Privacy Policy

This privacy policy describes the personal data we collect, the purposes for which it is used, and your choices regarding its use.

Personal Data We Collect

We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Information That is Not Personal Data

We may create and use aggregated, de-identified, or anonymized data from personal data we collect for business purposes, such as service improvement and promotion, without sharing information that identifies you.

Tracking Tools, Interest Based Advertising And Opt-Out

NewTXT and our third-party providers use cookies and other tracking technologies (“Cookies”) on the Services to collect information. Detailed information about the Cookies used (including the purpose for using them), interest-based advertising, how to manage Cookies, and do-not-track signals, can be found in each NewTXT’s respective Cookie Policy, which is linked in the respective company’s privacy statement.

Why We Share Your Personal Data Amongst Company

NewTXT share your personal data amongst each other:

1. To co-market, co-promote and cross sell our Services to you.
2. To learn how you use and interact with our Services, for the purposes of improving our Services, including by gathering commercial data and internal analytics on those unique users that subscribe to all or more than one of our Services, and gathering internal analytics on how you engage with one Service when integrated on another Service.
3. To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services.
4. To allow users to sign up for and sign in to multiple Services across NewTXT at one time.
5. To respond to customer inquiries about our Services, including customer support requests.
6. To respond to data subject requests under applicable privacy laws.
7. To distribute and display your content, which may include your username, across one or more of our Services. “Your content”, for purposes of this paragraph, refers only to user generated content you post on our Services. For example, if you post a question or answer on coursehero.com, it may be distributed and displayed on another NewTXT Service, and may include your username.
8. To protect the rights, property or safety of you, NewTXT, or another party, including doing fraud protection, security and debugging.
9. To analyze a NewTXT’s IT and IT security infrastructure, to assess compliance with NewTXT security standards and data migration.

Data Security

We seek to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Examples of data security measures include scanning our Services on a regular basis for security holes and known vulnerabilities in order to make your visit to or use of our Services as safe as possible; maintaining your personal data behind secured networks that are only accessible by a limited number of persons with special access rights to such systems and who are under obligation to keep the information confidential; and implementing a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal data.

Data Retention

For Services requiring an account, the relevant NewTXT will retain your personal data for as long as you have an open account or as otherwise necessary to provide you with Services. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information indefinitely in a de-identified, anonymous or aggregated form where that information would not identify you personally, as described in the policy and permitted under applicable privacy laws.

Changes To This Privacy Policy

We are constantly improving our Services, so we may need to change this policy from time to time, but we will alert you to any material changes by placing a notice on the product specific website to which the changes apply, by sending you an email and/or by some other reasonable means.

Additional Terms For California Residents

This section provides information in accordance with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act for California residents about how NewTXT handle certain personal data collected over the past 12 months. If you are a California resident, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your CCPA Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

California Resident Rights under the CCPA

• Access/Right to Know. You have the right to request certain information about our collection and use of your personal data over the past 12 months, including:
• The categories of personal data that we have collected about you.
  The categories of sources from which that personal data was collected.
• The business or commercial purpose for collecting or selling your personal data.
• The categories of third parties with whom we have shared your personal data.
• The specific pieces of personal data that we have collected about you.

You have the right to request that we delete the personal data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your personal data to provide you with the Services or complete a transaction or other action you have requested.

In some circumstances, you have the right to opt out of the sale of your personal data or the sharing of your personal data specifically for cross-contextual behavioral advertising purposes. Please note, however, that we do not sell your personal data or share your personal data for cross-contextual behavior advertising, and have not done so over the last 12 months 

Your Rights under California’s Shine-the-Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal data to third parties for such third parties’ direct marketing purposes. To submit such a request, please see the Contact Us section and specify “California Shine the Light Request” in the subject line.

Additional Terms For Residents of Other US States

This section provides information in accordance with US States other than California that may now or in the future have enacted state data privacy laws, including but not limited to the Virginia Consumer Data Privacy Act (the “VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Iowa Consumer Data Protection Act (“ICPA”). For residents of these US States, this section provides Information about how NewTXT handle certain personal data that we have collected about you.

Rights Under Effective US State Laws

Right to Know/Access/Portability. You have the right to confirm whether or not we are processing your personal data and to access such personal data. You may request for this information to be provided to you in a readily usable format, to the extent it is technically feasible.

• Right to Correct. Residents in certain states have the right to correct inaccuracies in their personal data, depending on the type of personal data and our purposes for processing it.
• Right to Delete. You have the right to request that we delete the personal data that we have collected about you.
• Right to Opt-Out of Certain Activities. In some circumstances, you have the right to opt out from (i) the sale of your personal data, (ii) the processing of your personal data for purposes of targeted advertising, (iii) the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. 

Exercising Your US State Privacy Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request.” We may deny requests that do not meet these criteria. You may appeal any denial by contacting the NewTXT relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Non-Discrimination. We will not discriminate against you for exercising your rights under applicable US State privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. Please note that we do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

Complaints

If you have an unresolved privacy concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request . Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

If you are a European Economic Area or UK resident, please see the Additional Terms for European Economic Area and UK Residents section for where to lodge a complaint.

Additional Terms For European Economic Area And UK Residents

If you reside in the European Union, Lichtenstein, Norway or Iceland (collectively, the European Economic Area or ” EEA”) or the United Kingdom, the following terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Legal Basis for Use of Your Personal Data:

• Contractual Necessity: Each NewTXT processes personal data as a matter of contractual necessity, meaning that we need to process the data to perform under our product specific Terms of Use or Terms of Service with you, which enables us to provide you with the Service. This includes for the purposes of:
• Providing users with the products, services or information they request.
• Providing customer support and assistance for the Services.
• Personalizing the Services, website content and communications based on users’ preferences.
• Creating and managing user accounts or user profiles.
• Processing orders or other transactions; billing.
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about NewTXT or the Services.

When we process personal data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such information. Each NewTXT processes personal data when it furthers its legitimate interests.

Purposes for Processing:

• Providing support and assistance for the Services.
• Learning how you use and interact with one or more of our Services for the purposes of improving the Services, including testing, research, internal analytics and product development.
• To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services.
• Personalizing the Services, website content and communications based on users’ preferences.
• Marketing and selling the Services, including co-market, co-promote and cross sell.
• Showing you advertisements, including interest-based or online behavioral advertising.
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about NewTXT or the Services.
• Sending emails and other communications to you as our customer according to your preferences or that display content that we think will interest you.
• Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities (such as fraud).
• Protecting the rights, property or safety of you, NewTXT, or another party.
• Enforcing any agreements with you, including our Terms of Use or Terms of Service.
• Completion of corporate transactions.

Consent: In some cases, a NewTXT processes personal data based on the consent you expressly grant to it at the time it collects such data (which you may withdraw at any time after giving it, as described in this policy). For example, we process your personal data to send you marketing communications where you have consented to such use. We may also obtain your personal data through the use of advertising or tracking cookies based on your prior consent and use your personal data for showing you advertisements, including interest-based or online behavioral advertising. We may furthermore share your personal data amongst NewTXT for marketing purposes, with your consent. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection. You have the right to withdraw your consent at any time. We refer to the EEA and UK Resident Rights section below for further information.
Legal obligation: Each NewTXT processes your personal data where necessary to fulfill its legal obligations under applicable law, regulation, court order or other legal processing (e.g. subpoenas or warrants). 

This includes for the purposes of:
Fraud protection, security and debugging.
Responding to data subject requests under applicable privacy laws.
Processing orders or other transactions; billing.
Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Data retention and administration obligations.
Complying with requests of competent supervisory authorities and legal agencies.
Other Processing Grounds: From time to time, a NewTXT may also need to process personal data if it is necessary to protect the vital interests of you or others, or if it is necessary for a task carried out in the public interest.

Contact Us

If you subscribed to more than one Service at checkout and would like to exercise any of the rights under applicable privacy law, you can submit your request to NewTXT and indicate so on the request; NewTXT will process it accordingly. Otherwise, please contact the NewTXT relevant to your request; you can find the contact details for the relevant company.

support@newtxt.io