PRIVACY POLICY
Our company (New Genesis Solutions) (“us”, “we”, or “our”) operates https://www.newgenesissolutions.org (the “Site” or “Website”). This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
Personal Information
In the course of offering and providing our products and services, it is common for us to receive personal information from and about our customers Generally speaking, personal information is any information that can be used, directly or indirectly, to identify, locate or contact someone. When ordering or registering on our Site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, company or other details to help you with your experience.
How We Collect Personal Information
Typically, we receive personal information directly from our clients or their customers in the course of performing our services.
We also collect personal information through our website (https://www.newgenesissolutions.org). For example, we collect information from you when you register on our site, subscribe to a newsletter, fill out a form, or enter information on our site. Our web servers may also collect information from visitors such as IP address, browser type and version, time zone setting, operating system and platform. Some web browsers allow the user to send “do-not-track” signals to websites, and our website respects those mechanisms.
Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website.
How We Use Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
-
To fulfill or meet the reason for which the information is provided.
-
To provide you with information, products or services that you request from us.
-
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
-
To improve our website and present its contents to you.
-
For testing, research, analysis and product development.
-
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
-
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Disclosure of Personal Information
We may disclose personal information we collect from you:
-
To our subsidiaries and affiliates.
-
To contractors, service providers, and other third parties we use to support our business.
-
To fulfill the purpose for which you provide it.
-
To a buyer or other successor in the event of a sale or transfer of some or all of our business or assets.
-
For any other purpose disclosed by us when you provide the information.
-
To comply with any court order, law or legal process, including responding to any government or regulatory request.
-
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
-
If we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others, or with your consent.
-
We do not sell or otherwise share personal information with third parties for direct marketing purposes.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to employees and contractors who need to know that information to provide services to you. We maintain physical, electronic, and procedural safeguards to limit access to your nonpublic personal information.
Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk.
Third-Party Providers
Some applications and services embedded within, or linked from, our website, such as maps and social media platforms, are controlled by third-party providers. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Statement does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.
Non-Personal Information
This Privacy Statement does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.
Changes to Our Privacy Statement
We will post any changes we make to this Privacy Statement on our website. If we make material changes to how we treat personal information we collect from you, we will notify you by email or through a notice on our website homepage. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Statement on our website to check for any changes.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its Website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
Users can visit our Site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website. Our privacy Policy can be found at the footer throughout the entire Site.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
-
On our Privacy Policy Page
Can change your personal information:
-
By calling us
-
By logging in to your account
Do Not Track
We honor “Do Not Track” (DNT) signals and cookies. We will not use advertising when a Do Not Track (DNT) browser mechanism is in place.
Third-party Behavioral Tracking
We do not allow third-party behavioral tracking.
COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
FAIR INFORMATION PRACTICES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
-
Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
-
Send information; respond to inquiries, and/or other requests or questions
-
Process orders and to send information and updates pertaining to orders.
-
Send you additional information related to your product and/or service
-
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
-
Not use false or misleading subjects or email addresses.
-
Identify the message as an advertisement in some reasonable way.
-
Include the physical address of our business or site headquarters.
-
Monitor third-party email marketing services for compliance, if one is used.
-
Honor opt-out/unsubscribe requests quickly.
-
Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails:
-
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This supplements the information contained in the Privacy Statement of New Genesis Solutions and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
---|---|---|
K. Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Never |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Job Application |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | Job Application |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Never |
G. Geolocation data. | Physical location or movements. | Never |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | Regularly |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Never |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Never |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Never |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Never |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | Regularly |
Personal information does not include:
-
Publicly available information from government records.
-
De-identified or aggregated consumer information.
-
Information excluded from the CCPA's scope.
We obtain the categories of personal information listed above from the following categories of sources:
-
Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
-
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
-
Directly and indirectly from activity on our website (https://www.newgenesissolutions.org). For example, from submissions through our website portal or website usage details collected automatically.
-
From third parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
-
To fulfill or meet the reason for which the information is provided.
-
To provide you with information, products or services that you request from us.
-
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
-
To improve our website and present its contents to you.
-
For testing, research, analysis and product development.
-
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
-
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
-
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
-
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
None
We disclose your personal information for a business purpose to the following categories of third parties:
-
Our affiliates.
-
Service providers.
-
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
-
The categories of personal information we collected about you.
-
The categories of sources for the personal information we collected about you.
-
Our business or commercial purpose for collecting or selling that personal information.
-
The categories of third parties with whom we share that personal information.
-
The specific pieces of personal information we collected about you (also called a data portability request).
-
If we sold or disclosed your personal information for a business purpose.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
-
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
-
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-
Debug products to identify and repair errors that impair existing intended functionality.
-
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
-
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
-
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
-
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
-
Comply with a legal obligation.
-
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
-
Calling us at (623-806-2651
-
Emailing us at Privacy@newgenesissolutions.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
-
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
-
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
-
Deny you goods or services.
-
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
-
Provide you a different level or quality of goods or services.
-
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
(623) 806-2650
New Genesis Solutions
Copyright 2018 New Genesis Solutions.
All Rights Reserved.