Privacy Policy

Last updated: June 30, 2020

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the lawprotects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and DefinitionsInterpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions

shall have the same meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    Under GDPR (General Data Protection Regulation), You can be referred
    to as the Data Subject or as the User as you are the individual
    using the Service.

  • Company (referred
    to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to newData, 2000 Mallory Ln, Ste 182, Franklin.TN 37067

    For the purpose of the GDPR, the Company is the Data Controller.

  • Affiliate means an entity that controls, is controlled by or is under common
    control with a party, where “control” means ownership of 50% or
    more of the shares, equity interest or other securities entitled
    to vote for election of directors or other managing authority.

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Website refers to newData, accessible from

  • Service refers to the Website.

  • Country refers to: Tennessee, United States

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the
    Service or to assist the Company in analyzing how the Service is
    used. For the purpose of the GDPR, Service Providers are
    considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a User can
    log in or create an account to use the Service.

  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number,
    location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

    For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • DataController, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the
    purposes and means of the processing of Personal Data.

  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing
    internet users to control the tracking of their online activities across websites.

  • Business, for the purpose of the CCPA (California Consumer Privacy Act),
    refers to the Company as the legal entity that collects
    Consumers’ personal information and determines the purposes and
    means of the processing of Consumers’ personal information, or
    on behalf of which such information is collected and that alone,
    or jointly with others, determines the purposes and means of the
    processing of consumers’ personal information, that does
    business in the State of California.

  • Consumer,for the purpose of the CCPA (California Consumer Privacy Act),
    means a natural person who is a California resident. A resident,
    as defined in the law, includes (1) every individual who is in
    the USA for other than a temporary or transitory purpose, and
    (2) every individual who is domiciled in the USA who is outside
    the USA for a temporary or transitory purpose.

  • Sale, for the purpose of the CCPA (California Consumer Privacy Act),
    means selling, renting, releasing, disclosing, disseminating,
    making available, transferring, or otherwise communicating
    orally, in writing, or by electronic or other means, a
    Consumer’s Personal information to another business or a third
    party for monetary or other valuable consideration.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain
personally identifiable information that can be used to contact or
identify You. Personally identifiable information may include, but
is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address,State, Province, ZIP/Postal code, City

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol
address (e.g. IP address), browser type, browser version, the pages
of our Service that You visit, the time and date of Your visit, the
time spent on those pages, unique device identifiers and other
diagnostic data.

When you access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to,
the type of mobile device You use, Your mobile device unique ID, the
IP address of Your mobile device, Your mobile operating system, the
type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.

We may also collect information that Your browser sends whenever You
visit our Service or when You access the Service by or through a
mobile device.

TrackingTechnologies and Cookies

We use Cookies and similar tracking technologies to track the activity
on Our Service and store certain information. Tracking technologies
used are beacons, tags, and scripts to collect and track information
and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when
a Cookie is being sent. However, if You do not accept Cookies, You
may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain
on your personal computer or mobile device when You go offline,
while Session Cookies are deleted as soon as You close your web
browser. Learn more about cookies: All
About Cookies

We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services
    available through the Website and to enable You to use some of
    its features. They help to authenticate users and prevent
    fraudulent use of user accounts. Without these Cookies, the
    services that You have asked for cannot be provided, and We only
    use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type:Persistent Cookies

    Administered by: Us

    These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use
    the Website, such as remembering your login details or language
    preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

  • Tracking and Performance Cookies

    Type: Persistent Cookies

    Administered by: Third-Parties

    Purpose: These Cookies are used to track information about traffic to the
    Website and how users use the Website. The information gathered
    via these Cookies may directly or indirectly identify you as an
    individual visitor. This is because the information collected is
    typically linked to a pseudonymous identifier associated with
    the device you use to access the Website. We may also use these
    Cookies to test new advertisements, pages, features or new
    functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding
cookies, please visit our Cookies Policy or the Cookies section of
our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor
    the usage of our Service.
  • To manage Your Account: to manage Your
    registration as a user of the Service. The Personal Data You
    provide can give You access to different functionalities of the
    Service that are available to You as a registered user.
  • For the performance of a contract: the
    development, compliance and undertaking of the purchase contract
    for the products, items or services You have purchased or of any
    other contract with Us through the Service.
  • To contact You: To contact You by email,
    telephone calls, SMS, or other equivalent forms of electronic
    communication, such as a mobile application’s push notifications
    regarding updates or informative communications related to the
    functionalities, products or contracted services, including the
    security updates, when necessary or reasonable for their
  • To provide You with news, special offers
    and general information about other goods, services and events
    which we offer that are similar to those that you have already
    purchased or enquired about unless You have opted not to receive
    such information.
  • To manage Your requests: To attend and
    manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your
    personal information with Service Providers to monitor and analyze
    the use of our Service, for payment processing, to contact You.
  • For Business transfers: We may share or
    transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require
    those affiliates to honor this Privacy Policy. Affiliates include
    Our parent company and any other subsidiaries, joint venture
    partners or other companies that We control or that are under
    common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal
    information or otherwise interact in the public areas with other
    users, such information may be viewed by all users and may be
    publicly distributed outside. If You interact with other users or
    register through a Third-Party Social Media Service, Your contacts
    on the Third-Party Social Media Service may see Your name,
    profile, pictures and description of Your activity. Similarly,
    other users will be able to view descriptions of Your activity,
    communicate with You and view Your profile.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will
retain and use Your Personal Data to the extent necessary to comply
with our legal obligations (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes,
and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes.
Usage Data is generally retained for a shorter period of time,
except when this data is used to strengthen the security or to
improve the functionality of Our Service, or We are legally
obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s
operating offices and in any other places where the parties involved
in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of
Your state, province, country or other governmental jurisdiction
where the data protection laws may differ than those from Your

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your
data is treated securely and in accordance with this Privacy Policy
and no transfer of Your Personal Data will take place to an
organization or a country unless there are adequate controls in
place including the security of Your data and other personal

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your
Personal Data is transferred and becomes subject to a different
Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid
requests by public authorities (e.g. a court or a government

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief
that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that
no method of transmission over the Internet, or method of electronic
storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee
its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their
tasks on Our behalf and are obligated not to disclose or use it for
any other purpose.


We may use third-party Service providers to monitor and analyze the use
of our Service.

  • Google Analytics

    Google Analytics is a web analytics service offered by Google that
    tracks and reports website traffic. Google uses the data
    collected to track and monitor the use of our Service. This data
    is shared with other Google services. Google may use the
    collected data to contextualize and personalize the ads of its
    own advertising network.

    You can opt-out of having made your activity on the Service
    available to Google Analytics by installing the Google Analytics
    opt-out browser add-on. The add-on prevents the Google Analytics
    JavaScript (ga.js, analytics.js and dc.js) from sharing
    information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please
    visit the Google Privacy & Terms web page:

Email Marketing

We may use Your Personal Data to contact You with newsletters,
marketing or promotional materials and other information that may be
of interest to You. You may opt-out of receiving any, or all, of
these communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails
to You.

  • Sendinblue

    For more information on the privacy practices of Sendinblue, please
    visit their Privacy policy:


We may provide paid products and/or services within the Service. In
that case, we may use third-party services for payment processing
(e.g. payment processors).

We will not store or collect Your payment card details. That
information is provided directly to Our third-party payment
processors whose use of Your personal information is governed by
their Privacy Policy. These payment processors adhere to the
standards set by PCI-DSS as managed by the PCI Security Standards
Council, which is a joint effort of brands like Visa, Mastercard,
American Express and Discover. PCI-DSS requirements help ensure the
secure handling of payment information.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement
of our Service.

  • Invisible reCAPTCHA

    We use an invisible captcha service named reCAPTCHA. reCAPTCHA is
    operated by Google.

    The reCAPTCHA service may collect information from You and from Your
    Device for security purposes.

    The information gathered by reCAPTCHA is held in accordance with the
    Privacy Policy of Google:

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or
    more specific purposes.
  • Performance
    of a contract:
    Provision of Personal
    Data is necessary for the performance of an agreement with You
    and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data
    is necessary for compliance with a legal obligation to which the
    Company is subject.
  • Vital interests: Processing Personal Data
    is necessary in order to protect Your vital interests or of
    another natural person.
  • Public interests: Processing Personal Data
    is related to a task that is carried out in the public interest or
    in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data
    is necessary for the purposes of the legitimate interests pursued
    by the Company.

In any case, the Company will gladly help to clarify the specific legal
basis that applies to the processing, and in particular whether the
provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal
Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are
within the EU, to:

  • Request access to Your Personal Data. The
    right to access, update or delete the information We have on You.
    Whenever made possible, you can access, update or request deletion
    of Your Personal Data directly within Your account settings
    section. If you are unable to perform these actions yourself,
    please contact Us to assist You. This also enables You to receive
    a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You
    have the right to to have any incomplete or inaccurate information
    We hold about You corrected.
  • Object to processing of Your Personal Data. This
    right exists where We are relying on a legitimate interest as the
    legal basis for Our processing and there is something about Your
    particular situation, which makes You want to object to our
    processing of Your Personal Data on this ground. You also have the
    right to object where We are processing Your Personal Data for
    direct marketing purposes.
  • Request erasure of Your Personal Data. You
    have the right to ask Us to delete or remove Personal Data when
    there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We
    will provide to You, or to a third-party You have chosen, Your
    Personal Data in a structured, commonly used, machine-readable
    format. Please note that this right only applies to automated
    information which You initially provided consent for Us to use or
    where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to
    withdraw Your consent on using your Personal Data. If You withdraw
    Your consent, We may not be able to provide You with access to
    certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to
verify Your identity before responding to such requests. If You make
a request, We will try our best to respond to You as soon as

You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if
You are in the European Economic Area (EEA), please contact Your
local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
  • The right to say no to the sale of Personal Data. You
    also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
  • The right to know about Your Personal Data. You
    have the right to request and obtain from the Company information regarding the disclosure of the following:
    • The categories of Personal Data collected
    • The sources from which the Personal Data was collected
    • The business or commercial purpose for collecting or selling the Personal Data
    • Categories of third parties with whom We share Personal Data
    • The specific pieces of Personal Data we collected about You
  • The right to delete Personal Data. You
    also have the right to request the deletion of Your Personal Data
    that have been collected in the past 12 months.
  • The right not to be discriminated against. You
    have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
    • Denying goods or services to You
    • Charging different prices or
      rates for goods or services, including the use of discounts or
      other benefits or imposing penalties
    • Providing a different level
      or quality of goods or services to You
    • Suggesting that You will
      receive a different price or rate for goods or services or a
      different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are
a California resident, You can email or call us or visit our “Do Not
Sell My Personal Information” section or web page.

The Company will disclose and deliver the required information free of
charge within 45 days of receiving Your verifiable request. The time
period to provide the required information may be extended once by
an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we
partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as
defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.


You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

  • From Our “Cookie Consent” notice banner
  • Or from Our “CCPA Opt-out” notice banner
  • Or from Our “Do Not Sell My Personal Information” notice banner
  • Or from Our “Do Not Sell My Personal Information” link

The opt out will place a cookie on Your computer that is unique to the
browser You use to opt out. If you change browsers or delete the
cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that
are targeted to your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your
mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.
If You are visiting such websites, You can set Your preferences in
Your web browser to inform websites that You do not want to be
tracked. You can enable or disable DNT by visiting the preferences
or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light
law), California residents with an established business relationship
with us can request information once a year about sharing their
Personal Data with third parties for the third parties’ direct
marketing purposes.

If you’d like to request more information under the California Shine
the Light law, and if you are a California resident, You can contact
Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions
Code Section 22581)

California Business and Professions Code section 22581 allow California
residents under the age of 18 who are registered users of online
sites, services or applications to request and obtain removal of
content or information they have publicly posted.

To request removal of such data, and if you are a California resident,
You can contact Us using the contact information provided below, and
include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive
removal of content or information posted online and that the law may
not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by
Us. If You click on a third party link, You will be directed to that
third party’s site. We strongly advise You to review the Privacy
Policy of every site You visit.

We have no control over and assume no responsibility for the content,
privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You
of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our
Service, prior to the change becoming effective and update the “Last
updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are
posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact

Policy for newData

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