Privacy Policy

Privacy Policy

This Notice of Information Practice describes the type of information we collect, how the information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information through use of our websites, including https://www.redhillrepurposing.com/ (the “Website”), as well as through other channels.

Nakupuna Companies (Nakupuna) may change this Notice at any time. If we do, we will post the changes here and highlight any material changes. Please review this Notice regularly.

Nakupuna will not use the information collected or obtained through this website for any purpose other than to fulfill the requirements of the contract with the Navy regarding the potential beneficial repurposing of the Red Hill Bulk Fuel Storage Facility. If you do not agree with the terms in this notice, you should not provide your personal information to Nakupuna.

About Us

The Nakupuna Companies are a Native Hawaiian Organization (NHO)–owned family of companies including 8(a) small disadvantaged businesses dedicated to providing innovative and impactful solutions to our customers while supporting our Native Hawaiian community. We specialize in providing management consulting, IT, facilities & infrastructure, logistics, and environmental services that solve our clients’ toughest technical, programmatic, and logistical challenges.

The U.S. Navy has contracted Nakupuna to develop and execute an outreach program to solicit information from the public on recommendations for the Navy to re-purpose the Red Hill Bulk Fuel Storage Facility (RHBFSF) (the “Contract”).  Through the Website, and on behalf of the Navy, Nakupuna and its team of subcontractors will solicit ideas received from the community and produce a report as part of the Navy’s effort to explore possible beneficial non-fuel reuses of RHBFSF.

Definitions

• “Agent” means any third party that uses Personal Information provided to it by Nakupuna to perform tasks on behalf of and/or under the instructions of Nakupuna or to which Nakupuna discloses Personal Information for use on its behalf.
• “Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing activities and websites usage, among its many uses.
• “Device” means any device that can access the Website such as a computer, cell phone or digital tablet.
• “Individual” means any natural person.
• “Personal Information” is any information that relates to an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) email address or online identifier associated with the individual; or (d) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non-personally identifiable information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person).
• “Personnel” includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, retiree of Nakupuna.
• “Sensitive Personal Information” is information that meets the “personal information” criteria and also reveals or is processed to uniquely identify a person:
  • All government-issued identification numbers (including US Social Security numbers, EU Social Security numbers, Canadian Social Insurance numbers, driver’s license numbers, and passport numbers);
  • All financial account numbers (bank account numbers, credit card numbers, and other information if that information would permit access to a financial account);
  • Individual medical records, biomedical specimens, and biometric information, including any information on any worker or patient/medical research subject’s health, disability, disease or product interests;
  • Reports of individual background checks;
  • Data elements revealing race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense sex life or sexual orientation, and information relating to the commission of a criminal offense.
• “Service Provider” means any person or business who processes information on Nakupuna’s behalf, including to provide services related to the Website or to analyze how the Website is used.
• “Usage Data” refers to personal and non-personally identifiable information collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
• “You” means the person accessing or using the Website.

What Information We Collect, and How

Personal Information

While using our Website, we may ask You to provide us with certain Personal Information that can be used to contact or identify you. Personal Information we collect includes or may include:

• Personal Identifiers  — Personal unique identifiers, such as full name
• Personal Information — Personal information, including contact details (e.g., email, zip code)
• Geolocation Data — Geolocation data, such as device location

We will limit access to personal data to authorized personnel having a justified need to access such information and limit retention periods to retain data for no longer than is necessary to fulfill the terms of the contract with the Navy.

Non-Personally Identifiable Information

The Website is hosted on WP Engine, which may collect information as a service provider, including use of cookies and similar technologies.  Their Privacy Notice and information related thereto can be found at https://wpengine.com/legal/privacy/

The contact information You voluntarily submit on the Website is collected via a third-party service provider plug-in, provided by WPForms. WPForms’ Privacy Notice can be found at https://wpforms.com/privacy-policy/

How We Use the Information We Collect

Nakupuna may use Personal Information for the following purposes:

• To distribute correspondence regarding the U.S. Navy’s public outreach project for the re-purposing of the Red Hill Bulk Fuel Storage Facility.
• To provide and maintain our Website, including to assess the usage of our Website,  alert you to new features and functionality of the Website, provide updated content and information; enforce this Privacy Statement; and monitor aggregate use of and access to the Site.
• To contact you by email to provide you information and solicit input for repurposing the Red Hill Bulk Fuel Storage Facility.
• To answer your questions, respond to, and process inquiries.
• For data analysis, identifying usage trends, determining the effectiveness of our communications, and to evaluate and improve our Website and your experience.

We may share your Personal Information in the following situations:

• With our Agents (CommPac and SMS Research & Marketing) to create a contact distribution list, to generate and communicate updates regarding the U.S. Navy’s public outreach project for the re-purposing of the Red Hill Bulk Fuel Storage Facility, and to generate and disseminate survey(s) links.
• With the US Navy, if/when requested by it.
• As required by law or as needed in legal proceedings, when Nakupuna believes in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• For any other purpose with your consent.

Nakupuna may transfer Personal Information for specified, limited purposes, to an Agent and will endeavor to obtain assurances that such Agent provides at least the same level of privacy protection as described in this Privacy Policy.

Data Retention

Nakupuna will keep Personal Data no longer than necessary to fulfil the purposes described in this Notice. We will retain and use your information to the extent necessary to manage your relationship with us, perform the requirements of the Contract, improve your overall website experience, and to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this Notice. All information will be destroyed pursuant to the completion of the contract with the US Navy.

These requirements also apply to our Agents.

Links to Other Websites

Our Website will contain links to our Agents’ websites where the surveys may be found.  Please check CommPacs’s and SMS Research & Marketing’s Privacy Notices, found below, to determine how your Personal Information will be collected, used, and disclosed.

• https://com-pac.net/privacy-policy/
• https://www.smshawaii.com/privacy-policy

Our Website may contain links to other websites. Nakupuna has no control over these sites and they are not subject to the terms of this Notice. Please check the privacy policies of these sites to determine how your Personal Information will be collected, used, and disclosed.

Children’s Privacy

This collection of information is intended for adults only and is not intended is not intended for use by anyone under the age of 18. Nakupuna does not knowingly collect personal identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we can take the necessary actions.

Security of Your Personal Information

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Our Website has industry standard security measures in place, including storage of personal identifying information in a secure environment, to protect against the loss, misuse, and alteration of the information under Nakupuna’s control. Nakupuna will employ reasonable and appropriate technical, administrative and physical safeguards designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information Nakupuna is processing.  Nakupuna has a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, concerns, including any potential privacy or security incident.

Although we have endeavored to create and source a secure and reliable Website, we cannot and do not guarantee the confidentiality of any communication or material transmitted via the Internet. Carefully consider whether you want to disclose Personal Information at all, and if so, whether you want to submit it electronically.

Access to Personal Information at Nakupuna is limited to personnel who need it to fulfill the requirements of the Contract. Nakupuna will implement and maintain reasonable and appropriate security measures to minimize the risk of unauthorized use and disclosure.

Deletion of Personal Information will render the information irrecoverable by Nakupuna.

Unauthorized Uses and Disclosures of Personal Information, and Security Incidents

If an unauthorized use or disclosure of Personal Information or a security incident occurs, Nakupuna will promptly assess its responsibilities under applicable law and take all required actions.

California Privacy Rights

This notice to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This notice supplements our Privacy Notice by explaining your privacy rights if you are a California resident, providing our “notice at collection,” and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline.  You may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA.

Your rights

• Right to Access
  • If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
• Right to Delete
  • If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
• Right to Correct
  • You may request that we correct PI that we maintain about you that is inaccurate.
• Right to Opt Out of Sale of Personal Information
  • If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).
  • You may opt out of “sales” or “sharing” of PI (as defined under applicable law) as follows:
    • Click on “Cookie Settings” at the bottom of the relevant website and deactivate cookies. 
    • Exercising opt-out choices offered by the Digital Advertising Alliance at http://www.aboutads.info/choices, or by the Network Advertising Initiative at http://www.networkadvertising.org/choices/.

Responding to Requests

Residents of the State of California, under the California Civil Code, have the right to request from certain companies conducting business in California to make an access or deletion request and a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes and a disclosure of the shared information. As required by the CCPA, any request you submit to us is subject to a verification process. To verify your request, you must provide your name, email, and state of residence, along with any other information we may require to verify your identity or your request. We may not fulfill your CCPA request unless you have provided sufficient information for us to appropriately verify you and your request.

To make such a request, contact us as described in the “Contact Us” section below.

Authorized Agents

If you are a California resident, you may authorize an agent to make a request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us as described in the “Contact Us” section below.  As part of our verification process, we may request that you provide, as applicable:

For an individual (“requestor”) making a request on behalf of a California resident:

• The requestor’s name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card.
• The name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card of the California resident on whose behalf the request is being made.
• A document to confirm that the requestor is authorized to make the request. We may accept, as applicable, a signed permission by the California resident on whose behalf the request is made, copy of a power of attorney, legal guardianship or conservatorship order, or a birth certificate of a minor if the requestor is the custodial parent.

For a company or organization (“legal entity requestor”) making a request on behalf of a California resident:

• The legal entity requestor’s active registration with the California Secretary of State.
• Proof that the California resident has authorized the legal entity requestor to make the request. We accept as applicable, a signed permission by the California resident on whose behalf the request is made, copy of power of attorney, or legal guardianship or conservatorship order.
• The name; contact information; Social Security or individual taxpayer identification number; data of birth; and driver’s license, state ID, or matricula card of the California resident on whose behalf the request is being made. From the individual who is acting on behalf of the legal entity requestor, proof that the individual is authorized by the legal entity requestor to make the request. We accept a letter on the legal entity requestor’s letterhead, signed by an officer of the organization. We provide a template to use via the URL provided above for making requests.

Please note that some web browsers and devices permit you to broadcast a preference to websites and online services that they “do not track” your online activities. At this time, we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received.

Contact Us

Questions, comments, concerns or complaints regarding this Notice or if you would like to receive further information about this Notice or any of our information practices, please contact Nakupuna at redhillrepurposing@nakupuna.com.

Updated: March 3, 2023

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