ADDENDUM FOR CALIFORNIA USERS
Effective Date: December 20, 2022
This Privacy Notice Addendum for California Residents (the “CA Notice”) supplements the information contained in the Newfold Digital, Inc. Privacy Notice (the “Privacy Notice”), and applies solely to California Residents (“Consumers” or “You”). This CA Notice does not apply when we are acting as a service provider and processing personal information on behalf of our customers.
In addition to the rights described, where the California Consumer Privacy Act 2018 (“CCPA”) or related data protection laws apply, you may:
- Request to know the categories of personal information we collect about you, as well as the sources from which the personal information is collected; the business or commercial purpose of our collection; the categories of third parties with whom we share your personal information; and the specific pieces of personal information we hold about you.
- Request certain information regarding the opt-out of our disclosure of your personal information to third parties.
- Request that we delete the personal information we hold about you in certain limited circumstances.
Information We Collect as a Business Under the California Consumer Privacy Act (“CCPA”)
We collect personal information, meaning information that identifies, relates to, references, describes, or is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or device. For the purposes of this CA Notice, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
We collect personal information from and about consumers for a variety of business purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the “Information We Collect From You” and “How We Use Your Information” sections in our Privacy Notice.
In the last 12 months, we have collected the following categories of personal information from the sources and for the purposes stated below.
Examples of Categories of Personal Information Collected
Identifiers: Name, address, phone number, email address, or other similar identifiers.
Commercial Information: Products or services purchased and information relating to your use of our services.
Internet/Network Information: IP address, browser or device information.
Other Personal Information: Information you provide to us when you register for or attend an event organized or hosted by us, information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you post on message boards, blogs or complete an online form.
Inferences: Information generated from your use of the websites reflecting predictions about your interests and preferences.
Sensitive Personal Information: Certain information such as social security, driver’s license, state identification card, or passport number may be collected to confirm your identify or facilitate payment. However, we do not use or disclose the information for any reason except as necessary to perform the service requested or meet our legal obligations.
We obtain the categories of personal information listed above from the following sources:
- Directly from you;
- From our business partners and affiliates;
- From third parties whom you direct to share information with us; and
- From your online browsing and usage activity.
Purposes for Collecting Personal Information
We may collect, use or disclose personal information about you for one or more of the following business and/or commercial purposes:
- To provide the requested services to you;
- To provide you with useful content;
- To ensure the proper functioning of our services;
- To offer and improve our services;
- To provide you with requested information or technical support;
- To facilitate your movement through our websites or your use of our services;
- To do a better job of advertising and marketing our services (subject to your consent where required by applicable law);
- To advertise and market third party products and services (subject to your consent where required by applicable law);
- To diagnose problems with our servers or our services;
- In connection with our security and compliance programs;
- To administer our websites;
- To communicate with you;
- To target current or prospective customers with our products or services through online advertisements served on third-party sites by third-party vendors, such as Google (subject to your consent where required by applicable law); and
- To assist us in offering you a personalized experience or otherwise tailor our services to you.
Disclosure of Personal Information
In the previous 12 months, we have disclosed the categories of personal information we collect to the following third parties for the business purpose set out in the table below.
Examples of Categories of Personal Information Collected and Disclosed to Third Parties
Identifiers: Service providers and vendors, partners, authorized users within your organization and other members of our corporate family.
Commercial Information: Service providers and vendors, partners, authorized users within your organization and other members of our corporate family.
Internet/Network Information: Partners and other members of our corporate family.
Other Personal Information: Third party service providers, vendors and partners.
Inferences: Third party service providers and vendors, partners and other members of our corporate family.
Sale of Personal Information
When you interact with our websites, we may use, or authorize third-party partners and service providers to use, cookies, web beacons and similar technologies to improve your experience with us. These technologies can collect personal information about you that can be used by us and/or our authorized third-party partners and service providers. Our sharing of your personal information in this way may constitute a “sale” under the CCPA.
Pursuant to the CCPA, in the preceding 12 months, we have sold the following categories of personal information for the purpose of showing you ads about Newfold’s services:
- Internet or other similar network activity
If you’d like to opt out of the sale of your personal information, please click Cookie Settings to update your Cookie Settings.
Except as provided above, we do not sell personal information to third parties.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain exceptions:
The Right to Know
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon our verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of your personal information;
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or, if applicable, selling the personal information.
The Right to Request Deletion
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of the Sale of your Personal Information
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising these rights.
“Shine the Light”
California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to a third party for the third party’s direct marketing purposes.
How to Exercise Your California Consumer Rights
To exercise your California Consumer Rights, please submit a request to us by:
- Visiting our Privacy Center or click here;
- Calling the toll free phone number or clicking the “contact us” link located on the homepage for the products or services you receive from us; or
- Sending an email to [email protected].
If you’d like to opt-out of the sale of personal information, please click Cookie Settings to update your Cookie Settings.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf. For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
If you’d prefer a hard copy of this CA Notice or to access it as a PDF, this site permits you to print it to PDF or to a printer.
Newfold as a Service Provider
Newfold acts as a service provider to its customers. When acting in this capacity, we process personal information on behalf of our customer, and we have no direct relationship with the end-users who use our customers’ services or products or visit our customers’ websites.
If you are an end user of one of our customers whose personal information we process and you are seeking to exercise your rights under the CCPA, you should contact our customer directly.