Privacy Statement and Notice of Privacy Practices
PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.
The Site is intended for, and directed toward, individuals and applicants in the United States of America and is not at this time directed to any individuals that may reside outside of the United States. If you are not located in the United States, please do not use the Site or submit information to us through the Site. The Site is controlled and operated by Newbold from the United States and is not intended to subject Newbold to the laws or jurisdiction of any other country.
What Information Do We Collect?
We collect two types of information from you when you visit the Site, “personal information” and “non-personal information”.
We may collect, store, and otherwise process the personal information (“PI”) of:
- visitors to the Site;
- officers and managers of Newbold and other business partners (or other representatives and agents of Newbold’s clients);
- job candidates; and
- other individuals who enter into a business relationship or apply for a job with us or who receive or request information about products or services from Newbold.
Such PI may include: name; phone number; country of residence; professional and/or private address; e-mail address; title and working position; employer; education history; professional interests; professional and/or private telephone numbers; previous work experience; skills; referral information; and other information voluntarily submitted.
For job candidates applying for positions in the United States, PI includes information the candidate includes on a resume. In some cases, Newbold may also collect geolocation data and audio, electronic, visual, or similar information from applicants and/or employees. Newbold may use PI to: conduct its internal and external business operations; provide offers and information about products, services, or events that Newbold thinks may be of interest and facilitate the recruitment process.
Where required by applicable law, Newbold will seek your express consent to collect or process your personal information. You may withdraw that consent at any time by e-mailing Newbold at email@example.com.
Non-Personally Identifiable Information
Non-personally identifiable information (“NPII”) can be technical information or aggregated, non-identifiable, or anonymized information. NPII does not identify you personally. If you provide us with NPII, we may use it for the purposes described in this Policy or any other legal purpose.
Automatic Collection of NPII
When you use the Site, Newbold may automatically collect certain information by automated or passive means using a variety of technologies described below. We use these technologies across the Site to enhance your user experience. These technologies may allow Newbold to personalize your online experience, recognize you as a previous visitor, save your user preferences, and/or maintain your login and password information on secure portions of the Site. We also use these technologies to analyze how users use the Site and to monitor the performance of the Site.
When you visit the Site, Newbold automatically collects certain information about your device, browsing actions, and patterns, including:
- Information about your device and internet connection, including your web browser, IP address, operating system, time zone, and cookies installed on your device.
- Details of your visits to our Site, including individual web pages or products viewed, what websites or search terms referred you to the Site, and other communication data and resources that you access and use on the Site.
For even more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- Necessary Cookies: These cookies are essential to the functionality of the Site in order to facilitate your use of the Site and its features, and in order to enable you to move around the Site smoothly. Without these cookies, Newbold may not be able to provide certain services or features, and the Site will not properly function. Unfortunately, these cookies cannot be disabled or modified, which is why Newbold refers to these as “Necessary.”
- Analytics and Reporting Cookies: Newbold and its third-party vendor service providers may use analytics cookies, which are sometimes called reporting cookies, to collect information about your use of the Site in order to enable us to improve the way it works and prepare statistical analysis of such data. For instance, analytics cookies may collect information about which pages you visit most. The information gathered via analytics cookies allows us to see the overall patterns of usage of the Site, helps us record any difficulties you have with the Site, and shows us whether our advertising is effective or not. We use Google Analytics and Zoominfo to help measure how users interact with the Site. If you have questions about Google Analytics, you may obtain more information about its policy privacy, which can be found at https://policies.google.com/privacy. If you have questions about Zoominfo, you may obtain more information about its policy privacy, which can be found at https://www.zoominfo.com/about-zoominfo/privacy-center.
- Social and Content Cookies: Many social media plugins use social and content cookies (for example, the Facebook ’like’ button), and other tools meant to provide or improve the content on a website. Newbold may integrate these modules into its platform to improve the experience of browsing and interacting with the Site. Please note that some of these third-party services place cookies that are also used for things like behavioral advertising, analytics, and/or market research.
How Long Will Cookies Remain on My Computer or Mobile Device?
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing, and persistent cookies last until they expire or are deleted. Most of the cookies Newbold uses are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. See the section below on how to control cookies for more information on removing them before they expire.
How do I Accept or Reject Cookies?
You can choose to disable or enable cookies at any time on your browser.
Your browser can be set to notify you of the cookies that are deposited in your computer and ask you to accept them or not. You can accept or reject cookies on a case-by-case basis or reject them consistently once and for all. We remind you that the refusal of cookies is likely to modify your conditions of access to the Site. In order to manage the cookies as close as possible to your expectations, Newbold invites you to set your browser taking into account the purpose of the cookies as mentioned above.
For the management of the cookies and your choices, the configuration of each browser is different. We suggest consulting the Help section of your browser or taking a look at the website AboutCookies.org, which offers guidance for all modern browsers.
Use and Disclosure of Personal Information.
Newbold does not sell your Personal Information.
Newbold currently, or may in the future, collect, use, and disclose your PI as authorized or required by written law and/or for any or all of the following purposes (“Purposes”) to:
- Fulfill a service or a service request to you;
- Determine your eligibility for employment with Newbold or its clients;
- Establish and verify your identity;
- Conduct Newbold’s internal business operations, i.e., human resources activities and processing of salaries, other compensation, benefits, and other employment related matters;
- Protect and improve Newbold’s services;
- Obtain services from Newbold’s authorized third-party agents or contractors;
- Respond to your questions, inquiries, comments, and instructions;
- Comply with applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- Manage the legal response in connection with any claims, actions, or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing Newbold’s contractual and legal rights and obligations;
- Update Newbold’s records and keep your contact details up to date;
- Gather data for statistical purposes to help improve the functioning and availability of the Site;
- Protect against fraud;
- Notify you of any known breach of your Personal Information;
- Transmit to any and relevant governmental and/or regulatory authorities, for these Purposes; and
- Assist with any other related purposes that would reasonably be expected for which you provided the information in accordance with consent obtained from you and in accordance with the applicable law.
These Purposes may continue to apply even in situations where your relationship with Newbold has been terminated or altered in any way. In such cases, Newbold may still retain PI relating to you and use or disclose such information for legal and/or business purposes, including for compliance with applicable law.
Sharing Your Personal Information.
Newbold shares your Personal Information with third parties for the Purposes described above. The third parties include vendors who collect and use your PI for employment-related purposes such as background checks and benefits administration.
We may also share your Personal Information with a third party in the event of a proposed or actual sale, merger, or any other type of transfer, or financing of all or any portion of Newbold’s business in order for you to continue to receive the same or similar products and services. In these circumstances, PI may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.
How Newbold Protects Your Personal Information.
We use commercially reasonable technical, administrative, and physical controls best practices to protect your Personal Information, including data encryption where appropriate. However, the internet is not a 100% secure environment and Newbold cannot ensure the security of Personal Information during its transmission between you and us. Accordingly, you acknowledge that when you transmit such Personal Information, you do so at your own risk. Nevertheless, Newbold strives to protect the security of your information. We will notify you of any confirmed security breach of your Personal Information to the extent required by applicable law.
Newbold will retain your Personal Information as long as necessary to fulfill the Purposes outlined in this Policy and in accordance with applicable law.
Use of Website by Minors.
Newbold’s website and services are not directed to children or any individuals under the age of 18, and Newbold does not knowingly collect Personal Information from children. If a parent or legal guardian becomes aware that his or her child has provided Newbold with PI without their consent, the parent or legal guardian should contact Newbold at firstname.lastname@example.org, and Newbold will take steps to delete any such Personal Information.
Communicating With You Electronically.
By using the Site and providing your Personal Information, you agree that Newbold can communicate with you electronically. This includes any required notifications (i.e., legal, technical, regulatory, security, privacy) relating to your use of the Site or Newbold’s services.
Where required by law, Newbold will seek your express consent to send electronic messages. You may withdraw your consent by contacting us at the address listed below, or by e-mailing email@example.com.
How to Contact Newbold.
Newbold Advisors, LLC
25400 US Hwy. 19 N., #124
Clearwater, FL 33763
Effective Date: August 1, 2021
Important Information for California Residents
Rights of California Residents
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes those rights and explains how to exercise them.
- Disclosure of Personal Information We Collect About California Residents
You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
iii. Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information if any; and
- The specific pieces of personal information we have collected about you.
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
iii. Provide the personal information to you more than twice in a 12-month period.
- Disclosure of Personal Information of California Residents Sold or Used for a Business Purpose
Please be aware that Newbold is not currently in the business of selling personal information. Nevertheless, in connection with any personal information, we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
- The categories of personal information that we disclosed about you for a business purpose.
- California Residents’ Right to Opt-Out of the Sale of Personal Information
Under the CCPA, you have the right to opt-out of the sale of your personal information. Please be aware that Newbold is not currently in the business of selling personal information. Nevertheless, if you exercise your right to opt-out of the sale of your personal information, we will add you to a “Do Not Sell List.”
- California Residents’ Right to Deletion
You have the right to request that we delete any of your personal information that Newbold collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform services under a contract;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
iii. Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
vii. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
viii. Comply with an existing legal or contractual obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
- California Residents’ Protection Against Discrimination
You have the right to not be discriminated against by us because you exercise any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
iii. Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you if that difference is reasonably related to the value provided to you by your personal information.
Submitting Requests by California Residents
Requests to Know, Requests to Delete and Do-Not-Sell (Opt-out) Requests* may be submitted by either:
- E-mailing Newbold at firstname.lastname@example.org
- Writing to Newbold at
Newbold Advisors, LLC
25400 US Hwy. 19 N., #124
Clearwater, FL 33763
*Please note that Newbold is not in the business of selling Personal Information.
Only you, or a person registered with the California Secretary of State 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.
Response to California Residents, Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Collection of Personal Information of California Residents
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).
Categories of Personal Information Collected on California Residents
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, identification badges with photograph(s), or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), 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, genetic information (including familial genetic information).|
|D. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.|
|E. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|F. Geolocation data.||Physical location or movements.|
|G. Sensory data.||Audio, electronic, visual, or similar information.|
|H. Professional or employment-related information.||Current or past job history or performance evaluations.|
|I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|J. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Newbold does not collect commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
This section on the rights of California residents does not address or apply to Newbold’s handling of:
- Publicly available information from government records;
- De-identified or aggregated consumer information;
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
- Personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Newbold; and
- Personal information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions (accept that such individuals have the right to opt-out of any sale of their personal information and to not be subject to any discrimination for exercising such right).
Sources of Information Collected on California Residents
We collect personal information directly from you, as well as automatically related to your use of our websites and other services, and from third parties. For example, we collect personal information:
- From any form you may complete and submit through our website;
- From the content of surveys that you may complete;
- When you provide information as a client in connection with us providing professional services to you;
- From other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), and from other third parties; and
- From or on behalf of clients when we provide professional services, which could include personal information about their employees, benefits recipients, insureds, etc.
Purposes of Collecting Information on California Residents
Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table above sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Sources of Information Collected section above, and for the following purposes:
- Contract administration;
- Executing and performing our client engagements;
- Providing various professional services to our clients;
- Activating and maintaining client accounts;
- Fulfilling requests for or responding to inquiries about our products or services;
- Analyzing how our websites are used and how they are performing;
- Performing business development analysis;
- Providing offers and information to you (as permitted by law) about products, services, or events offered by us or that we think may be of interest to you;
- Facilitating the recruitment process; and
- To complete processes necessary to act as an employer
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information of California Residents
We may disclose your personal information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Categories A-J in the above table.
We disclosed your personal information for a business purpose to the following categories of third parties:
- Service providers and independent contractors we use to help deliver our products and/or services;
- Other third parties we use to help us run our business, such as marketing agencies, website hosts, technical security solutions;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Our insurers and brokers; and
- Our banks
We may disclose your personal information in response to subpoenas, court orders, or other lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information in order to enforce or apply our rights and agreements, or when we believe in good faith that disclosing this information is necessary or advisable, including, for example, to protect the rights, property, or safety of our businesses, our websites, our customers, our users, or others, as permitted under the applicable laws, or as otherwise required by law or by government and regulatory entities. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Changes to Our California Privacy Disclosures
We reserve the right to amend these California specific privacy disclosures at our discretion and at any time. Newbold therefore asks all concerned California residents to check it occasionally to ensure that you are aware of the most recent version.
Newbold Advisors, LLC is a consulting and professional services company serving institutional clients in the private and public sectors.
The firm’s mission is to deploy qualified people at competitive rates to achieve tangible results. Our goal is to earn every client’s trust by delivering results with integrity.
25400 US 19 N. #124
Clearwater, Florida 33763
© Copyright 2022 Newbold Advisors