Portfolio Company INTRODUCTION
New Tradition Holdings, LLC (together with its affiliates, “New Tradition”, the “Company,” “we,” “us,” or “our,”) is committed to safeguarding the privacy of your (“you,” “your,” or “users”) personal information. This Privacy Policy explains how we collect and process information when you visit www.newtradition.com and any other websites owned, controlled or operated by New Tradition that post this Privacy Policy (each, a “Website” and collectively, the “Websites”). Please read this Privacy Policy carefully to understand our policies and practices regarding such information. By using or accessing any Website, you signify your agreement to this Privacy Policy. If, for any reason, you do not consent to these practices, please do not use the Websites.
Users in certain jurisdictions, such as residents of a U.S. state with a comprehensive consumer privacy law, may have specific rights which are set forth in the YOUR RIGHTS, CHOICES AND OPT OUT section below.
Special assistance with the Websites is available for persons with disabilities. If you need assistance accessing a Website or reading this Privacy Policy, please email us at legal@newtradition.com.
INFORMATION COLLECTION
Our Websites collects information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”, also called “personal data” under some laws). We collect the following categories of personal information and have collected the following categories of personal information from individuals within the last twelve (12) months, for the following categories of purposes and from the following categories of sources, and Company shares personal information with the following categories of third parties:
| Category | Examples | Purposes for Which Such Information Was Collected in the Preceding 12 Months or Will be Used | Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12 Months or will be Collected | Categories of Third Parties With Whom the Websites Shares or Sells Personal Information |
| Identifiers |
|
As described below in HOW WE USE YOUR INFORMATION | From you directly
From third party platforms and data suppliers
|
As described below in DISCLOSURE OF YOUR INFORMATION |
| Internet or other electronic network activity information |
|
As described below in HOW WE USE YOUR INFORMATION | From you directly
From third parties who place pixels on our Websites or third party services
|
As described below in DISCLOSURE OF YOUR INFORMATION |
COOKIES
When you visit our Websites, certain browsing information is automatically collected through various means such as cookies and pixels through our Websites or in our emails. “Cookies” are pieces of information that may be placed on your device by a third party service for the purpose of facilitating and enhancing your communication and interaction with that service or delivering targeted advertisements. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, pixels, tags, etc.) on our Websites to analyze how you use our Websites and to enable us to enhance our Websites.
By way of example, we use Google Analytics on this Websites and other Google services in connection with our Websites. For information about Google Analytics please see “How Google uses information from sites or apps that use our services”, located at www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, please copy and paste https://tools.google.com/dlpage/gaoptout into your browser and download the Google Analytics opt-out browser add-on.
Based on your web browser, you may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Further information on cookies is available at www.allaboutcookies.org.
HOW WE USE YOUR INFORMATION
We use information that we collect from you:
- To deliver our Websites content and services to you and analyze usage
- To provide you with information that you request
- To market our products and services to you on this Website, through emails and on third party services (such as through advertisements placed on other websites)
- To carry out our obligations and enforce our rights
- In any other way we may describe when we collect the information from you
- For any other purpose with your consent.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information as described in this Privacy Policy or otherwise with your consent:
- To contractors, service providers, and other third parties we use to support our business and provide services to you at your request or pursuant to agreements we have entered into with you – but we only authorize such parties to use information we provide for the benefit of and as permitted by New Tradition
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company is among the assets transferred
- To companies within the same corporate family as Company
- To comply with any court order, law, or legal process, including to respond to any lawful government or regulatory request
- To enforce or apply our policies or investigate fraud
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our users, clients or others
LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES
On the Websites, we may share links to other websites that we think may be of interest to you, such as providers of various products and services. We do not endorse any other websites and providers by providing such links, and our privacy policy applies only to your use of our Websites. We are not responsible for the privacy policies of any websites and services we link to on our Websites, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.
DATA RETENTION
We will retain your information for as long as needed for us to manage and provide our services and for our business needs. Even if we delete some or all of your personal information, we may continue to retain and use de-identified or aggregate data previously collected.
YOUR RIGHTS, CHOICES AND OPT OUT
If you are a resident of California or another U.S. state that has privacy legislation that applies to both you and the Company (collectively, “Covered States”), you may have specific rights regarding your personal information under the California Consumer Privacy Act (“CCPA”) or similar laws in other U.S. states (collectively, “State Privacy Laws”). This section describes the rights that residents of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of a Covered State and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the State Privacy Laws.
The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.
In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:
- Right to know. You may have the right to know whether we process your personal information and to access such personal information. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal information. Users in some states may also have the right to obtain a list of the categories of third parties to which we have disclosed personal information.
- Right to data portability. You may have the right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.
- Right to delete. You may have the right to delete personal information that you have provided or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception as set forth in the State Privacy Laws.
- Right to correct. You may have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it.
- Right to opt out. You may have the right to opt out of the processing of your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or (iv) selling/sharing (as defined by the CCPA or another applicable State Privacy Law). As of the date set forth at the top of this Privacy Policy, we do not use personal information collected on this Websites for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or for “sales” or “shares” (as defined under the CCPA or any other applicable State Privacy Laws).
- Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you with a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
EXERCISING YOUR U.S. STATE PRIVACY RIGHTS
To exercise any of the rights described above, you may:
- Email us at legal@newtradition.com
- Complete a request form at www.newtradition.com/privacy-contactus/
- Contact us at (800) 709-4006
Only you, or a person or business entity that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. You may also make a request on behalf of your minor child. If you are an authorized agent or an adult acting on behalf of your minor child, please reach out by emailing to legal@newtradition.com so we can verify your authority.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. However, we will process opt-out requests without any additional verification, unless we suspect fraud. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed through technical means of matching your device or identifiers to the data we possess.
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
We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the State Privacy Laws may allow us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.
If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint to the extent required by State Privacy Laws.
SECURITY
Safeguarding your personal information is a top priority. We have implemented reasonable security measures designed to protect your data from unauthorized access, misuse, alteration, or disclosure. While we take extensive precautions to ensure the security of your information, it is important to note that no method of data transmission over the Internet or electronic storage is 100% secure. We are committed to ongoing improvements in our security practices to maintain the integrity and confidentiality of your personal information.
CHANGES TO OUR PRIVACY POLICY
We may change this Privacy Policy at our discretion at any time. If we do make any changes, such change will appear on this page of our Websites. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of the Websites following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy.
CHILDREN UNDER THE AGE OF 18
Our Websites are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under 13, please contact us at legal@newtradition.com.
UNITED STATES OF AMERICA / CROSS BORDER DATA TRANSFERS
By using the Websites, you authorize the export of personal information from your home jurisdiction to other countries and its storage and use as specified in this Privacy Policy, such as the United States of America. Information stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at legal@newtradition.com.