privacy-policy 2017-01-30T23:27:11+00:00

January 30, 2017
New Context Services Inc.
Privacy Shield Compliant Privacy Policy:
New Context Services, Inc. “New Context” complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. New Context has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

New Context strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business. This Privacy Shield Policy sets forth the privacy principles that New Context follows with respect to transfers of personal information between member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area or EEA) and the United States. The US enforcement authority which has jurisdiction over New Context’s compliance with the Privacy Shield is the Federal Trade Commission.

Definitions
“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Disclosure to Law Enforcement
New Context may be required to disclose Personal Data, including the data you submit to us, with or without notice, in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

New Context and Its Affiliates
New Context is a United States based corporation, which also operates with several international affiliates. New Context may share some or all of your Personal Data with these, or future, affiliates. New Context requires all affiliates to honor its Privacy Policies, including the Privacy Shield Policy.

Change of Ownership
In the event of change in ownership, or a direct merger or acquisition with another entity, we reserve the right to transfer all of New Context User information, including Personal Data, to a separate entity. We will use commercially reasonable efforts to notify you (by posting on our website or issuing an e-mail to the e-mail address you provided when you registered) of any change of ownership; merger or acquisition of New Context by a third party, and you may choose to modify any of your registration information at that time.

Principles
New Context adheres to the Privacy Shield Principles:
1. Notice
New Context shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide the Individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which is was originally collected.
2. Choice
The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, New Context will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of their information to a non-agent third party or the use of their information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
3. Accountability for Onward Transfer
New Context will obtain assurances from its agents that they will safeguard personal information consistent with this Policy, by means of a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles. Where New Context has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, New Context will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, New Context is potentially liable.
4. Security
New Context shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. New Context has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. New Context cannot guarantee the security of Information on or transmitted via the Internet.
5. Data Integrity and Purpose Limitation
New Context shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, New Context shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
6. Access
Upon request, New Context will grant individuals reasonable access to personal information that it holds about them. In addition, New Context will take reasonable steps to correct, amend, or delete personal data. Individuals have a right to access their Personal Information data and may do so by contacting us at:

New Context Services, Inc.
Re: Privacy Shield
717 Market Street, Suite 200
San Francisco, CA 94103
contact@newcontext.com
www.newcontext.com

7. Recourse, Enforcement and Liability
New Context uses a self-assessment approach to maintain compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with these Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

Data and Purposes
New Context may collect personal data under Privacy Shield such as name, mailing or email address, and contact information for the purposes of maintaining a New Context website, sharing information through a newsletter, recruiting, and various sales and marketing tasks related to ongoing commercial business. New Context may disclose personal information third parties, e.g., business partners, clients, or vendors) for required commercial business purposes.

Dispute Resolution

In compliance with the Privacy Shield Principles, New Context commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact privacysheild@newcontext.com.

New Context Services, Inc.
Re: EU-US Privacy Shield
717 Market Street, Suite 200
San Francisco, CA 94103
contact@newcontext.com
www.newcontext.com

New Context has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit, please contact or visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of BBB EU PRIVACY SHIELD are provided at no cost to you.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. We will post any revised policy on this website.

Information Subject to Other Policies
The Company is committed to following the Principles for all Personal Information within the scope of the Privacy Shield Agreement. However, certain Information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.