Personal Data is any information that enables us to identify you and that is related to an identified or identifiable natural person (also known as a “Data Subject”), such as a name, an address, an email address, a phone number, an identification number, location data, or an online identifier.

We may collect Personal Data from you and about you from a variety of sources. We strive to only collect Personal Data that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected. In addition, we strive to keep all Personal Data accurate, complete, and reliable for its intended need, and we only retain your Personal Data for as long as necessary to achieve the purpose(s) for which it was collected, as explained more fully in the section “How Long We Retain Your Personal Data”. Finally, we may, from time to time, provide you with supplemental information at the time we collect your Personal Data to address unique or situational collection needs.

Examples of the ways in which we collect your Personal Data include: 

Personal Data that We Collect Directly from You

We collect Personal Data directly from you in the following circumstances:

• When you use our websites or portals (collectively a “Site”), we will collect information about your use of the Site and any information that you submit through that Site.
• When you download white papers, reports, or other collateral, we may collect your name, contact information, job title, industry and location.
• When you access some of our premises (we may collect your name, contact details such as phone numbers and email address, the company you work for, biometric information, video and/or audio recordings of you at our premises).
• When we collect technical information in relation to delivery of our Solutions.
• When we onboard you as a client or representative of our client (we collect your name, business contact information, job title, the company you work for, financial and payment information (where applicable)).
• When you place an order for our Solutions or otherwise interact with us, you may be required to create an account.
• When we communicate with you (via email, chat, voice calls and/or self-service portal).
• When you interact with us (we may collect your name, contact details such as phone numbers and email address, the company you work for, user credentials, device details, and location).
• If you contact us with questions, requests, or complaints, we may collect Personal Data sufficient to answer your questions, address your requests, and/or handle your complaints. We may also require you to provide Personal Data to authenticate your identity in order to answer your questions, address your requests, and/or handle your complaints.

Special Categories of Personal Data We Collect About You

We only collect Special Categories of Personal Data about you in certain instances, such as:

• For access to some of our premises and/or connection to New Era Solutions, we may collect certain biometric information for which your consent would be required.

Special Categories of Personal Data includes information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation. We ask that you do not send or provide this information to us.

Personal Data that We Automatically Collect

We, and our Service Providers (defined below), automatically collect the following information about your use of our Site through cookies (see our Cookie Policy) and other technologies including:

• Your domain name
• Your browser type and operating system
• Web pages you view
• Links you click
• Language preferences
• Demographic information such as your marketing preferences
• Your IP address
• The length of time you visit or use our Sites; and the referring URL, or the webpage that led you to our Sites
• We may also collect your approximate location through collection of your IP address

Typically, we do not combine this information with other information that we have collected about you, including other Personal Data.

Personal Data that we Collect from Other Sources

We also collect Personal Data from other sources, as follows:

• New Era Subsidiaries and Business Units: We may collect information about you from our subsidiaries and business units.
• New Era 3rd Party Service Providers: We may collect information about you from our Service Providers where we have sub-contracted out parts of our Solutions; where we engage third party applications, services or products; or where we engage third parties to administer New Era internal business processes. For purposes of this Privacy Statement all such Service Providers and third parties are referred to as ‘Service Providers’.
• New Era Business Partners: We collect information about you from our Business Partners with whom we offer joint services to you.
• The Company You Work For: We may access information about you from the company you work for when we provide Solutions as specified in our agreed contract with you or the company you work for (‘contract’).

You have choices about certain information we collect. When you are asked to provide your Personal Data, you may decline to do so; but if you choose not to provide your Personal Data that is necessary for us to provide any aspect of our Solutions, you may not be able to use those Solutions.

Moreover, to the extent that Personal Data you share with us is not your own (because, for example, you are a representative of a New Era customer), you warrant that you have the right to provide such Personal Data, and you and the business with which you are associated shall be fully responsible for any liability arising from any such use of Personal Data, including indemnifying New Era from any such liability. If you share Personal Data with us that is not your own, you agree to inform your agents, employees, or any authorized personnel (e.g., contractors, partners, or authorized third parties) (i) that their Personal Data may be processed by us; and (ii) of their rights regarding the processing of their Personal Data in accordance with this Privacy Statement and applicable data privacy and protection law.

Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, which is not Personal Data. To the extent this data is stored or associated with your Personal Data, we will treat it as Personal Data; otherwise, it is not subject to this Privacy Statement.

When we use your Personal Data in connection with the purposes set out in this Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which your Personal Data was collected and our relationship with you: 

Your Consent. When you opt-in to receive our marketing and promotional materials, we process your Personal Data to send messages to you about us and the Solutions we offer. You can withdraw your consent at any time.

Performance of a Contract. We may use your Personal Data to enter into, or perform under, the agreement between us and you or the business with which you are associated.

Legitimate Interests. We may use your Personal Data for our legitimate interests, including:

• Improving our Solutions.
• Providing information about our Solutions.
• Preventing and detecting fraud; ensuring network and information security; for administrative and legal compliance purposes.
• For the purposes of recruitment, human resources management, managing our interactions with you, and record keeping in relation to recruiting and hiring; except where our interests are overridden by your interests or fundamental rights or freedoms which require the protection of personal data.

Compliance with Legal Obligations and Protection of Individuals. We may use your Personal Data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harm.

We may use your Personal Data for one or more of the following business purposes:

Performance of Contract and Pre-Contractual Activities. To provide Solutions to you as specified in our contract, including provisioning of Solutions and enabling the use of certain features; to support our relationship with you and the business with which you are associated, including customer or technical support services, and accounting and billing services; to report on the Solutions and resolution activities.

Business Process Management: To support certain internal processes to ensure protection of property and interests for both New Era and its customers, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments.

Research and Analytical Purposes: To improve how we deliver Solutions to you, including obtaining feedback from you about our products, services and solutions including through client satisfaction surveys; to analyze the use of our website or our online services by you in order to develop and enhance the Solutions we may provide to you and the business with which you are associated.

Recruitment: To identify and contact you throughout the recruitment process; enable our personnel to search our internal global talent databases to help us identify suitable candidates for new or current job vacancies; determine your suitability for current job opportunities with us; analyze our applicant pool in order to better understand who is applying for roles at New Era and how to attract top talent; record online interviews for review by recruiters and hiring managers if you expressly agree to being recorded; perform administrative functions (e.g. keeping records in relation to recruiting and hiring); check information provided by you, or third parties including qualifications and references; process your job application, and if successful, your details of your employment with us.

Marketing: To send marketing communications to you; provide you with current information about our products, services and solutions; provide you with a more personalized experience when you interact with us; enable you to subscribe to our newsletters and mailing lists; enable you to register for events, workshops and seminars hosted by us.

Communications: To enable you to contact us, and for us to respond to you.

We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):

• Our New Era Technology Subsidiaries and Business Units: We may share information about you with our subsidiaries and business units for the purposes of operating our business, delivering, analyzing, improving, securing, and customizing our Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.
• Authorized Personnel and Advisors: We may share information about you with authorized New Era personnel, agents and professional advisors of New Era including legal advisors, auditors, and consultants to New Era, where required.
• Our Service Providers: We may share information about you with our Service Providers where we have subcontracted out parts of our products, services and solutions; where we engage third party applications, services or products; or where we engage third parties to administer New Era internal business processes. Examples include processing of orders and credit card transactions, hosting websites, assisting with sales related efforts or post-sales support, and providing customer support.
• Our Business Partners: We may share information about you with our Business Partners with whom we jointly offer our Solutions with respect to providing additional technical assistance in resolving the issue logged.

We also may share Personal Data in the following circumstances:

• When you consent to the sharing of your Personal Data.
• In connection with the agreed terms of contract for the Solutions provided.
• In connection with, any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company and to our advisors and the advisors of the other company in such transactions.
• To protect the rights, property or safety of New Era Technology, its business partners, you, or others, or as otherwise required by applicable law.
• To respond to a request for information by a competent authority in accordance with, or required by any applicable law, regulation or legal process; or where necessary to comply with judicial proceedings, court orders or government orders.
• In an aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.
• For other legal reasons.

Any Service Providers or other parties with whom we share Personal Data are contractually required to implement appropriate physical, administrative and technical safeguards to protect Personal Data and are not permitted to use Personal Data for any purpose other than the purpose for which they are provided with or given access to Personal Data by us.

Considering the global reach of our business, we may transfer your Personal Data between our business units including locations where the data privacy legislation may differ from that in your country or jurisdiction. In addition, we may transfer your Personal Data to certain contracted service providers, as outlined in the section “How We Share Your Personal Data”, to a region where the data privacy legislation may differ from that in your country or jurisdiction.

When we transfer your Personal Data outside of the country from where it was originally collected to a third country or international organization, we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your Personal Data is protected.

We employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of your Personal Data. Those safeguards include: (i) the encryption of personal information where we deem appropriate; (ii) the deployment of technical safeguards; (iii) taking steps to ensure Personal Data is backed up and remains available in the event of a security incident; and (iv) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

However, no method of safeguarding information is completely secure. While we use measures designed to protect your Personal Data, we, unfortunately, cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit to us is or will be secure.

We retain your Personal Data for only as long as necessary to carry out the processing activities described in this Privacy Statement, including but not limited to: (i) to provide Solutions to you or to the business with which you are associated; (ii) to enter into or perform contracts with you or with the business with which you are associated; (iii) to comply with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies; and (iv) to protect our rights, property, or safety, and the rights, property, and safety of our customers, users, and other third parties.

You have rights under various data protection laws in various countries in relation to your Personal Data, but we offer them irrespective of your location.

We are committed to upholding your rights, including: 

• Right to be informed: you have a right to know what Personal Data we have about you, what we do with it, where we get it from, who we share it with, how long we keep it and why we need it.
• Right of access: you have the right to access your Personal Data and obtain a copy of your Personal Data from us.
• Right to rectification: you have the right to update inaccurate and/or incomplete Personal Data about you.
• Right to be forgotten: you have the right to have your Personal Data erased, deleted or destroyed.
• Right to data portability: you have the right to move, copy or transfer your Personal Data in a safe and secure way and reuse it for your own purposes.
• Right to withdraw consent: you have the right to withdraw consent at any time regarding the Use of your Personal Data or in relation to direct marketing activities.
• Right to restrict use: you have the right to limit the way we use your Personal Data.
• Right to object: you have the right to stop or prevent us from using your Personal Data. In particular, you can object to our use of your Personal Data for direct marketing or the sale of your Personal Data.
• Right to challenge automated decisions: you have the right to query and review decisions made about you using purely automated means (i.e. without human involvement or intervention).
• Right to complain: you have the right to make a complaint or raise a concern about how we use your Personal Data. Complaints may be made directly to us or a relevant Data Protection Authority.

Where required by applicable law, we will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging.

If you are a California resident, you have the right to request and obtain from us a list of what personal information we have disclosed to third parties for their own direct marketing purposes in the preceding calendar year, but please note that we do not disclose your Personal Data, protected under the law, to third parties for their own direct marketing purposes.

We respect your rights, and we will never discriminate or retaliate against you or the business with which you are associated as a result of your exercise of any right outlined in this Privacy Statement or afforded to you under applicable law.

In some instances, you may provide New Era Technology with consent to process your Personal Data such as where you have opted in to receiving direct marketing communications from us. You can change your consent preference at any time, and manage your communication preferences by:

• Selecting the option to ‘Unsubscribe’ included in our communications with you.
• Sending an email to privacy@neweratech.com

Once we have received and verified your opt-out request, we will comply with your request as soon as is reasonably practicable.

If you opt-out of receiving marketing related communications from us, we may still send you administrative messages or other required communications as part of your ongoing use of our products, services and solutions, which you are unable to opt-out of.

We do not provide your Personal Data to unaffiliated parties for their own direct marketing purposes or sell, rent, distribute or otherwise make Personal Data commercially available to any third party.

When you access our Site, we and our service providers use cookies (small text files containing a unique identification number which are placed on your PC, laptop, tablet or mobile phone) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects (flash cookies) and Local Storage (HTML 5). Please refer to our Cookie Policy for more information on:

• What cookies are.
• How we use cookies.
• How third parties we partner with may use cookies.
• Your choices regarding acceptance of cookies.

• Collection of Personal Information from Minors. Except as part of our New Era Technology DB Primary and SchoolPing Solutions, we do not knowingly collect Personal Data from children under the age of 16. By using our Solutions, you represent that you are 18 years of age or older.
• Links to Third-Party Websites and Applications. Our Site may provide links to the websites and/or applications of other parties. You may further interact with us through third party applications, owned and operated by the company you work for or other third parties such as LinkedIn, WhatsApp, Slack, Microsoft Teams, Facebook, Twitter, Google+, and other social media sites or applications. We are not responsible for and make no representations or warranties in relation to the security, privacy practices and content of these third-party websites and applications. Please ensure that you read the applicable privacy and cookie policies before sharing Personal Data on these websites applications. Your use of such websites and applications is at your own risk.
• Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations, or assets to a third party, whether by merger, acquisition or otherwise. We may disclose Personal Data we obtain from or about you to any potential or actual third-party acquirers, and it may be among the assets transferred.

We reserve the right to change the terms of this Privacy Statement at any time. If we do make changes, though, we will take steps to indicate that the Privacy Statement has been updated on this website.

To facilitate our compliance with applicable data privacy and protection laws, such as the UK and EU’s General Data Protection Regulation or the California Consumer Privacy Act, and to ensure strong and consistent support for our privacy practices within New Era globally, we have established a Privacy Office to manage privacy compliance for New Era and to coordinate support for our customers on privacy matters.

If you have any query or complaint about this Privacy Statement or our privacy practices, or if you wish to exercise any of your rights, you may contact us at any time using the following contact information: · Email: privacy@neweratech.com

If you wish to raise a complaint regarding our privacy practices, you have the right to do so by contacting your local supervisory authority.