PRIVACY NOTICE     

Last updated October 12, 2019  

Thank you for choosing to be part of our community at The NEWHITE inc. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at info@thenewhite.com. 

When you visit our website www.thenewhite.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our 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 Sites and our services. 

This privacy notice applies to all information collected through our website (such as www.thenewhite.com), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the “Services“).  

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.   

TABLE OF CONTENTS  

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?    

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?      

5. HOW LONG DO WE KEEP YOUR INFORMATION?   

6. HOW DO WE KEEP YOUR INFORMATION SAFE?   

7. DO WE COLLECT INFORMATION FROM MINORS?  

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES 

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

11. DO WE MAKE UPDATES TO THIS POLICY?

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?  

Information automatically collected 

In Short: Some information – such as 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.

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 information collected via our Services for a variety of business purposes described below. We process your personal 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.
  
  
• To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  
  
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  
  
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
  
  
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
  
  
• 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 manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  
  
• 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 and to evaluate and improve our Services, products, marketing and your experience. 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 information. We will not use identifiable personal information without your consent.                 

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.   

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose. 
  
  
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. 
  
  
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal 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). 
  
  
• 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 information in the following situations:   

• 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. 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 about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.       
  
  
• 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. 
  
  
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.     

In Short:  We may use cookies and other tracking technologies to collect and store your information.  

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.         

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 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 policy will require us keeping your personal information for longer than the period of time in which users have an account with us.  

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal 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 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 information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal 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 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal 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 have collected from children under age 18, please contact us at info@thenewhite.com.  

8. WHAT ARE YOUR PRIVACY RIGHTS?  

In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.   

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.   

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
 

Account Information  

If you would at any time like to review or change the information in your account or terminate your account, you can: 

■  Log into your account settings and update your user account.  

■  Contact us using the contact information provided.  

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.     

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. To opt-out of interest-based advertising by advertisers on our Services  visit http://www.aboutads.info/choices/.       

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 will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may: 

■  Note your preferences when you register an account with the site.  

■  Access your account settings and update preferences.  

■  Contact us using the contact information provided.