Privacy Policy

Your privacy is critically important to us.

NewGrowth eCommerce Inc. (“NewGrowth”)  is an advertising agency with a special focus on helping direct to consumer product companies grow.

At NewGrowth we have a few fundamental principles:

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.

 

EFFECTIVE Jun 30, 2021

Below is our privacy policy which incorporates these goals:

Click on one of the hyperlinks to take you directly to that section of the notice.
  1. Personal Information Collected
  2. Use of your information
  3. Your Rights Under the General Data Protection Regulation (“GDPR”)
  4. How We Share and Disclose Your Information
  5. International Transfer of Data
  6. Third-Party Links
  7. Choice and Individual Rights
  8. Your California Privacy Rights
  9. Security
  10. Sensitive Data
  11. Our Policy on Children’s Information
  12. Privacy Notice Changes
  13. Contact Us

 

1. PERSONAL INFORMATION COLLECTED

1.1. Information You Provide

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:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Job title, profession
  • Company name and URL
  • Social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Site and other service such as tools, widgets and plug-ins offered by social media services or posted on social media pages (such as our social media page or other pages accessible to us)
  • Any other information that you share with us online or offline

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:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • DOB
  • Race/Ethnicity
  • Gender
  • Veteran status
  • Disability status

 

1.2. Information Received from Clients

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.

1.3. Information Automatically Collected

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.

1.4. Cookies

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.

1.4.1. What Kinds of Cookies Do We Use?

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.

  • Strictly Necessary Cookies: These are cookies without which you would not be able to use this Site. For example, Strictly Necessary Cookies adjust the Site data transmitted to match your Internet connection, get you to the secure versions of the Site, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Site will not work. Strictly Necessary Cookies do not store any Personal Information.
  • Performance Cookies: We use these cookies to count visits and traffic sources, to measure and improve Site performance. They help us to know which pages are the most and least popular and see how visitors move around the site. Performance Cookies do not store any Personal Information. Specifically, for analytics providers, we use Google Analytics and Marketo. Google Analytics, which is a web analytics service offered by Google, and Marketo, a 3rd party inbound marketing and sales software, track and report website traffic. Both services uses the data collected to track and monitor the use of our Service. Google Analytics shares this data with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time by contacting us or clicking on the “unsubscribe” link located at the bottom of our email communication. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. To exercise these rights, please contact us at [email protected] . For more information on the privacy practices of Marketo, please visit their Privacy Policy: https://www.marketo.com/company/trust/security/
  • Functional cookies: These cookies allow the Site to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
  • Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the Site and other sites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. To better serve users’ preferences, we have partnered with the Digital Advertising Alliance (http://youradchoices.com), by visiting their website you can learn more about their members who deliver tailored online ads and your choices to opt-out of receiving them. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests. We work with Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/Google AdWords/Analytics: Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/We may also use third-party Service Providers to show advertisements, which may include targeted advertisements on a third-party website after you have visited the Site. We and the third-party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to the Site. Any tracking that a third party performs is subject to their own privacy notice. Our third-party service providers may provide us information that tells us how our marketing ads, often placed on third party websites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you, we would treat it as Personal Information.
  • Social Media Cookies: Social Media Cookies make social sharing easier for you, provide you with tools to connect with the Site, and help us better understand both the audience for the Site and the effectiveness of our social media outreach. These are third-party cookies. Your choices with respect to such cookies are determined by the social media platforms on which you have accounts. Facebook: You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this notice.For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanationWe may participate in Facebook.com’s Custom Audience or LinkedIn’s Audience program which enables us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn respectively. We provide Personal Information such as your email address and phone number to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of participation in this program by contacting us as noted below. You may also opt out of receiving these ads from the social media network directly.

1.4.2. Don’t Want Cookies?

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:

  • Chrome
  • Firefox
  • Internet Explorer
  • Safari

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.

1.5. Aggregated Statistics

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.

2. USE OF YOUR INFORMATION

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:

  • Provide the Services to you, improve the quality of the service, and develop new products and services;
  • Provide you with information about related goods and services which we believe may be of interest to you;
  • Understand how users interact with the Services;
  • Contact you about goods and services by any of the methods that you have consented to at the time we collected your information;
  • Fulfill any other business or commercial purposes at your direction or with prior notice to you and your consent;
  • To assess your suitability for employment when you apply online for a job with us.

We use log data for various internal business purposes which include:

  • To monitor abuse and prevent illegal activities and fraud,
  • To troubleshoot product functionality and fix bugs;
  • To track people’s preferences which allows us to create new services, features and content that may be more personalized for you and your interests;
  • To track behavior on a aggregated/anonymous level to track and understand trends related to our offerings and services.

If you are a new customer, NewGrowth will only contact you when you have provided consent and only by those means you provided consent.

 

3. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

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:

  • Legitimate Business Interests: To notify you about any changes or improvements to NewGrowth services that may affect our service. If you are an existing customer, NewGrowth may contact you with information about goods and services like those which were the subject of a previous transaction with you.
  • Performance of Contract: To meet NewGrowth’s contractual commitments to our clients and in performance of contractual obligations to our clients.
  • User Consent: If you are a user of the Site and have supplied your email address and provided consent, NewGrowth may occasionally send you email to tell you about industry news and information, solicit your feedback, or keep you up to date with what’s going on with NewGrowth and our services. We primarily use our email newsletter or email you updates on our blog to communicate this type of information.

4. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

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.

4.1. Third Party Service Providers, Employees, Agents or Contractors

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.

4.2. Third-party Disclosure for Joint Marketing Events & Digital Assets

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.

4.3. To Comply With Legal Process Or To Protect NewGrowth

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.

4.4. Business Transfers

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.

5. INTERNATIONAL TRANSFER OF DATA

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 transfer data that we collect from you to locations outside of headquarters for processing and storing. In addition, it may be processed by staff operating outside the office area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. NewGrowth will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Notice.
  • Data that is provided to NewGrowth is stored on our secure servers. Details relating to any transactions entered into via the Site will be encrypted to ensure its safety.
  • The transmission of information via the internet is not completely secure and therefore NewGrowth cannot guarantee the security of data sent to NewGrowth electronically and the transmission of such data is entirely at your own risk. Where NewGrowth has given you (or where you have chosen) a password so that you can access certain areas of the Site, you are responsible for keeping this password confidential.

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.

7. CHOICES AND INDIVIDUAL RIGHTS

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:

  • Email. As described above, if you do not wish to receive promotional emails from NewGrowth or for us to share your information with a joint partner in co-branded marketing events, you may opt out at any time. If you opt out of a promotional email, NewGrowth may still send you transactional and administrative emails about this privacy notice or about the products or services you have purchased.
  • Cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
  • Advertising. You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings.
  • Your rights under certain circumstances. To initiate any of these actions please contact us at [email protected].
    • To access and receive a copy of the Personal Information we hold about you.
    • To rectify any Personal Information held about you that is inaccurate
    • To request the deletion of Personal Information held about you
    • You have the right to data portability for the information you have provided to us. You can request to obtain a copy of this information in a commonly used electronic format so that you can manage and move it. We will need to verify your identity before being able to respond to such requests.
    • Please note that in some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
  • Right to Lodge a Complaint. For European Union residents, if you feel that NewGrowth’s processing of your personal data infringes on data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you habitually reside, your place of work or the location of the alleged infringement. If you are located outside of the European Union, you may have rights under privacy laws in the jurisdiction where you live.

8. YOUR CALIFORNIA PRIVACY RIGHTS

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.

8.1. Right to Access and Information Regarding Personal Information

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:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information;
  • The specific pieces of information we have collected about you;
  • The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
  • The categories of personal information about you that we disclosed for a business purpose.

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.

8.2. Right to Deletion of Personal Information

You have the right to request that we delete personal information about you that we have collected from you.

8.3. Right to Opt Out

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.

8.4. Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the foregoing rights, including by:

  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

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.

8.5. Personal Information We Collect About California Consumers

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:

Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above.

Yes

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

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

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

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

Geolocation data.

Yes

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

Professional or employment-related information

Yes

Education information

No

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.

8.6. Disclosure of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes

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.

  1. Identifiers such as name, address, email address, phone number.

Yes

  1. 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

  1. Characteristics of protected classifications under California or federal law

Yes

  1. 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.

No

  1. 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 Response Media pages or accounts on any third-party social media platforms.

Yes

  1. Geolocation data.

Yes

  1. Audio information from calls placed with customer service that may be reported, and electronic information in the form of Internet or other electronic network activity information described above.

No

  1. Professional or employment-related information

No

  1. Education information

No

  1. Inferences drawn from (1) the information we collect when you visit our 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

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.

8.7. Requests to Exercise Your Rights

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:

  • Logging in to your account (if you have an account) and submitting a request (provide link to log in page);
  • Submitting a request to [email protected] 

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.

8.8. Data Sharing for Direct Marketing Purposes

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.

9. SECURITY

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.

10. SENSITIVE DATA

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.

11. OUR POLICY ON CHILDREN’S INFORMATION

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].

12. PRIVACY NOTICE CHANGES

Although most changes are likely to be minor, NewGrowth may change its Privacy Notice from time to time, and in NewGrowth’s sole discretion.

13. CONTACT US

NewGrowth welcomes any queries, comments or requests you may have regarding this notice.