Privacy Policy

[New Company Name] generally records certain information regarding how you access the Site (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of "cookies" (a small data file placed on the hard drive of your computer) or other technologies or tools. This information helps us determine how much our visitors use parts of the Site and to do internal research on our users' demographics, interests and behavior to better understand and serve you. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of the Site. If we use such information at all, it will be on an aggregate basis, and we will not voluntarily disclose to third parties any information that could be used to identify you personally. Our Cookie Policy is available for your review on this Site.

Personal information is information about an individual, which may include first and last name, physical street address, e-mail address, telephone number, Social Security number, payment card information, birth date, employment history, veteran status, certain health related data, passport information and photographs or any other information that permits a specific individual to be contacted physically or online or otherwise personally identified, but does not include aggregated information that does not allow a person in possession of such information to identify you individually.

Please be assured that we will not collect personal information about you when you visit the Site, unless you choose to provide such information to us. If you voluntarily submit information to the Site, for example, in a request for general information, we are permitted to record and use any personal information for reasonable business purposes including, but not limited to, fulfilling your request.

To the extent that you provide us with any personal information through or in connection with the Site, we may use such information for [New Company Name's] business purposes but will not disclose any personal information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personal information to [New Company Name], you consent to [New Company Name's] use of such personal information for the purposes described in this Privacy Policy.

Except as described in this Privacy Policy or as required or allowed by applicable law and regulation, we will not use personal information for any incompatible purposes without providing a notice of how it will be used, and the relevant opt-out options that may apply.

Please be assured that we will not collect personal identifying information about you when you visit the Site, unless you choose to provide such information to us. Unless we request it, we ask that you not send us, or disclose, any sensitive personal information.

Subject to the relevant jurisdictional regulatory requirements, [New Company Name] may process sensitive personal information. [New Company Name] will only use and disclose sensitive personal information for the purpose for which it was originally collected.

We use both internal and external personnel and service providers to operate the Site and to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personal information you submit through the Site, but only for the purpose of performing their duties. These persons are contractually obligated not to use or disclose your personal information for any other purpose.

We will not provide your personal information to any other persons without your consent, except (a) as required by law or regulation or (b) if we are required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding. We can (and you authorize us to) disclose any such information in those circumstances.

[New Company Name] does not sell personal information or share for purposes of cross-context behavioral advertising. We only disclose it to our service providers, agents, or delegates, or for related, disclosed business purposes as allowed by law.

We use industry standard technology to protect the security of your information. We also employ different security techniques to protect your personal information from unauthorized access by users inside and outside of our organization. You should be aware, however, that "perfect security" does not exist anywhere on the Internet. Although we believe we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal information will never be disclosed in a manner inconsistent with this policy and make no representations or warranties regarding the sufficiency of our security measures.

We retain personal information for as long as needed or permitted for the purpose(s) for which it was obtained and the requirements of applicable law.

Other criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we are allowed to delete them); and/or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations; for example, to comply with our legal or regulatory obligations or our document retention policy, resolve disputes, enforce our agreements, and investigate or defend against potential legal claims).

If you are located in any of the aforementioned jurisdictions, you may have certain rights regarding the personal information we hold about you. These rights may include the right to; access, correct, delete, restrict, object to, opt-out or limit our use of, or receive a portable copy in a usable electronic format, of your personal information.

Please note that we may require additional information from you to verify your identity in order to honor your requests.

Subject to applicable law, you may also lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of EU/EEA data protection authorities is available here. California residents can register complaints with the California Office of the Attorney General.

We are located in the United States, and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.

We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take at our discretion include, for instance, entering into standard contractual clauses in connection with any onward transfers of personal information. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request by contacting [contact@newcompanyname].

To the extent that EU data protection laws apply to the processing of your personal information, or to the extent that you are a resident of the United Kingdom ("UK"), the European Union ("EU") or the European Economic Area ("EEA"), you have certain rights with respect to your personal information, as outlined below.

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact [contact@newcompanynamecom].

• Access: You have the right to ask for a copy of the personal information that we hold about you free of charge; however, we may charge a "reasonable fee," if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
• Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
• Deletion: If you think that we should not be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
• Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

If you believe that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

The California Consumer Privacy Act of 2018 (the "CCPA/CPRA"), as amended and expanded by the California Privacy Rights Act of 2020 (the "CPRA"), provides California residents with certain data rights regarding what we do with your personal information. If you are an individual who resides in California and whose personal data is collected and processed by [New Company Name], you may have the right to:

• Request that we disclose, free of charge, the categories and specifics of the personal information we collect about you, the sources from which the personal information was collected (and/or, if applicable, sell, share or otherwise disclose to a third party), and the business purposes for collecting your personal information.
• Request the correction of any inaccurate personal information maintained by us about you.
• Choose to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying goods and services.
• Choose to opt-out of the sale of your personal information. Currently, however, [New Company Name] does not sell your personal information.
• Request that we delete the personal information we have collected from you. Following our verification of the request, we will comply with the request and delete any or all the personal information in our possession that we collected from you and/or any or all such personal information in the possession of our service providers, unless otherwise restricted by law or regulation.

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

We may collect online recruiting information from individuals who visit our Site and are interested in pursuing job opportunities with [New Company Name]. To this end, our Site may provide you with the opportunity to review and apply for available positions listed in an online jobs database and provide assistance to individuals needing a disability reasonable accommodation.

If you choose to proceed and gain access to this database through our Site, you will be linked to a third-party website hosted and maintained by one or more of our service providers ("Online Recruiting Site"). The Online Recruiting Site will allow you to provide information (e.g., your CV, contact information and identification of [New Company Name] positions of interest) that will be shared with [New Company Name] and used to evaluate your eligibility for employment and contact you as appropriate. Please note that third party vendors may be responsible for operating the Online Recruiting Site, and their privacy practices may be different than [New Company Name]. We encourage you to review such privacy policies and terms of use posted on the Online Recruiting Site prior to submitting any Personal Information in connection with your employment application.

[New Company Name] does not knowingly collect or use any Personal Information from children under the age of 13 on the Site. We do not knowingly allow children to communicate with us or use any of our online services. If you are a parent and have become aware that your child has provided us with information, please contact us as provided below.

Job applicants residing in California are entitled to the full scope of rights under the CCPA/CPRA/CPRA. For additional information on the rights available to California residents, please see the above section on Consumer Rights under the CCPA/CPRA/CPRA.

For additional information about how we process and protect the personal information of prospective employees and job applicants please email [[email protected]].