Effective Date: January 15, 2019
New Context Services, Inc.

New Context Services, Inc. (New Context, Company, we, us) is a Lean Security company incorporated in Delaware and operating in the United States that offers DevOps Services, Product Development and Cyber Threat Integration Services to corporations as well as Security Software to individuals.

New Context is subject to the regulatory and enforcement authority of the US Federal Trade Commission.

Scope
This privacy policy applies to personal information and other information New Context collects from or about the users of the New Context websites, services and applications, and other interactions (e.g., customer services inquiries, etc.). Unless otherwise noted herein, this privacy policy does not apply to any other services or products or to information collected in any other way (whether offline or online) or for any other purposes.

Personal Information of New Context’s Customers
When providing services on behalf of our corporate customers New Context receives information under the direction of its customers and acts as a data processor. We have no direct relationship with any individuals whose personal data we process on behalf of our customers. Furthermore, as the data controller, the customer themselves retains responsibility over any information we handle. Each relationship we have with our customers is unique to that entity and their needs. As such the services New Context provides to its customers will in some instances require us to process personal information about its clients or their employees (‘client information’) on their behalf. The range of personal data we may handle in this context consists of, but may not be limited to, basic contact data (first and last name, email, company and department, phone number, etc.)

If you are a client or employee of one of New Context’s customers and would no longer like to be contacted by that entity, or for details of how the client information will be used and protected, and details of how to access or correct the information, please refer to the privacy statement of the New Context customer to which you submitted your personal information. New Context may be required to transfer personal information to companies at the request of our corporate customer. Transfers to these subsequent third parties are covered by existing service agreements with New Context’s customers. New Context does not directly utilize third parties to complete its business relationship with any corporate customer.

If New Context receives an individual’s direct request to access their data, we are obliged to refer that request to our client who remains the data controller.

New Context retains personal data processed on behalf of its customers for as long as is needed to provide services to its customers at their instruction. New Context may also retain this personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

Personal Information of New Context’s Corporate Customers and Direct Users
New Context may receive personal data from corporate representatives wishing to explore opportunities on behalf of their companies. Likewise, we also provide a suite of direct to consumer software, which can be purchased by individuals. In these situations, we act as a data controller for that information. The range of data we collect under these circumstances can contain, but not be limited to basic contact data (first and last name, email, company and department, phone number, etc.)

Sharing Personal information Across Country Borders
New Context does not share data with non-agent third parties or allow it to be used for any reason other than that for which it was originally provided. If this practice should change in the future, we will update this policy to identify those third parties and/or actions and illustrate how individuals can provide opt-out choice prior to their data being shared or used.
New Context may disclose your personal information across country borders:

    • to any New Context affiliates as required;
    • to comply with the law or in response to a court order, subpoena, law enforcement or government request, or other legal process;
    • to produce relevant documents or information in connection with mediation, adjudication, litigation, arbitration, government or internal investigations, or other legal or administrative proceedings;
    • if New Context determines in its good faith judgment that disclosure is necessary to provide its services or to protect the rights, interests, safety, or property of its business, suppliers, customers, employees, or others;
    • in connection with any actual or proposed sale or transfer of some or all assets of New Context, and/or any actual or proposed sale or merger of New Context or any division of New Context;
    • to enforce the terms of any agreement with New Context;
    • to combat suspected or actual fraud or other criminal activity;
    • for any other purpose as disclosed by New Context when you provide the information;
    • as otherwise required or permitted by law; and/or with your consent.

Unless permitted by relevant laws, New Context will not share, sell, trade, or lease your personal information to or with others except as provided for in this privacy policy.

Marketing Choices, The Right to Access Your Personal Information, and Retention For Individuals Utilizing Our Software and Direct Corporate Contacts
Marketing Choices: Your decision to provide the personal information that New Context may request from time to time is voluntary. However, if you do not provide the personal information requested, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested. You always have the option of unsubscribing or choosing not to receive promotional materials from New Context by following the specific instructions in the email or other communication you receive, or by notifying New Context via the appropriate method(s) described below. It may take a reasonable period of time to process your request, but should be no longer than 10 business days for email promotions. In countries where New Context is required to do so by law, New Context will offer you the opportunity to provide specific opt-in consent before promotional materials are sent, or promotional calls are made, to you. This will not apply to service communications that are considered a required part of certain services, which you may receive periodically unless you specifically cancel the applicable services.

How New Context Uses Collected Information
New Context may use the personal and other information it collects from you in various ways including in connection with: providing services and support to you; billing you for services; verifying your identity; carrying out its required obligations and enforcing its rights arising from any contracts entered into between you and New Context; communicating information about New Context websites, services, and applications, as well as any other necessary interactions (e.g., customer service inquiries, etc.); improving its websites, services and applications, and other interactions (e.g., customer service inquiries, etc.); contacting you to complete surveys that New Context uses for marketing or quality assurance purposes; sending you promotional information; complying with services offering obligations as well as in any other way New Context describes when you provide information; combating fraud, crime and as otherwise required or permitted by law; and for any other purpose with your consent.

To assist New Context with the uses described in this privacy policy, information New Context has collected from or about you through New Context websites, services and applications, and other interactions (e.g., customer service inquiries, etc.), including about your use thereof, may be combined with or enhanced by other information from or about you that New Context has obtained from other sources, including those from its business partners or service providers.

New Context does not use, rent or sell personal information for uses other than those for which it was originally provided.

Access to Your Personal Information: New Context strives to keep your personal information accurate. New Context has implemented technology, management processes, and policies designed to maintain data integrity (see Security of Your Personal Information below). New Context will provide you with reasonable access to your personal information in accordance with relevant laws, including by making reasonable efforts to provide you with online access and the opportunity to update your information. To ensure that New Context protects your privacy and security, New Context will take steps to verify your identity before granting access or making changes to your personal information. Upon request (see the Privacy Complaints and Dispute Resolution section below for how to make requests), New Context will provide you with information about whether New Context holds any of your personal information. To request access, correction, or deletion or transfer of your personal information, please follow the applicable instructions below. While New Context will make reasonable efforts to accommodate your request, it also reserves the right to reject such requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law. New Context will respond to your request within a reasonable time frame.

Retention of your information: New Context will retain your personal information for as long as your account is active or as needed to provide you with the New Context websites, services and mobile applications. If you wish to cancel your account, or request that New Context no longer use your personal information to provide you services or software, contact New Context via the applicable methods provided below. Even after New Context cancels your account or ceases using your personal information to provide you services or software, New Context may still retain, use, and disclose your information as necessary to comply with its legal, regulatory, ethical, or document retention obligations, and any request to delete your personal information is subject to these obligations and restrictions.

Security of Your Personal Information
New Context has implemented best-practice administrative, technical, and physical measures designed to protect your personal information from accidental loss as well as from unauthorized access, disclosure, use, alteration, or destruction. These measures include computer safeguards and secured files and buildings, Internet firewalls, intrusion detection, anti-virus protection, network monitoring, and, where appropriate and required by applicable law, Transport Layer Security (ìTLSî) or similarly encrypted browsers. Please note that, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure, and you understand that New Context cannot and does not ensure or warrant the privacy or security of any information it collects from or about you, and that you use the New Context websites and provide New Context with information at your own risk. If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential and secure. Please also be careful to avoid common ‘phishing’ scams, where an email may be sent to you that looks like it is from New Context asking for your personal information. New Context will never under any circumstances request your personal information through email. If you have further questions about the security measures that New Context takes to secure and protect your personal information, please contact New Context as described below.

Collection of Information Using Cookies and Other Tools
New Context may collect and/or log your Internet Protocol address, Internet domain name, the web browser type and operating system used to access New Context websites, services, its mobile applications or other interactions (e.g., customer service inquiries, etc.), the files visited, the time spent in each file, and the time and date of each visit or clickstream data. New Context may collect this information automatically as you browse its websites via the use of log files and web beacons to analyze trends in the aggregate and administer the New Context websites and services. New Context and its partners use cookies or similar technologies to analyze trends, administer websites, track usersí movements around websites, and to gather general demographic information about its user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on its websites or service.

New Context may also use cookies and other electronic tools placed by a third-party service provider to measure the effectiveness of its advertising and other information and help it understand what product information is of most interest to its customers and what kinds of advertising offers its customers like to see. Although the service provider logs the information coming from New Context websites or services on its behalf, New Context controls how that data may or may not be used. You can directly control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on its websites or service.

If you wish to opt out of interest-based advertising, please contact New Context at privacy@newcontext.com or follow the specific opt-out instructions in the email.

New Context uses analytics software to allow it to better understand the functionality of its mobile applications on your phone. This software may record information such as how often you access the application, the specific events that occur within the application, aggregated usage statistics, performance data, and where the application was downloaded from. Please note that New Context does not link the information it stores within the analytics software to any personal information you submit within the mobile application.

New Context websites Cookies Policy
New Context (“us’, “we”, or “our”) uses cookies on the newcontext.com websites (the “Service”). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how New Context uses cookies, how third-parties it may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies
Cookies are small pieces of text sent to your web browser by a websites you visit. A cookie file is stored in your web browser and allows the service or a third-party to recognize you and make your next visit easier and the service more useful to you.

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.

How New Context uses cookies
When you use and access the Service, New Context may place a number of cookies files in your web browser.

New Context uses cookies for the following purposes:

      • To enable certain functions of the Service
      • To provide analytics

New Context uses both session and persistent cookies on the service and it uses different types of cookies to run the Service:

      • Essential cookies: New Context may use cookies to remember information that changes the way the service behaves or looks, such as a user’s language preference on the Service.
      • Analytics cookies: New Context may use analytics cookies to track information how the service is used so that it can make improvements. New Context may also use analytics cookies to test new advertisements, pages, features or new functionality of the service to see how its users react to them.
      • Third-party cookies: In addition to its own cookies, New Context may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies?
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features New Context offers, you may not be able to store your preferences, and some of New Context’s pages might not display properly.

Where you can find more information about cookies
You can learn more about cookies at the following third-party websites:

Change of Ownership
In the event of change in ownership, or a direct merger or acquisition with another entity, New Context reserves the right to transfer all of the New Context user information, including personal data, to that entity. New Context will use commercially reasonable efforts to notify you (by posting on its websites or issuing an email to the address you provided when you registered) of any change of ownership; merger or acquisition of New Context by a third party, and you may request to modify any of your registration information at that time.

EU-US Privacy Shield (For EU Personal Data Transferred into the United States)
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 transferred to the United States pursuant to Privacy Shield. New Context has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under 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/

Pursuant to the Privacy Shield the following statements and/or principles apply:

  • We acknowledge the right of EU individuals to access their personal data. Individuals wishing to exercise this right may do so by sending a request to New Context as outlined below under Privacy Complaints and Dispute Resolution.
  • We may be required to release EU personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
  • We remain liable for the onward transfer of personal data to agent third parties unless we can prove we were not a party to the actions giving rise to the damages.

Privacy Complaints and Dispute Resolution
In compliance with the Privacy Shield principles, New Context commits to resolve complaints about its collection or use of your personal information. EU individuals with inquiries or complaints regarding New Contextís Privacy Shield policy should contact New Context by:

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 New Context, or if New Context has not addressed your complaint to your satisfaction, 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.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at:
https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Your California Privacy Rights
If you are a California resident, California Civil Code ß1798.83 permits you to request information regarding the disclosure of your personal information by New Context to its affiliates and/or third parties for their direct marketing purposes, within the past year. To make such a request, contact New Context as set forth above.

Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. New Context will post any revised policy on its websites.
Information Subject to Other Policies
New Context 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 New Context that may differ in some respects from the general policies set forth in this privacy policy.