Last updated February 8, 2023
Thank you for choosing NEWITY LLC and its affiliates (“NEWITY”, “we”, “us”, “our”). We are committed to protecting your personal and business information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal and business information, please contact us at firstname.lastname@example.org.
When you visit and use our website newitymarket.com (the “Website”), use our mobile application, as the case may be (the “App”), and more generally, use any of our services (the “Services”, which include the Website and App), we appreciate that you are trusting us with your personal and business information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, marketing, or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU
1. WHAT INFORMATION DO WE COLLECT?
Personal and business information you disclose to us
In Short: We collect personal and business information that you provide to us.
We collect personal and business information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us.
The personal and business information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal and business information we collect may include the following:
Personal and Business Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; contact preferences; contact or authentication data; billing addresses; SSN/TIN; business information; and other similar information.
All information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal and business information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies, including third-party cookies that may provide such information to third parties. The information we collect includes:
- Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
- In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), credit scores, Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
- We use personal and business information collected via our Services for a variety of business purposes described below. We process your personal and business information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third- party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract and your requests.
- To post testimonials. We may post testimonials on our Services that may contain personal and business information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To manage user accounts. We may use your information for the purposes of managing accounts and keeping them in working order.
- To send administrative information to you. We may use your personal and business information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
- To verify information. We may use your information to verify your identity, conduct appropriate diligence, and keep your information current, each in connection with our Services.
- To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- To deliver and facilitate delivery of Services to the user. We may use your information to provide you with the requested Service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- To send you marketing and promotional communications. We may use the information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal and business information from you. You can opt-out of our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS” below).
- For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, to evaluate and improve our Services, products, marketing, and your experience and to prepare offers for services from third parties. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal and business information.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process or disclose your data to third parties if you have given us specific consent to use your personal and business information for a specific purpose.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal and business information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Legitimate Business Interests: We may disclose your information to third parties to provide you with requested Services.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal and business information in the following situations.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work and other third parties to offer you services. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
- We will only keep your personal and business information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal and business information for longer than 60 months past the termination of the user’s account unless otherwise required by applicable law.
- When we have no ongoing legitimate business need to process your personal and business information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal and business information has been stored in backup archives), then we will securely store your personal and business information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal and business information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal and business information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal and business information, transmission of personal and business information to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If we learn that personal and business information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your account or that we otherwise have collected on you, or to terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
If you believe that information that we have collected about you is incorrect, you may email us at firstname.lastname@example.org to request that we correct the information. If, after reviewing you request and any supporting documentation, we do not agree to change the information, you may appeal this adverse decision by emailing our legal department at email@example.com. If we change the inaccurate information, NEWITY will notify you of the change.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
Cookies and other tracking technologies may also be used in connection with digital advertising. You can signal digital interest-based advertising opt-out requests with certain participating companies at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you Service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
- Access your account settings and update your preferences.
- Contact us using the contact information provided.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
- California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
- If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary, including to stay compliant with relevant laws.
We may update this privacy notice from time to time. If we make material changes to this privacy notice, the updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org or by post to:
1123 W. Washington Blvd, 3rd Floor
Chicago, IL 60607 United States
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal and business information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal and business information, please email email@example.com. We will respond to your request within 30 days.