Newflow Partners Online Privacy Policy

Website Visitors

What Information Do We Collect?

Newflow and third parties working on our behalf collect personal information that you provide on this Website or on third parties’ websites as designated by Newflow that link to this privacy policy, such as through forms you choose to submit to contact us to obtain more information about or register for an event. Personal information may include, but is not limited to:

• Contact information and other identifiers (names, addresses, phone numbers, e-mail addresses, and other data you may provide us so that we can contact you).
• Internet activity information (“cookies,” web server logs, web beacons, and other electronic tools to collect statistical information about your use of this Website and other websites). For more information about how we collect and process such information, please see “Cookie Policy” below.

How Do We Use and Share Your Personal Information and Other Information?

Newflow and third parties working on our behalf use the information we have about you for internal business purposes, as well as to communicate with you, respond to your requests, enhance our services to you, compile aggregate statistics, and improve this Website. Newflow and third parties working on our behalf may also use your information to provide you with information about this Website and its services, and about Newflow. To assist us with our use and sharing of your information, information covered by this privacy policy, including information about your use of this Website, may be combined with or enhanced by other information that we have from other online or offline sources.

Newflow has a legitimate interest in using the information we collect for the purposes outlined above. Specifically, Newflow has a legitimate interest in ensuring that its website continues to function efficiently and effectively, and to enhance the functionality of its website in response to how visitors use the website and collects data to that end. When you submit contact information to receive our newsletters or other communications, we use that data to fulfill your request. We also have a legitimate interest in using data about the individuals who visit this website and the companies for which they work to cultivate business relationships that may benefit Newflow or our portfolio companies. For some processing activities, such as communicating with you about opportunities to learn from or work with Newflow, we seek your consent to process that data.

We may also share your information with third parties as permitted or required by law, including: (a) with service providers that assist in operating our business; (b) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (c) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (d) to protect the interests, rights, safety, or property of Newflow or others; (e) to enforce any terms of service or other legal disclosures on or related to this Website; (f) in connection with a sale or other transfer of all or some of the assets of Newflow and/or in connection with a sale or merger of Newflow or any division of Newflow; (g) to provide you with the services or products requested by you, and to perform other activities related to such services and products; (h) to operate Newflow’s systems properly; or (i) any other sharing with your consent.

We do not sell your information to third parties.

For Users of Newflow-Sponsored Surveys

You may have reached this policy because you are participating in a survey or assessment sponsored by Newflow on behalf of one of our portfolio companies (the “Service”), such as the HireSelect program sponsored by Newflow in collaboration with Criteria Corporation. Newflow is an equity investor in some of the companies that use the Service (the “Employers”), and we process information shared with us to, among other things, monitor and improve the performance and use of the Service. Please read this portion of the privacy policy carefully to understand what information Newflow collects, and how it uses and shares that information.

What Information Do We Collect?

• Contact information (including name, test-event ID, and email address);
• Test results (including score, report or other performance evaluation); and
• Other personal information you may provide as part of the employment application process.

In addition, if you live in the United States, we may also collect demographic or ethnicity information (“sensitive information”) to monitor compliance with applicable non-discrimination laws. You do not have to submit this sensitive information and, where you have submitted this information and given us consent to use the information, you may withdraw your consent at any time. If you wish to withdraw your consent, please contact us at info@Newflowpartners.com.

Note that we will not share with the Employers any of this sensitive information, except in anonymized and aggregated form. The Employer will never know if you do or do not submit this information, and your decision to provide the information or not, or to consent or not (or to withdraw consent) will play no role in any hiring decisions by the Employer.

How Do We Use and Share Your Personal Data?

Newflow and third-parties working on our behalf use the information collected via your use of the Service to:

• Monitor and improve the Service;
• Monitor compliance with applicable non-discrimination and anti-bias laws and requirements; and
• Communicate with you solely in connection with your use of the Service.

Newflow has a legitimate business interest in performing these limited processing activities to ensure that the Service continues to perform as expected by Newflow and the Employers. To the extent that certain processing activities, or the processing of certain data, requires us to seek your consent, we have done so — for example, with respect to the sensitive information mentioned above.

Newflow may also process or share your information in connection with a sale or other transfer of all or some of the assets of Newflow and/or in connection with a sale or merger of Newflow or any division of Newflow, or to operate Newflow’s systems properly. Newflow has a legitimate interest in such processing activities.

Lastly, Newflow may share your information with third parties as permitted or required by law, including: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) to protect the interests, rights, safety, or property of Newflow or others; or (d) to enforce any terms of service or other legal disclosures on or related to the test. To the extent any of this processing takes place, Newflow will only perform such processing to the extent necessary for compliance with applicable legal requirements.

Cookie Policy
As described above, Newflow, third parties working on our behalf, and our partners, including social networking sites, may also place, view, and/or use cookies, web server logs, web beacons, and other electronic tools to collect statistical information about your use of this Website and other websites. Such information may include your device’s IP address, browser type, operating system, computer platform, web pages viewed, the date and time of your visit, the links you click within this Website, the websites used prior to visiting this Website, and whether you have been to this Website before. Newflow or such third parties may use such information either on behalf of Newflow or for the other parties’ own purposes, including research and analysis, to enhance your experience with this Website, to provide you with certain functions on this Website, to create aggregate and anonymize information about usage of this Website and other websites, etc. Newflow may also combine such information with information we collect from other sources — such as company websites and social media — to identify potential opportunities for partnership with other companies. Newflow has a legitimate interest in cultivating and building the business-to-business relationships made possible by such data processing.

The collection, use, and disclosure of the information by third parties is governed by their own privacy policies and is not the responsibility of Newflow. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or how to disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. You may also opt out of our third party partners’ cookies by following the instructions provided by DAA AdChoices – http://optout.aboutads.info/#!/. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of this Website will not function properly.

Security
To protect your personal information from unauthorized access and use, we use reasonable administrative, technical, personnel, and physical measures. These measures include computer safeguards and secured files and buildings.

Links to Third-Party Websites

This Website may contain links to third-party websites, including social networking sites. Since we do not control third-party websites and are not responsible for any information you may provide while on such websites, we encourage you to read the privacy policies on those websites before providing any of your information on such websites.

Accessing and Updating Your Personal Information

To access, review, rectify, or delete your name, e-mail address, phone number, or physical address, or your business name, business e-mail address, business address, or business phone number Newflow has collected about you that is subject to this policy, please contact us at info@Newflowpartners.com. Please include the following information in all requests: first name, last name, and e-mail address. While Newflow will make reasonable efforts to fulfill your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

Consent to Transfer of Personal Information to Other Countries

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer of your personal information to various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information through this Website, you consent to such transfers and to the processing of your personal information in such countries for the purposes described in this privacy policy.

Your Rights to Under Certain Data Privacy Laws

European Union and United Kingdom Residents

If you are viewing this website from the European Union or United Kingdom, under the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA 18”) you have a number of rights with regard to your “personal data” (as defined in the GDPR or the DPA 18). For example, you have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing and (in certain circumstances) the right to data portability. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time; however, such withdrawal will not affect the lawfulness of the processing before your consent was withdrawn. You also have the right to lodge a complaint if you believe that we have not complied with the requirements of the GDPR or the DPA 18 regarding your personal data.

Likewise, if you are a resident of the Cayman Islands, the Cayman Islands’ Data Protection Law, 2017 provides you with certain rights as regards your personal information.

To learn more about these rights, make a request for your information, or to lodge a complaint with respect to your personal data, please contact us at info@Newflowpartners.com.

How we respond to Do Not Track signals

Some web browsers may give you the option to request that a website operator not track your information across its website or other websites using the browsers’ “Do Not Track” settings. At this time, we do not respond to “Do Not Track” browser settings or requests, and we will only use your information in a manner consistent with this Privacy Policy.

Modifications to this Privacy Policy

Newflow reserves the right to modify this privacy policy at any time by posting the revised version on this Website and updating the effective date. Such changes will be effective upon posting. We encourage you to check this Website frequently to see the current privacy policy in effect and any changes that have been made to it.

Questions Regarding this Privacy Policy

If you have additional questions regarding this privacy policy, please contact us at info@Newflowpartners.com.