customers in managing their gas service.

Traffic Data

In order to improve the usefulness of our Online Services, we automatically collect and maintain statistical information from data logs that concern network traffic flow and volume ("Traffic Data"). This Traffic Data consists of:

• Name of the domain, or URL, from which the visitor accesses the Internet;
• Internet Protocol ("IP") address;
• Type of web browser used; and
• Date and time the website was visited.

Traffic Data does not identify individual visitors. It is used to highlight what our visitors find interesting, to improve the website's design specification, to identify performance issues, and for other internal purposes.

Location Based Information

Certain Southwest Gas Online Services provide location services that enable a customer’s location to be determined. If you use a location-based service, we will collect location information about your longitude and latitude and may save your device's coordinates to offer certain features to you.

Location-based services can be disabled through Southwest Gas’ Online Service or the privacy settings on your mobile device.

California Do Not Track Disclosure

Under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. Like many websites, our Site is not designed to respond to “Do Not Track” signals received from browsers. This law also requires operators of online services to disclose whether third parties may collect personal information about their users' online activities over time and across different online services when the users use the operator's service. We do not knowingly permit third parties to collect personal information about an individual customer’s online activities over time and across different online services when using our Online Services.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Southwest Gas Corporation  (“we,” “us,” or “our,” “Southwest Gas,” or “the Company”) and applies solely to visitors, users, and others who reside in the State of California (“consumer” or “you”). Southwest Gas adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
Southwest Gas collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
 
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
NO
G. Geolocation data.
Physical location or movements.
NO
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information. Current or past job history or performance evaluations.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
Personal information does not include:
• Publicly-available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Southwest Gas obtains the categories of personal information listed above from the following categories of sources:
• Directly from you or your agents. For example, from documents that you provide to us related to the services for which you engage us (e.g., information received as part of routine credit verification when establishing natural gas service).
• Indirectly from you or your agents. For example, through information we collect from you in the course of providing services to them.
• Directly and indirectly from activity on our website (swgas.com). For example, from submissions through our website portal (SWG “My Account”) or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. (For example: government agencies)

Use of Personal Information
At Southwest Gas, we do not sell your personal information or data. We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which you provided us information. For example, if you provide us with personal information to establish natural gas service for you at your residence, we will use that information to provide such service and to respond to natural gas emergencies that may affect your service.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts between you and us, including billing and collections.
• To improve our website and present its content to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described by you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divesture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Southwest Gas 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.

Sharing of Personal Information
Southwest Gas may disclose your personal information to a third party for a business purpose. When we do so, we enter a contract with that third party that describes the purpose and requires the recipient to keep your personal information confidential and not to use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose**:
Category A: Identifiers
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:
• Our affiliates
• Service providers
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sales of Personal Information
In the preceding twelve (12) months, Southwest Gas has not sold any personal information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a “data portability request”).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• Sales, identifying the personal information categories that each category of recipient purchased; and
• Disclosures for a business purpose, identifying the personal information categories that category of receipt obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained,subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 et. seq.)
5. 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.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9. The following is the list of all personal information the Company collects on customers and whether it can be deleted upon a verifiable request from you:
 
Can Delete? (YES/NO)
Data Collected
Reason why this information cannot be deleted
YES *Email Need for customer’s ONLINE Southwest Gas account. If the customer’s email address is deleted pursuant to a deletion request, Southwest Gas will be unable to provide a deletion confirmation/response via email and the account will no longer be accessible ONLINE to the customer.
NO *ACH / Bank Routing If signed up with Automatic Payments, ACH and Banking data will be stored with payment history
NO Bill Address Needed to provide service to our customers
NO Date of Birth Required for customer verification
NO
First & Last Name
Needed to provide service to our customers
NO *Income If enrolled in CARE assistance, this personal information is needed to continue in the state administered program
NO
*Online Password
Needed to log into the customer account from the Southwest Gas website. If this is removed, then the Online Customer experience will no longer be available
NO
Service Address
Needed to provide service to our customers
NO
Social Security Number(SSN)
SSN is the primary customer number used for verification
NO
*Tax ID
If there is no SSN, then the Tax ID is the primary customer number used for customer verification
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Calling us at  877-860-6020
• Visit swgas.com/ccpa
Only you or a person registered with the California Secretary of State that you authorize 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:
• Provide sufficient information that allows us to reasonable verify you are the person about whom we collected personal information or your authorized representative.
• 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.

Response Timing and Format
Southwest Gas strives to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and the extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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.
Southwest Gas does not charge a fee to process or respond to your verifiable consumer request less 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.

Non-Discrimination
Southwest Gas will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level or quality of good or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to This Privacy Policy

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described in this notice [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:
Email us
• Call us at 877-860-6020
Contact us

Last updated December 2019