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New Chapter, Inc.
Website Privacy Statement
Last updated April 9, 2020
New Chapter, Inc. (“New Chapter,” “our,” “us,” or “we”) is committed to protecting your privacy. This Privacy Statement describes how we process personal information relating to you, including the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights that you may have with respect to such information. This Privacy Statement applies to the personal information you provide us when you visit our website (www.newchapter.com), when you contact us, when you visit any of our business locations or facilities, or when you otherwise engage with us.
It is important that you read this Privacy Statement together with any other privacy statements or other notices we may provide to you on specific occasions when we are collecting or processing your personal information so that you are fully aware of how and why we are using your personal information. By using or accessing our website or other online services (collectively, “Sites”), contacting us, or otherwise providing us with personal information in person or online, you agree that we may process your personal information in the manner described in this Privacy Statement. If you do not agree with our policies and practices, your choice is not to visit the Sites or provide us with personal information.
1. Personal Information
For purposes of this Privacy Statement, the term “personal information” refers to any information, or a combination of pieces of information, that allow you to be identified, and that is subject to, or otherwise afforded protection under, an applicable data protection law, statute, or regulation. In accordance with applicable law, we may anonymize your personal information so that it can no longer be used to identify you. Such anonymized information is not considered personal information and is therefore not subject to this Privacy Statement.
2. The Personal Information We Collect
We may collect personal information from, or about, you under a broad range of circumstances. Generally, we collect the following types of information during our routine business operations:
- Identity data, such as your name, title, company/organization name, e-mail address, telephone and fax numbers and physical address (including street, city, state, postal code, and/or country). If you visit any of our business locations in person, we may require you to sign-in and provide your name, driver’s license number, or other information.
- Registration data, such as information provided by you when you register for an account to use our Sites, including user names and passwords.
- Business contact data, such as information related to other employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we may conduct, or possibly conduct, business activities.
- Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
- Transaction data, including inquiries about and orders for our products and services and details of payments to and from you, including purchase order history.
- Your feedback, including feedback from you about our Sites as well as our products and services generally.
- Usage data, including information about how you use our Sites, the pages you view, the number of bytes transferred during your visit to our Sites, the links you click, the materials you access, the date and time you access the Site, the website from which you linked to one of our Sites and other actions taken within the Sites. We may also collect usage data if you access our internet services at a New Chapter location or facility.
- Technical data, such as your Internet Protocol (IP) address, your browser type and capabilities and language and your operating system. For information about the cookies we use on our Sites, please refer to the section below on cookies and analytical tools. We may also collect technical data if you access our internet services at a New Chapter location or facility.
When you do not provide requested information, we may not be able to provide you the requested service or complete your transaction.
3. Our Use of Personal Information
We may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:
- Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on New Chapter products or services you have purchased or otherwise use, processing product orders, handling warranty claims, answering customer service requests, and facilitating the use of our Sites.
- Improving our Business. We may use your personal information to perform business analyses or for other purposes that help us to develop and improve the quality of our business, Sites, products and services (including new products and services), for example, by customizing our Sites to your particular preferences or interests. We may use your personal information to conduct research and analysis to help us analyze your purchasing preferences, identify the products and services that best meet your requirements and measure the effectiveness of the advertising we serve you. Where permitted by law, we may combine the information that we collect via our Sites with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this Privacy Statement.
- Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of products or services which may be of interest to you, and to otherwise communicate with you about offerings, events and news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us.
- Rewards Programs. We collect and use personal information to maintain and administer our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to offer unique rewards, track your program status, and to facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any Rewards Program, you may withdraw that consent at any time by contacting us using the contact details at the end of this Privacy Statement or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions.
- Enforcement and Protecting our Business. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our Sites, products, or facilities. We may use your personal information to administer and protect our business and our Sites, including troubleshooting, system maintenance, support, reporting and hosting of data. We may use your personal information to defend or protect our legal, regulatory, and business interests.
4. Our Disclosure of Personal Information
We may share your personal information with selected third parties in accordance with applicable law, including as set out below.
- Service Providers. We may share your personal information with other companies with whom we have contracted to provide services on our behalf, such as hosting websites, conducting surveys, processing transactions, supporting our financial incentive and marketing programs, analyzing our Site, and performing analyses to improve the quality of our business, Site, products and services. We may also disclose your personal information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. For example, the Company has retained Promotion Execution Partners to assist with managing our purchase orders and return processes, Smile.io to support our Rewards Programs, and ZenDesk to assist with our customer support program.
- Distributors and Business Partners. We may share your personal information with third parties that distribute our products to you and engage in similar routine business functions. For example, the Company uses Retention Science, HubSpot, Dynamics eShop, BigCommerce, nChannel, CoStrategix, and OrderGroove to support our e-commerce and marketing programs.
- Business Restructuring. Circumstances may arise where the Company decides to sell, buy, divest, merge or otherwise reorganize our business in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.
- Disclosure for Other Reasons. We may disclose personal information if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property or, in urgent circumstances, to protect the personal safety of any individual. We may share your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, and business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with the Company, or request information from, or otherwise engage with us, and such activities require the Company (in our reasonable judgment) to share your personal information with a service provider or other third party, you hereby direct the Company to intentionally disclose your personal information to the service provider or third party as described herein provided the service provider or third party does not, in its reasonable judgment, sell the personal information, unless that disclosure would be consistent with the law.
5. Our Data Retention Criteria
The period during which we store your personal information varies depending on the purpose for the processing. For example, we store personal information needed to provide you with products and services, to facilitate transactions you have requested, or to engage in marketing activities, in accordance with applicable law. In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Statement, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure, including implementation of such security measures as may be required by applicable law. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Sites over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a User ID and password to access the Sites, you are responsible for keeping those log-on credentials confidential and not revealing them to others. You must contact us immediately if you have to reason to believe that your User ID or password to our Site have been compromised.
7. Credit Card Information
8. Information Collected from Third Parties
In accordance with applicable law, we may collect personal information about you from third parties, such as social media websites/applications, which we may combine with the information we already hold about you in order to help us improve and customize our Sites to your preferences and for other purposes set forth in this Privacy Statement. We may also collect your business contact information from your employer or other third parties, which we will use to facilitate or otherwise engage in traditional business activities and similar administrative matters.
9. Data Localization
The information (including personal information) that New Chapter collects and processes is stored in the United States and Canada. If you are located outside of the United States or Canada, please be aware that information you provide to New Chapter will be transferred to the United States or Canada, and that the United States and Canada may not provide the same level of protections as the laws in your country. New Chapter does not participate in the Privacy Shield Frameworks. By continuing to provide us such information you hereby consent to your personal information being transferred to, and stored in, the United States and Canada.
Cookies are text files containing small amounts of information which are downloaded to your hard disk or to your browser’s memory when you visit one of our Sites. Cookies are useful because they help arrange the content and layout of our Sites and allow us to recognize those computers or other devices that have been to our Sites before. Cookies do many different jobs, such as allowing our Sites to remember your preference settings and helping us to enhance the usability and performance of our Sites and your experience using them. Our Sites also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited specific pages. We may also include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon. The type of cookie or similar technology that may be used on our Sites can be categorized as follows: strictly necessary, performance, functionality and profile and advertising.
- Strictly Necessary Cookies. These cookies are essential for basic functionalities of the Site, and they enable you to move around our Sites and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. Examples of strictly necessary cookies are a “shopping basket” cookie, which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout; an “authentication” cookie which allows and manages your login to the Site and identifies you after logging in for a single session; a “session” cookie that is required to carry out the data transmission and provide the Site to you; and, a “security” cookie that detects repeat failed login attempts or similar abuses of the Sites. These types of cookies are regularly stored only as long as required for their purpose.
- Performance Cookies. These cookies collect information about how you use our Sites, such as which pages you visit most often and if you get any error messages from certain pages. These cookies collect information that is used to improve how our Sites operate. Without these cookies we cannot learn how our Sites are performing and make relevant improvements that could better your browsing experience. Examples of performance cookies that our Sites use include cookies from Google Analytics (see further discussion below).
- Functionality and Profile Cookies. These cookies allow our Sites to store information that you provide, such as preferences, and to store technical information useful for your interactions with our Sites. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the Sites is relevant to you. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience. For example, we use a cookie to store your language preferences, which allows us to present you with product search results in the correct language.
- Advertising Cookies and Similar Technologies. These cookies or similar technologies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement as well as help to measure the effectiveness of the advertising campaign. These cookies may track your visits to other websites. Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests.
Setting your cookie preference
You can usually modify your browser settings to decline cookies at any time by modifying the settings of your browser to reject or disable cookies or by opting out of specific cookies through the opt-out options shared below. If you choose to decline cookies altogether, you may not be able to fully experience the features of the Sites that you visit.
Our use of web analytics
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our Site’s performance, marketing, and providing you with customized advertisements that could be of particular interest to you. In particular, we use tools and programs from the following sources:
- Google Analytics and Google Tag Manger. To see how you can opt-out of certain Google features and to better understand Google privacy practices, visit: Google Analytics Opt Out Link.
- Facebook. To find out more about the privacy settings by Facebook and the options to change them, please see Facebook Privacy Settings Link (you must be logged into your Facebook account).
- LinkedIn Ads and LinkedIn Analytics. You can opt out from LinkedIn targeting cookies by clicking on the following opt out link: Linkedin Opt Out Link.
You can find more information about cookies, behavioral advertising and online privacy at www.allaboutcookies.org.
11. Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to New Chapter if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon anyone’s data privacy rights or privileges.
You may have certain rights under applicable data protection laws with respect to personal information about you that is collected through the Sites or when you contact or otherwise engage with us. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law.
Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future.
California Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents may have additional data privacy rights, such as the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information. California residents have the right to know and access the categories or specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months; the categories of sources from which the personal information is collected; and, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold. California residents have the right to request the Company transfer, to the extent feasible, personal information in certain forms and formats. California residents have the right to request that we (and any applicable service provider) delete/erase your personal information under certain circumstances.
California residents have the right to opt-out of the sale of their personal information. The Company does not sell your personal information to third parties for profit. However, (as described above) we do use third party website analytical tools and features, marketing partners, and other service providers and such relationships may involve the disclosure of your personal information in a manner that constitutes a “sale” of personal information under the CCPA. We are currently in the process of establishing mechanisms to address this area of our business and we are waiting on final regulations to be published by the California government. However, please contact us if you have any questions or concerns related to our privacy practices. Our Site is not directed to, and should not be used by, minors under the age of sixteen (16) and therefore the Company does not knowingly “sell” (as defined by the CCPA) the personal information of minors under sixteen (16) years of age without affirmative authorization.
California residents have the right not to be subject to discrimination for asserting their rights under the CCPA. If you make, or an authorized agent on your behalf makes, any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required under the law before addressing your request. The Company may require you to match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces, or categories of, personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein.
Do Not Track. Some web browsers may transmit “do-not-track” signals to the Sites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Children’s Data. We do not knowingly collect information from children and do not target or direct our Sites to children. You are prohibited, without our prior written consent, from providing New Chapter with any personal information on children, unless such disclosure of personal information is necessary to facilitate an applicable business transaction or otherwise related to our services and the disclosure of such personal information will not violate any applicable data protection law, statute, or regulation. The meaning of “children” is subject to the laws and regulations in the jurisdiction in which you are located.
Persons with Disabilities. New Chapter strives to ensure that every person has access to information related to our products and services, including this Privacy Statement. Please contact us if you would like this Privacy Statement provided in an alternative format and we will seek to meet your needs.
12. Links to Third Party Website
Our Sites may contain links to third-party websites, products and services. We have no liability or responsibility for those websites, products and services, their policies, or their collection or other processing of your personal information. The practices of those third parties with respect to information collected through their websites, products or services is governed by their own privacy policies. We encourage you to learn about the privacy policies of those third parties.
13. Contact Us
If you have questions regarding this Privacy Statement or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us using the interactive form at https://www.newchapter.com/contact or by telephone at the following: 888 874 4461 (for consumer) or 800 543 7279 (for retailers).
14. Changes to this Privacy Statement
We may occasionally update this Privacy Statement. When we do, we will revise the “last updated” date at the top and bottom of the Privacy Statement and take such additional steps as may be required by law.
Last updated: April 9, 2020