NewNew Privacy
NewNew Privacy

NewNew Privacy

Table of Contents

Introduction

This privacy policy (“Privacy Policy”) describes NewNew Inc.’s (“NewNew” or “We” or “Company”) practices for collecting, storing, using, disclosing and protecting information.

This policy applies to information we collect:

  • when you visit or otherwise use our website https://newnew.co
  • when you visit or otherwise use our mobile application
  • when you interact with us through email, text and/or other electronic messages

(collectively, the “Site”). This Privacy Policy does not apply to other websites to which we may link, or to other companies or persons who might be listed as third-party contacts on our Site, or to whom we may refer you if you contact us.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By installing, accessing or using the Site, you agree to the use of your information in accordance with this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy located below). Your continued use of our Site after we make changes to this policy is deemed to be acceptance of those changes, so please check the policy periodically for updates.

What This Privacy Policy Covers

This Privacy Policy describes the following general aspects of our collection and processing of information concerning you.

1. Information We Collect

The following generally describes the type of information we may collect about you.

Information Provided by You

We collect information directly provided by you (which may be obtained from emails, registration, web forms or in other manners), including, without limitation:

  • Personal Information. Information that relates to you, or can be related to you, personally and/or can be used alone to contact you online or offline, such as your full name, user name, email address, phone number, photograph, videos, User UUID, Device Information, gender, date of birth, and zip code. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This includes information provided at the time that you register for an account with us, participate in bids, multichoice, chat, direct messaging, request support, sign up to receive notifications, submit a video, or in any other way take steps that require the submission of information.

If you provide User Content (as defined in our Terms of Use), you may be required to submit additional Personal Information.

If you choose to submit your information to us for any other reason in any other form (e.g., customer support requests, inquiry submissions, etc.), we will collect such information and use it for the purposes for which you submitted it and to improve the Site and our services.

Should you provide us with your information, you consent to our use of it in accordance with this Privacy Policy.

Content You Share

You may be able to post information and materials publicly, for example, when you submit a video and other similar forums (collectively, “Public Forums”), subject to the Public Forums rules in our Terms of Use. If you post any information in Public Forums on the Site, it will be deemed public information and available to the general public. Please do not post any personally identifiable information in a Public Forum. If you do post personally identifiable information, you do so at your own risk, and consent to it being used as User Content, in accordance with our Terms of Use.

You may be able to access posting and sharing tools on the Site that allow you to post or share information to your social networks outside of the Site. By using these tools, you acknowledge that some account information from your account on the applicable social network may be shared with us and we may use that information in accordance with this Privacy Policy.

Technical Information

As you navigate through and interact with our Site, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Information about your mobile device, such as your unique device ID, Internet Protocol (IP) address, or other persistent identifiers, and their hardware/software/firmware.
  • “Usage Data,” which includes data relating to usage of your device, such as the actions you take within and outside of the Site, the browser and/or device you use, the date and time of your use of the Site, particular preferences you have chosen, and the apps you used before and after using our Site, and other communication data and the resources that you use to access and use our Site.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

Even if you do not submit Personal Information through the Site, we gather navigational information about where visitors go on the Site and information about the technical efficiencies of our Site and services (i.e., the time the Site was accessed, what content was accessed, etc.). This information allows us to see which areas of our Site are most utilized and helps us better understand the user experience. In this process of gathering information, we may collect personally identifiable and non-personally identifiable information (for example, browser type and version, service provider and IP address, operating system, and date/time stamp). This helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

  • Improve the quality of the Site by recognizing and delivering more of the features, areas, and services our visitors prefer.
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Site according to your individual interests.
  • Recognize you when you return to our Site.

We may also create and use this navigational information to compile statistics about how our visitors collectively interact with our Site. We may also maintain this information or associate it with Personal Information we collect in other ways or receive from third parties.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on our Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Social Media

We may monitor social media or review sites, and collect information posted on comments or reviews. When you post information on social media pages owned or controlled by us, we may collect information about your activities on those pages, including whether you visited or commented on the page, or provided a rating or review.

Customer Support

You may contact our customer support for assistance, such as getting information and advice regarding using our Site, etc. If you do so, we may ask you for information such as your name, email address, postal address and telephone number. We use this information to respond to your requests.

2. How We Collect Your Information

We collect information in three primary ways!

You Give Us Information

We collect information from you when you submit it to us through our Site, and other digital media.

We Collect Information Automatically

We automatically collect certain types of information when you visit our Site or use our products and services. For example, we automatically collect various types of technical information when you use our Site as otherwise described in this Privacy Policy.

We Collect Information from Other Sources

We may obtain information about you from outside sources. For example, we may obtain commercially available information about you from third parties, such as credit information, or to prevent fraud, or we may purchase email lists from third parties for advertising and marketing purposes. We may also receive information from third parties who provide services for us through web-beacons and other technologies as otherwise discussed in this Privacy Policy.

We also may use various technologies to collect information about you, including:

Use of Cookies

Cookies are bits of electronic information that may be transferred to a user’s computer or mobile device to identify specific information about the user’s use of a website, email or other electronic media. The Site may use cookies that assign a unique identification to your mobile device or computer. Cookies are typically stored in your device’s local storage and are used to help track clicks as you go through a website or electronic advertisement. We may also use cookies to tell us whether you have previously accessed an electronic advertisement. Third-party entities with whom we have agreements may also place cookies onto your computer or mobile device. Those third-party cookies enable us to obtain aggregated information (i.e., information where your Personal Information has been de-identified) and user statistics about you and your preferences.

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools to remove cookies which may have been placed onto your computer or mobile device. However, please be aware that some of our Site’s features require cookies to operate correctly and if you turn off cookies or refuse them, they may not function properly. We will not use shared local objects (commonly referred to as “Flash cookies”) in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service. Flash cookies are cookies that are placed on your computer or mobile device that are not removed through normal browser management tools.

Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript

We may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on our Site and in our emails to you. Both pixel tags, which are small graphic images (typically that you cannot see), and JavaScript plug-ins, which are code on a website or in an email message, are used for such things as recording links and advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our Site and our marketing. We also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices through the Site and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which you may click in emails.

Server Logs and Widgets

A “server log” is a record of activity created by a computer that delivers certain content to your browser or mobile device. Certain activities that you perform on our Site may record information in server logs. The server log may record the content you requested, or the links you clicked on our Site. The server log may also record information such as your IP address and the cookies set on your device.

A “widget” is generally an application that can be embedded in a webpage or mobile application. Widgets can provide real-time information to the webpage or app. Widgets are often provided by third parties and we may provide widgets on our website. Widgets may enable the third-parties that provide them to collect data about users using the Site.

Notifications

We may communicate with you via push notification, email, SMS, MMS or other text message (“Message”) (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Message or receive a push notification. We use this information to improve our services, including without limitation our customer support.

Surveys and Promotions

From time to time, we may request information from users via surveys and other promotions. Participation in these surveys or promotions is completely voluntary and the user therefore has a choice whether or not to disclose this information. If you choose to participate, we may ask you for additional information, which may include contact information (such as name, email and shipping address) and/or demographic information (such as postal code, age level), to provide better services and options to you. We use the information you provide to us to administer our sweepstakes, surveys, contests and other promotions, in addition to the purposes set forth herein. If your information gathered via a survey will be used in a manner different from that described in this Privacy Policy, such use will be detailed in the survey instructions. For example, the instructions will alert you if the information will be shared with anyone in addition to those identified in this Privacy Policy, such as a third party sponsoring the survey.

3. How We Use Your Information

We use the information we collect in a variety of ways. We collect information from you because it helps us to provide, improve and deliver our products and services. Specifically, we use the information we collect.

To Provide our Services

For many business purposes, such as to: (i) allow you to register an account; (ii) allow you to participate in Bids, Superpolls, Goals, and/or subscriptions; (iii) analyze trends and conduct research about improving our products and services; (iv) provide support and respond to questions from Site users; (v) improve our Site, products and/or services; (vi) learn about our users’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our product recommendations and promotions to you based upon your information; (viii) track traffic patterns and Site usage; and (ix) provide customer support.

When permitted by law, we may also use your personally identifiable information to contact you in ways other than email or regular mail, such as via telephone contact, facsimile or text message.

To Market to You

To send you promotional, advertising and other marketing materials or communications from us or our agents, and provide you with more relevant advertisements (referred to as “Retargeting”). We may correlate your information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts and to provide specific relevant marketing, promotional, or other information to you. You may opt-out of receiving such communications any time by contacting us as provided for in the Section of this Privacy Policy entitled Your Choices Regarding Your Information.

To Improve our Business

To help us design and deliver our Site, including but not limited to as part of our network’s functionality, engineering activities, and troubleshooting.

When you Send-To-A-Friend

You may also have us send certain content to other individuals using the Site. To send information to others, we request both your email address and theirs. We may retain the information you provide in connection with this feature.

As part of Business Transfers

In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a reorganization, we may need to transfer some or all of your information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or reorganization. We may also need to transfer your information to that reorganized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.

If we, or substantially all of our assets, were acquired, or in the unlikely event that we go out of business or enter 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 may continue to use your Personal Information in accordance with this Privacy Policy.

To Comply With the Law and Our Legal Obligations

To investigate claims and/or legal actions, violations of law or agreements, and as part of complying with relevant applicable laws and legal process. For example, we may disclose your information in order to comply with or respond to a request or requirement pursuant to law or regulation, or from a governmental or judicial body, or to help prevent fraud or for risk management purposes.

To Protect Ourselves and Our Users

To the extent necessary to detect, block, report and mitigate cyber-threats, improve our network and information security, and in order to prevent or detect fraud. Network and information security means the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via, those networks and systems.

We may use your information to cooperate with police and other governmental authorities, or to protect the rights, property or safety of our Site users or the public.

When We De-Identify or Aggregate Information

We may collect, use, transfer, and disclose information that is de-identified or does not identify you. To the extent we combine information that is de-identified or does not identify you with information that does identify you that we collected directly from you on the Site, we will treat the combined information in accordance with the practices described under this Privacy Policy.

4. Children’s Information

We recognize the importance of children’s safety and privacy. The Site is not designed to attract children, and is not directed at, or intended for use by, children under the age of 13. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not request or collect any personally identifiable information (“PII”) from anyone who we know to be under the age of 13. If you are under the age of 13, you should not register with, or provide information to us. If you are a parent of legal guardian or a child under the 13 years of age and you believe your child has provided us with Personal Information, please contact us at legal@newnew.co.

If we become aware that a user of our Site is under the age of 13 and has registered for our Site or provided other PII without prior verifiable parental consent, we will take all commercially reasonable steps to delete such information from our files and not to use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). We ask all parents and legal guardians to assist us in our efforts to comply with COPPA by prohibiting children under the age of 13 from providing us with any of their PII or using the Site without parental oversight and assistance. If you have knowledge or become aware that a child under the age of 13 has submitted PII to us, please contact us and we will remove that child’s PII from our files. If you are under the age of 18, you should use this Site only with the involvement of a parent or legal guardian and should not submit any PII to us.

If you are resident of California under the age of 18, please see also see the Your California Privacy Rights Section of this Privacy Policy.

5. Sharing of Information with Third Parties

We may share personally identifiable information and non-personally identifiable information externally with our affiliates, licensees and joint venture partners, as well as with other third-party service providers who help us provide services for the Site and our business. 

However, we require these service providers to use your information only for our benefit and in accordance with this Privacy Policy. These service providers include, but are not limited to:

Email Marketing Services Providers

Business entities that provide email address management and communication contact services;

Information Technology Service Providers

Network equipment, artificial intelligence platforms, application management providers and hosting entities;

Credit Processing Companies and Related Financial Institutions

Credit and debit card payment gateways and processors; the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts;

Other Service Providers

Other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Policy.

We may share your personally identifiable information and non-personally identifiable information with other users of our Site, including:

User Profile Information

User profile information that includes your first name, first initial of your last name, username and other information you may enter or submit at sign up, and the content you submitted as part of using our services. Please do not provide any personal information in your profile that you do not wish to be made public. Your profile information is generally accessible to other users of our Site.

We may also share personally identifiable information and non-personally identifiable information with selected third parties, who may use your information for reasons other than for our benefit, including:

Legal and Investigator Service Providers

We may share your information with judicial, administrative, legal, financial and/or accounting providers, and related government entities and adverse parties. Some instances where this may occur, include, but are not limited to: if we are required to respond to civil and/or criminal investigations, claims and/or lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and as we believe is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

Business/Asset Purchasers

In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a reorganization, we may need to transfer some or all of your information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or reorganization. We may also need to transfer your information to that reorganized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.

If we, or substantially all of our assets, were acquired, or in the unlikely event that we go out of business or enter 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 may continue to use your Personal Information in accordance with this Privacy Policy.

We may also share personally identifiable information and non-personally identifiable information with selected third parties who may also use your information in accordance with their own privacy policies.

By using our Site, you agree to your information being collected and used in this manner. These companies include but may not be limited to:

Vercel

We use Vercel to compile analytics regarding the usage of our Site. As part of providing these features, Vercel may gather information about your device, usage information, and/or location information. They may also use devices such as cookies and local storage to gather additional information. To better understand the types of information that Vercel may gather and how they may use your information, please see their privacy policy located at: https://vercel.com/legal/privacy-policy.

AppsFlyer

We use AppsFlyer to measure and analyze the effectiveness of our marketing campaigns. AppsFlyer may gather such information as technical information, technical identifiers, and/or engagement information. They may also use devices such as pixel tags, redirection links, JavaScript tags, cookies or similar data collection technologies to gather additional information. To better understand the types of information that AppsFlyer may gather and how they may use your information, please see their privacy policy located at: https://www.appsflyer.com/legal/services-privacy-policy/.

Mixpanel

We use Mixpanel to compile analytics regarding the usage of our Site. Mixpanel may gather information such as: IP address, location, website activity, and browser information. They may also use devices such as first and third-party cookies, local browser storage, and other tracking technologies to gather additional information. To better understand the types of information that Mixpanel may gather and how they may use your information, please see their privacy policy located at: https://mixpanel.com/legal/privacy-policy/.

When you take part in transactions through our Site, we may process payments through third-party service providers. The third-party service providers may collect certain financial information from you to process a payment, including your name, email address, address, credit card number, and other billing information. These third-party service providers may also provide such information to us. Since your information is provided directly to these service providers when you complete a transaction, you should review their privacy policies to see how your information will be handled. The following is a list of these providers and where to locate their privacy policies:

Third parties may also use various forms of technology through our Site to collect personally identifiable information and non-personally identifiable information.  In these instances, your information is governed by that third-party’s privacy policy. These technologies may include:

Social Media Platforms

We maintain presences on social media platforms, including Twitter, TikTok and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices Regarding Your Information.

By your own actions, you may also be able to share personally identifiable information and non-personally identifiable information with third parties through our Site, such as when you:

Post Information

You may be able to post information and materials publicly, for example, when you submit a video as a creator. If you post any information on the Site, it will be deemed User Content and available to the general public. Please do not post any personally identifiable information. If you do post personally identifiable information, you do so at your own risk, and consent to it being used as User Content, in accordance with our Terms of Use.

Use Social Media and Social Media Widgets

Certain widgets embedded in our Site may enable you to post information and materials publicly on social media pages. If you post any information on social media, it will be deemed public information and available to the general public. If you do post personally identifiable information, you do so at your own risk, and consent to it being used as User Content, in accordance with our Terms of Use. Your interactions with those widgets and platforms are also governed by the privacy policies of the companies that provide them.

We will not sell, rent or transfer your Personal Information to third parties for their direct marketing purposes without your prior consent. Specifically, we will not disclose your Personal Information to third parties for their direct marketing purposes unless you first “opt in” or affirmatively agree to the disclosure.

6. Links to Third Party Websites

For your convenience, our Site may contain links to other websites. We are not responsible for the privacy practices, advertising, products, or the content of such other websites. None of the links should be deemed to imply that we endorse or have any affiliation with the third party websites being linked to.

7. Your Choices Regarding Your Information

If you do not consent to the way in which we may use your information, please do not submit any information to us.

Opt-Out of Email Promotions

If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link or follow the unsubscribe instructions located in our emails.

Updating Your Information

We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at legal@newnew.co. Further, you can update your profile information by logging into your account. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

You may also contact us, as provided below, to request review, correction or deletion of any Personal Information that you have provided to us. We reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.

Please note we may not be able to delete your Personal Information except by also deleting your user account. We may also not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you choose to delete your User Content from the Site, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Access and use of information on the Site, including User Content, is governed by our Terms of Use.

Tracking Technologies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

How We Respond to “Do Not Track” Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. We will abide by any “Do Not Track” signals. As described above, such technology may negatively affect the functionality of the Site. To learn more about DNT signals, please see http://allaboutdnt.com.

Targeted Advertising

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us as provided below.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties provide you with ways to choose not to have your information collected or used in this way, namely:

  • You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at: www.networkadvertising.org/choices/.
  • You can also opt out of receiving targeted ads from certain members of the Digital Advertising Alliance (“DAA”) by installing the DAA’s AppChoices tool. You can find more information about AppChoices at: http://youradchoices.ca/.

Please note that any opt-out choice you exercise will apply to interest-based advertising by the third parties you select, but will still allow the collection and use of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.

To learn more about interest-based advertising or to “opt-out” of interest based advertising programs from participating companies visit www.networkadvertising.org, www.aboutads.info/choices/, http://youradchoices.ca, or http://www.youronlinechoices.eu.

Depending on your device and its operating system, you may also be able to choose to prevent your device’s ad identifier being used for interest-based advertising or reset your device’s ad identifier by changing the settings of your device.

How to Opt-Out by Mail or Email

If you do not wish to receive other marketing materials from us and/or if you do not want us to share your Personal Information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please direct your opt-out requests to:

8. Your California Privacy Rights

If you are a California resident, you are entitled to certain notices and disclosures regarding the collection and use of your information. Please see our Privacy Notice for California Residents that describes our collection and use of your information for specified purposes.

In addition, while we do not sell your information for money, we may disclose your information to third parties, such as our marketing and analytics providers, in such a way that may be considered a “sale” of personal information under the California Consumer Privacy Act of 2018 (“CCPA”).  To stop such “sales” please follow the instructions provided on our Do Not Sell My Personal Information page.

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that consumer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that either do not disclose Personal Information to third parties for direct marketing purposes without prior approval or gives California consumers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes (for more detail on our policy, please see the Section above entitled “Sharing of Information with Third Parties”). California users may request further information about their rights under this law and our policy by writing to us at legal@newnew.co, using the subject line “CA Request for Information,” and requesting further information. We may need to request additional information from you to verify your identity and determine you have the necessary rights to access the information.

If you are a California resident under the age of 18, and a registered user of our Site, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to legal@newnew.co and include “CA Removal Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

If you would like to exercise your rights under California law, please send your written request to legal@newnew.co. Please include your postal address in your request.

9. Visitors From Outside of the United States

We are a United States company that utilizes service providers located in the United States and other countries. Therefore, when you use our Site, your information may be transferred to, stored, or processed outside of the country in which you reside and may be maintained on servers and systems located within the United States or other countries. The data protection laws in the United States and those other countries might not be as strict as those in your country. By using our Site and/or submitting information to us, you specifically consent to the transfer of your information to the United States and those other countries and the facilities and servers utilized by us and those with whom we may share your information.

10. How We Protect Your Information

It is entirely your choice whether or not you provide Personal Information to us. We have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, use, modification and disclosure and to maintain data security, and correctly use the Personal Information collected through the Site. We take, or obligate applicable third parties to take, reasonable precautions to protect our users’ Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, no transmission of data over the Internet or any wireless network or stored and utilized for business purposes can be guaranteed to be 100% secure, and no security measures are perfect or impenetrable. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information we received, store or other utilize.  Therefore, we advise you that if you provide us with your information you do so at your own risk.

If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at legal@newnew.co.

11. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time, in whole or in part, at our discretion and without prior notice. In the event we make material changes to this Privacy Policy, such policy will be re-posted in the “Privacy” section of our Site with the date such modifications were made indicated on the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to this Privacy Policy. If you have any questions about the changes that were implemented, please contact us at legal@newnew.co and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Site after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Site or opt out by sending us an appropriate notice.

This Privacy Policy and each of its revisions is effective as of the date it is posted, which is indicated by the LAST MODIFIED date found at the bottom of the policy.

12. How to Contact Us

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: legal@newnew.co.

Last Modified: July 20, 2022