1.2 This policy applies where we are acting as a data processor with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
How do we collect and use your personal data
2.1 To access the certain Services, you are required to create a user account, including user ID and password, and input certain Personal Information, including your email address phone number. We collects Personal Information from you through the Services to allow us to provide the Services that will most likely meet your needs and preferences. We only collect Personal Information about you that we consider necessary for achieving this purpose.
2.2 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.3 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.5 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 We may obtain financial data of you payment transaction information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.
2.7 Device Information : We collect device-specific information when you access our Services, including hardware model, operating system and version, unique device identifiers, mobile network information and information about the device’s interaction with our Services. We may also identify other software running on the device (but will not collect any content from such software) for anti-fraud measures and malware-prevention purposes.
2.8 Please do not supply any other person's personal data to us, unless we prompt you to do so.
How do we retain and delete your personal data
3.1 This Section 3 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
3.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: the period of retention of personal data specified in Section 2 will be determined based on your ongoing business relationship with us and/or of your involvement in our industry sector.
3.4 Notwithstanding the other provisions of this Section 3, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your choices and rights
4.1 In this Section 4, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
4.2 Your principal rights under data protection law are: the right to access, rectification, erasure, restrict processing, object to processing, data portability, complain to a supervisory authority; and withdraw consent.
4.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
4.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
4.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
4.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
4.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
4.8 To the extent that the legal basis for our processing of your personal data is:
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
4.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the state of your habitual residence, your place of work or the place of the alleged infringement.
4.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
4.11 You may exercise any of your rights in relation to your personal data by written notice to us.
How we disclose to Third Parties
5.1 Newland NPT and any of our subsidiaries may engage other companies, service providers or individuals or any third party to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to the third parties such as those listed below (which is not exhaustive):
1) Information technology service providers
2) Data entry service providers
3) Regulatory and governmental authorities in order to comply with statutory and government requirements
4) Potential buyer of transferee in the event of any re-organization or disposal of our business or any part thereof
5.2 We may also disclose your Personal Information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5.3 Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Statement. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information, including your email address, to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from Company. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should neither rely upon nor expect, that your Personal Information or private communications will always remain private.
Third-Party Providers and Their Services
6.1 To ensure a positive user experience, you may receive content or web links from third parties other than Newland NPT and its partners ("third parties"). Newland NPT does not have the right to control such third parties, but you can choose whether to use the links, view the content and/or access the products or services provided by third parties.
6.2 Newland NPT cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When you submit personal information to such a third party, please read and refer to the privacy protection policy of the third party.
Updates to This Policy
Policy for children under the age of 18
We do not knowingly solicit information from or market to children under the age of 18. If you become aware of any data we have collected from children under age 18, please contact us using the contact information provided below.