Privacy Policy

New Signature Website Privacy Policy 

Last Updated on April 25,2018

New Signature Inc. and its subsidiaries (“New Signature“, “we“, “us” and “our“) respect your privacy. This privacy policy describes how we collect and use personal information relating to you, or that you provide to us:

(i) when you visit or use:

  • New Signature’s website at newsignature.com (the “Website”);
  • any of our computer or mobile software applications (“Apps”);
  • our social media pages; and
  • any of the services accessible through the Website (the Services); and

(ii) through offline sales and marketing activities.

For the purposes of this privacy policy, all references to the Website shall include a reference to the Apps.

Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to understand our practices regarding personal information.

By visiting the Website, downloading an App, accessing one of our social media pages and/or using the Services, you are accepting the practices described in this policy.

If you live in the US or outside of the European Union (“EU”), the data controller (the company that is responsible for the information relating to you) is New Signature, Inc., 901 K Street NW, Suite 450, Washington, DC 20001, USA. If you live in the EU, the data controller is New Signature UK Limited, a company incorporated in England and Wales under company number 04972823, and having its office at 57 Bermondsey Street, London SE1 3XJ.

  1. What personal information do we collect?

The type of information we collect from you will depend upon the type of interaction you have with us.

Broadly speaking, the types of personal information that we collect may include:

  • if you are a customer of New Signature: your full name, email address, postal address, telephone number, and the details of the transactions which you conduct using the Services;
  • if you are a job applicant, employee or contractor: your full name, contact details (including address, phone number and email address), identification details, job title, employment history and education details, names and contact details of referees, next of kin details, national insurance number or other information if required by law;
  • personal information that you provide by completing forms on the Website, including if you sign up to receive our communications or attend one of our training or other events, if you request a trial of a product or service, if you search for a product or service, or if you request any other information;
  • if you register or create an account with us, your log-in and password details;
  • information contained in messages when you post on our social media accounts;
  • information contained in communications you send to us, for example when you report a problem or submit queries, concerns or comments regarding the Website or its content; and
  • data from surveys that we may, from time to time, run on the Website for research purposes, if you choose to respond to, or participate in, them.

You are under no obligation to provide any such data. However, if you choose to withhold requested information, you may not be able to access all of the contents and services available on the Website.

We also collect information automatically when you use the Website and when you navigate through the Website.  Information collected automatically may include usage details, geo-location data, IP addresses and information collected through cookies, and other tracking technologies (which may not be information which identifies you).  For more information on our use of these technologies, see our Cookie Policy.

New Signature may also collect personal information relating to you from third parties. This may include (but is not limited to) the collection of personal information relating to you from:

  • our partners;
  • our customer support service provider, when you make a customer service inquiry;
  • someone you duly authorise to act on your behalf; and
  • recruiters we have retained and from referees you have provided in support of a job application.
  1. How do we use personal information relating to you?

 We use personal information relating to you that we collect, or that you provide to us, for the purposes of our legitimate interests as follows:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about, where you have consented to be contacted for such purposes;
  • to ensure that content from this Website is presented in the most effective manner for you and for your computer;
  • to administer this Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve this Website to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our Services, when you choose to do so;
  • to liaise with partners in connection with your use of the Services;
  • to deal with enquiries or complaints;
  • as part of our efforts to keep this Website safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to conduct our internal business and management processes, for example accounting or auditing purposes; and
  • for any other purposes that you would reasonably expect.

We may combine this data with personal information you give to us and personal information we collect that relates to you. We may use this personal information and the combined data for the purposes set out above (depending on the type of data we receive).

You have the right to object to this processing if you wish, and if you wish to do so, please send an email to or write to us using the contact details set out at the end of this policy.  Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit. 

  1. Do we share your personal information with any third parties?

We may disclose personal information relating to you to third parties in certain circumstances including (but not limited to) the following:

  • other companies within our group who may be involved in providing products and services to you, and who may use personal information relating to you in any manner set out above;
  • other third parties that we or our group companies engage to help us run our business – such as our customer support service provider; payment processors; contractors; couriers; pay roll service providers; debt collection agencies and other parties that assist with debt-recovery functions;
  • analytics and search engine service providers that assist us in the improvement and optimisation of this Website;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you; and
  • our professional advisors, including lawyers, accountants, tax advisors and auditors;
  • law enforcement bodies, Courts of law or as otherwise required or authorised by law; and
  • regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies;

We may also disclose personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
  • if we restructure our business, or if integrate our business with another group of companies, in which case personal information held by us will be disclosed to the new owner to be used in the same ways set out in this policy;
  • if we are under a duty to disclose or share personal information relating to you in order to comply with any legal obligation, or in order to enforce or apply the terms and conditions on which we supply products and/or services to you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • for any other purposes that you would reasonably expect.

Before New Signature discloses any personal information to a third party, we take steps to ensure that the third party will protect personal information in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

  1. How do we protect your personal information?

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal information relating to you, we cannot guarantee the security of such data transmitted to the Website; any transmission is at your own risk. Once we have received personal information relating to you, we use strict procedures and security features to try to prevent unauthorised access.

All information you provide to New Signature is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted industry-standard encryption technologies when transferring or receiving personal information, such as SSL technology. The safety and security of your information and any personal information relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website and/or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

New Signature takes steps to destroy or de-identify personal information when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information. 

  1. Where do we store personal information?

If you live in the EU, the personal information relating to you that we collect may be transferred to, and stored at, locations outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

As described in this privacy policy, we may also share personal information relating to you with other companies within our group or with third parties who are located overseas, for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services.

Countries where personal information relating to you may be stored and/or processed, or where recipients of personal information relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence.  By submitting your personal information, you accept that personal information relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. 

  1. Thirdparty links

Although this Website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout this Website.

This Website may, from time to time, contain links to and from the websites of our partners and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

  1. Social Media Platforms

Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.

This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion – you should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these social media platforms.

  1. Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

  • Google Display Network Impression Reporting
  • Demographics and Interests Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.


Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on. 

  1. Additional provisions for US residents

California Online Privacy Protection Act (CalOPPA) 

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found on the page specified above.


You will be notified of any Privacy Policy changes:

  • On our Privacy Policy Page

Can change your personal information:

  • By emailing us

 

COPPA (Children Online Privacy Protection Act) 

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.

Fair Information Practices 

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email

  • Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act 

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

  • Follow the instructions at the bottom of each email.

and we will promptly remove you from ALL correspondence.

  1. Additional provisions for EU residents

If you reside in the EU, you have the right to access personal information held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We also want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate.

Requests in this section should be sent by email or by writing to us using the contact details set out at the end of this policy.

We will only send you marketing material if you consent. We will only send personal information relating to you to a third party for marketing purposes if you consent. When you have consented to marketing material, you have the right at any time to ask us not to process personal information relating to you for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the marketing emails we send to you.  You can also exercise the right at any time by sending an email or by writing to us using the contact details set out at the end of this policy.

If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.

  1. Changes to this policy

New Signature reviews and amends its privacy policy from time to time.  Any changes we make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this policy.  The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Website.

  1. Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

If you live in the US or outside of the EU : 

New Signature, Inc.

901 K Street NW,
Suite 450
Washington, DC
20001
USA
Email: marketing@newsignature.com
Tel: 202-452-5923

 

If you live in the EU:

New Signature UK Limited

57 Bermondsey Street
London SE1 3XJ
United Kingdom
Email: marketing@newsignature.com
Tel: +44 (0) 845-402-17