Newledge will never sell your information to someone else for advertising, or made money by showing you other people’s ads, and we never will. This has been our approach and we remain committed to it. This policy tells you what information we do collect from you, what we do with it, who can access it, and what you can do about it. We respect the EU regulation called GDPR 697/2016.
The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.
Part I Information Newledge collects and controls
We only collect the information that we actually need. Some of that is information that you actively give us when you sign up for an account, register for an event, ask for customer support, or buy something from us. We store your name and contact information, but we don’t store credit card numbers.
When you visit one of our websites or use our software, we automatically log some basic information like how you got to the site, where you navigated within it, and what features and settings you use. We use this information to improve our websites and services and to drive new product development.
Sometimes we receive information indirectly. If you ask about our products through one of our referral programs or reselling partners or sign in to one of our products through an authentication service provider like LinkedIn or Google, they’ll pass on your contact information to us. We’ll use that information to complete the request that you made. If you engage with our brand on social media (for instance, liking, commenting, retweeting, mentioning, or following us), we’ll have access to your interactions and profile information. We’ll still have that information even if you later remove it from the social media site.
What we do with your information
We use your information to provide the services you’ve requested, create and maintain your accounts, and keep an eye out for unauthorized activity on your accounts. We also use it to communicate with you about the products you’re currently using, your customer support requests, new products you may like, chances for you to give us feedback, and policy updates. We analyze the information we collect to understand user needs and to improve our websites and services.
We’re required to have a legal basis for collecting and processing your information. In most cases, we either have your consent or need the information to provide the service you’ve requested from us. When that’s not the case, we must demonstrate that we have another legal basis, such as our legitimate business interests.
You can decline certain kinds of information use either by not providing the information in the first place or by opting out later. You can also disable cookies to prevent your browser from giving us information, but if you do so, certain website features may not work properly. We completely disable third-party cookies from all Newledge websites and products.
We limit access to your personal information to our employees and contractors who have a legitimate need to use it. If we share your information with other parties (like developers, service providers, domain registrars, and reselling partners), they must have appropriate security measures and a valid reason for using your information, typically to serve you.
Part II Information that Newledge processes on your behalf
If you handle other people’s data using Newledge apps, such as information about your customers or employees, you are entrusting that data to us for processing. If you use a Newledge mobile app and give the app access to your contacts and photo library, you are entrusting data to us. The data you entrust to us for processing is called service data.
You own your service data. We protect it, limit access to it, and only process it according to your instructions. You may access it, share it through third-party integrations, and request that we export or delete it.
We hold the data in your account as long as you choose to use Newledge Services. After you terminate your account, your data will be automatically deleted from our active database within 6 months and from our backups within 3 months after that.
If you are in the EU and you believe that someone has entrusted your information to us for processing (for instance, your employer or a company whose services you use), you can request certain actions from us regarding your data. To exercise those data rights, please contact the person or company that entrusted the data to us and we will work with them on your request.
Part III General
There are some limitations to the privacy we can promise you. We will disclose personal information if it’s necessary to comply with a legal obligation, prevent fraud, enforce an agreement, or protect our users’ safety. We do not currently honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.
Information that you provide us
- Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the account signup process. You’ll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language, but we don’t require that information to sign up for an account. After signing up.
- Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact Newledge for any other purpose.
- Testimonials: When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at info@new-com.
- Interactions with Newledge: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically
- Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
- Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.
Information that we collect from third parties?
- Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at info@new-com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
- Information from our reselling partners and service providers: If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Newledge. If you register for or attend an event that is sponsored by Newledge, the event organizer may share your information with us. Newledge may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
- Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. Newledge may also add and update information about you, from other publicly available sources.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
- To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
- To ask you to participate in surveys, or to solicit feedback on our products and services;
- To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
- To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
- To provide customer support, and to analyze and improve our interactions with customers;
- To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Newledge, Newledge users, third parties and the public;
- To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
- To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
- To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to Newledge: If you are an individual from the EU our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on contractual necessity, one or more legitimate interests of Newledge or a third party that are not overridden by your data protection interests, or your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the «unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information : You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
Who we share your information with
Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Domain registrars: When you register a domain through Newledge from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the ICANN domain registration rules.
Reselling partners: We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.
Marketplace application developers : When you install or purchase any application developed using Newledge’s APIs that is posted on Newledge’s online marketplace, your name and email address will be shared with the developer of the application, so they may engage with you directly as the provider of that application or service. Newledge does not control the use of your personal information by the developers, which will be based on their own privacy policies.
Other cases: Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you as a controller
If you are in the EU, you have the following rights with respect to information that Newledge holds about you. Newledge undertakes to provide you the same rights no matter where you choose to live.
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
Who we share service data with
Newledge group and third party sub-processors: In order to provide services and technical support for our products, the contracting entity within the Newledge group engages other group entities and third parties
Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the Newledge group entities involved in providing the services (collectively our employees”) so that they can identify, analyze and resolve errors, manually verify emails reported as spam to improve spam detection, or manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Newledge group.
Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.
Third-party integrations you have enabled: Most of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.
Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Data subject requests
If you are from the c and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III General
Children’s personal information
Our products and services are not directed to individuals under 16. Newledge does not knowingly collect personal information from children who are under 16 years of age. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to firstname.lastname@example.org with the details, and we will take the necessary steps to delete the information we hold about that child.
External links on our websites
Social media widgets
Our websites can include social media widgets such as Facebook “like” buttons and Twitter “tweet” buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes