NewGrowth eCommerce Inc. (“NewGrowth”) is an advertising agency with a special focus on helping direct to consumer product companies grow.
We don’t ask you for your personal information unless we truly need it and the only reasons would be for you to contact us, so that we can tell you about our services, join our newsletter, download or sign up to receive content, offer our services, or join our team.
We share your personal information as little as possible, including some co-marketing and co-sponsoring events, and to comply with applicable laws, develop, enhance or modify our services or protect our rights.
We don’t store personal information on our servers unless required to provide you the information you’ve asked for, or for the on-going operation of one of our services or as specified on our website forms.
NewGrowth Inc. (“NewGrowth,” “we,” “us,” or “our”) operates NewGrowth.co (the “Site”), their subdomains, and all portals, products, goods, services, events, and interactive features, or other services controlled by us that post a link to this Privacy Notice (the “Site”). It is NewGrowth’s policy to respect your privacy regarding any information we may collect while operating the Site. This Privacy Notice governs information that we collect from you on the Site and other online and offline communications with our personnel. We refer to all of the above as “Services.” By using the Services, you agree to the terms and conditions of this Privacy Notice. This Notice only applies to Personal Information and other information collected by us from: (i) visitors to our Site; (ii) users of our Services; and (iii) job applicants. If you have questions about this Privacy Notice, contact us at [email protected].
NewGrowth is a data controller for data collected on the Site.
Below is our privacy policy which incorporates these goals:
While using the Site, we ask you to provide us with certain personal information that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to:
We collect Personal Information from you when you choose to apply online for employment with us to assess your suitability for employment. Personal Information includes, but is not limited to:
NewGrowth receives data from its clients and processes this data per contract in place with our clients. NewGrowth does not have a direct relationship with these individuals and is acting as a service provider to our clients in this instance. While we maintain this data, we are only permitted to use it to provide the services we are contracted to handle.
Like most website operators, NewGrowth collects information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. NewGrowth’s purpose in collecting non-personally identifying information is to better understand how NewGrowth’s visitors use the Site.NewGrowth also collects potentially personally identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on blogs if available. NewGrowth only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally identifying information as described below.
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. NewGrowth uses cookies to help NewGrowth identify and track visitors, their usage of the Site, and their website access preferences. NewGrowth visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Site, with the drawback that certain features of the Site may not function properly without the aid of cookies.
The Site may use Strictly Necessary Cookies, Performance Cookies, Functional Cookies, Targeting Cookies and Social Media Cookies. Any of these may be first-party cookies or third-party cookies, persistent or session.
Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example:
There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.
Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
NewGrowth collects statistics about the behavior of visitors to the Site. For instance, NewGrowth monitors the most popular blog posts or pages on the Site. NewGrowth may display this information publicly or provide it to others. However, NewGrowth does not disclose personally identifying information other than as described below.
As mentioned, the information that NewGrowth collects and stores relating to you is used to communicate to you and to provide our services to you. NewGrowth takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personal information.
We may use the information we collect for various purposes, including to:
We use log data for various internal business purposes which include:
If you are a new customer, NewGrowth will only contact you when you have provided consent and only by those means you provided consent.
This section of the Privacy Notice applies solely to visitors, users, and others who reside or are located in the European Economic Area (“EEA”). We adopted this section to comply with European privacy laws, including the GDPR. NewGrowth relies on the following lawful grounds to collect and process any personal data you may have provided:
NewGrowth does not share your personal information with others except as indicated within this policy or when we inform you and give you an opportunity to opt out of having your personal information shared.
NewGrowth discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on NewGrowth’s behalf or to provide services available through the Site, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Site, you consent to the transfer of such information to them. NewGrowth will not rent or sell potentially personally identifying and personally identifying information to anyone without advance notice. We do share information as described above with our website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to only use this information for the purpose in which NewGrowth shared it with them.
For users in the United States, we sometimes participate in joint marketing events with third parties. On the registration page, it is clear who the other joint marketing party is. If you opt-into a joint marketing event or digital asset in the United States, we may provide your registration information to these third parties and partners for use in marketing and in designing or providing their own services, to send you information about their products and to notify you if you win a contest. You may opt out of us providing such information by opting out of our email newsletter and/or not registering for joint marketing events. You should contact the other third party directly who may already be sending you messages in order to request that these communications stop, and to review their privacy policies.
However, anonymized visitor information may be provided to other parties for marketing, advertising, or other uses.
Other than to its employees, contractors and affiliated organizations, as described above, NewGrowth discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when NewGrowth believes in good faith that disclosure is reasonably necessary to protect the property or rights of NewGrowth, third parties or the public at large.
If NewGrowth, or substantially all of its assets, were acquired, or in the unlikely event that NewGrowth goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of NewGrowth may continue to use your personal information as set forth in this policy.
NewGrowth operates the Site in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing NewGrowth with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as the European Union. NewGrowth service providers use appropriate safeguards to transfer your personal data to the United States.
NewGrowth may have links on the Site to other websites that NewGrowth does not operate. If you click on a third-party link, you will be taken directly to that website, which is governed by its own privacy notice. NewGrowth strongly encourages you to read that privacy notice. NewGrowth does not control that website and assumes no responsibility for the content, policies or its practices.
NewGrowth aims to take reasonable steps for you to correct, amend, delete or limit the use of your Personal Information. If you are a customer of one of our clients that works with NewGrowth and would no longer like to be contacted by them, please send your request to the client that you interact with directly. If our client requests NewGrowth to remove or amend that data, we will respond to that request within thirty (30) days.
NewGrowth outlines your choices below:
This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
We will deliver personal information that we are required by law to disclose to you in the manner required by law within (forty-five) 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you through your account, if you maintain an account with us, or electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance.
You have the right to request that we delete personal information about you that we have collected from you.
You have the right to opt out of the disclosure of personal information about you for monetary or other valuable consideration. To Opt-Out, click Do Not Sell My Personal Information.
We may not discriminate against you because you have exercised any of the foregoing rights, including by:
We may however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.
We describe the personal information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled, “Personal Information Collected” above. The information we collect includes the following:
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Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above. |
Yes |
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The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. |
No |
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Characteristics of protected classifications under California or federal law list any of these that you collect: 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. |
Yes |
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Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. |
Yes |
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Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, mobile apps, advertisements that we display on the Site or mobile apps or on third party websites and apps, or NewGrowth pages or accounts on any third-party social media platforms. |
Yes |
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Geolocation data. |
Yes |
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Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above. |
Yes |
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Professional or employment-related information |
Yes |
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Education information |
No |
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Inferences drawn from (1) the information we collect when you visit the Site, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on the Site and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. |
Yes |
We collect this personal information from sources that include our clients and other sources referenced in the “Personal Information Collected” section above.
NewGrowth does not sell your data —we are not data brokers, and we don’t put your data on the open market. However, under the CCPA, some sharing of personal information necessary to provide you with personalized ads and with some of our partners may be considered a “sale,” even if no money is exchanged. In that respect, we have disclosed email addresses and contact information to other businesses and third parties which include our joint marketing partners when we host webinars and events with them within the twelve (12) months preceding the effective date of this Privacy Notice. As is common practice among businesses that operate websites, we may also have disclosed certain online identifiers, information about the use of the Site and inferences drawn about you to our social media, advertising and analytics partners.
We have disclosed personal information in all or substantially all of the categories identified in this section for various business purposes.
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Yes |
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No |
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Yes |
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No |
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Yes |
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Yes |
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No |
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No |
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No |
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Yes |
For more information about the categories of personal information we have disclosed, the categories of entities with which we have disclosed this information and the purposes for which we have disclosed the information, please see “Use of Your Information” above and “Where and How We Share and Disclose Your Information”.
For information regarding the purposes for which we collect and use the personal information we collect, please see “Use of Your Information” and “Where and How We Share and Disclose Your Information” sections above.
Only you or a person 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 if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:
Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within ten (10) business days describing our verification process. We will respond to your request within forty-five (45) calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at [email protected] or by writing us at the address below.
NewGrowth cares about the security of your personal information. Although we cannot guarantee 100% security, we use reasonably appropriate security measures to protect your personal information against unauthorized use, access, modification, destruction or disclosure. We require our third party service providers to use similar safeguards to those we use.
NewGrowth requests that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send NewGrowth this information, then you are consenting to its processing in accordance with this privacy notice. To avoid processing of sensitive data, do not submit it.
The Site is not directed to children under 16. If you learn that your minor child has provided NewGrowth with personal information without your consent, please contact us at [email protected].
Although most changes are likely to be minor, NewGrowth may change its Privacy Notice from time to time, and in NewGrowth’s sole discretion.
NewGrowth welcomes any queries, comments or requests you may have regarding this notice.