PRIVACY POLICY
Last updated November 12, 2024
This privacy policy from the Manufacturer ("Company" "we" "us" or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
Data Controller: The Manufacturer, Newline Interactive, Inc., is the controller of any information processed in connection with this policy.
Questions or concerns?
We are committed to complying with applicable data protection laws. We reserve the right to change the provisions of this Policy periodically. You are encouraged to review this page periodically for the latest information on our privacy practices. Reading this privacy notice will also help you understand your privacy rights and choices.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with applicable laws. We may also process your information for other purposes with your consent. We process your information only when we have valid legal basis to do so.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties for service provision purposes only.
How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, we will promptly inform you by email in case that risky security incidents occurred.
What are your rights?
Depending on where you are located geographically, the applicable privacy laws may mean you have certain rights regarding your personal information.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us.
The term "personal information" refers to information that specifically identifies an individual (such as name, contact information, device information and other information which may be used to identify a natural person, both directly and/or indirectly). Anonymous, aggregated information is considered non-personal information for the purposes of this policy.
We may collect personal information that provided voluntarily by you, collected automatically when you use our Services, and obtained from third-party sources. Details regarding the categories and sources of information are provided below.
1.1 Information provided by you
1.1.1 Account Registration Information
To engage in the process of account registration, your ID and related account details will be collected, which includes email addresses, devices registered, organization's name and your region.
1.1.2 Administrator Information
You can invite new users and manage your group. Information provided about new users, such as email address, is collected by you.
1.1.3 Location Information
Your location information is collected when you log in and agree for region-specific services.
1.1.4 Other Information
If You contact our customer support team, the information provided during the interaction may be collected for quality assurance purposes. Telephone number is also convenient for our customer support team to contact You.
1.2 Information collected automatically
1.2.1 Usage information
Information about your activity on the Services, including log-in/log-out times, used features, usage patterns, and order details.
1.2.2 Device information
Information about the devices used to access the Services, including device identifiers, IP address, time zone, device type, operating system details, and more.
1.3 Information from other sources
You may alternate third parties (e.g. Google, Microsoft) to share information with us so that you may share your account of third parties with us for our account activation.
1.4 No special categories of information
We do not request or intend to collect any sensitive data (e.g., data on health, race, religion) and advises you to exercise caution when sharing such data of you or others within the System.
You are not required to provide the personal information that we have requested. However, if you reject, it may not be able to provide you with our Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with applicable laws. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal basis to do so under applicable laws. To process your information as described in this policy, we rely on the following legal bases involving consent, contractual necessity, legitimate interests, compliance with applicable laws and regulations.
3.1 Consent.
We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. For example, if you proactively click "Agree" before you register and sign up to NSP, you will be deemed to have read and agreed to the terms of privacy policy. You can withdraw your consent at any time.
3.2 Contractual necessity.
We may process your information for the fundamental and mutually understood purpose of the contract between you and us.
3.3 Legal interests.
We may process your information where we believe it is necessary to protect your legitimate interests or the legitimate interests of a third party, such as situations involving potential threats to the safety of any person.
3.4 Compliance with applicable laws and regulations.
We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party account details (i.e. Google or Microsoft logins). When you choose to do this, we will receive certain profile information about you from your third-party service provider. The profile information we receive may vary depending on the third-party service provider concerned, but will often include your name, email address, as well as other information you choose to make public on such a third-party service platform.
We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party service provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
6. 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 policy unless otherwise required by applicable laws.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by relevant applicable law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, 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.
7. HOW DO WE TRANSFER YOUR PERSONAL INFORMATION BETWEEN COUNTRIES?
In short: Your personal information collected by us will be stored at the United States. To provide you with our Services globally, your personal information may be transferred or accessed by entities from various countries. We comply with applicable laws and regulations on the transfer of personal information between countries to safeguard your personal information.
To facilitate the System's operation, assist to fix technical issues that you report, or under other reasonable circumstances, our team may have access to your personal information incidentally. We will comply with related applicable laws and regulations and undertake corresponding protection and safeguarding measures.
If transferred personal information is collected in the European Economic Area, the Standard Contractual Clauses from the European Commission will be applied to.
8. 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 and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 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. In case of security incidents involving personal data, you will be promptly notified by email.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from children under 18 years of age.
We do not knowingly solicit data from 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.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: As the subject of personal information, you are entitled to exercise your rights under applicable laws. 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.
We will consider and act upon any request in accordance with applicable data protection laws.
10.1 Right to be informed: You may be informed about how we will process your personal information through this policy.
10.2 Right to access personal information: You may access your personal information held by us.
10.3 Right to correct personal information: You may correct inaccurate personal information through your NSP account settings or by contacting our support team.
10.4 Right to delete personal information: You may request deletion of your account or specific personal information, subject to legal requirements. There may be situations where we cannot grant your request -- for example, if you ask us to delete your transaction data and we are legally obligated to keep a record of that transaction to comply with laws. We may also decline to grant a request while doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical or unreasonable.
10.5 Right to restrict processing: You may request us to stop processing your personal information in certain circumstances.
10.6 Right to information portability: You may request a copy of your information in a machine-readable format for transfer to another provider, where applicable.
10.7 Right to object: You may object to certain processing of your personal information, including marketing activities.
10.8 Right to withdraw consent: You may withdraw consent for the processing of your personal information, subject to legal consequences and service limitations. But this will not affect the lawfulness of the processing before its withdrawal nor, when applicable laws allow, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
10.9 Right to refuse automated decisions: You may refuse automated decisions, including user's profiling.
10.10 Right to lodge complaints: You may lodge complaints with relevant authorities or contact our support team for resolution.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.
14. HOW CAN YOU CONTACT US?
For any inquiries or concerns regarding this policy, you can contact us via info@newline-interactive.com.
15. SPECIAL TERM FOR UNITED STATES
If you are a California resident, and the California Consumer Privacy Act ("CCPA") does not apply an exemption to you and your personal information, you or your authorized agent are entitled to make requests under CCPA to:
We did not and will not "sell" or "share" your personal information as defined in the CCPA. Therefore, the organism to opt out from selling or sharing is not able to be exercised.