Effective Date: February 13, 2023

Last Updated: May 10, 2023

Welcome to the New Era Partners, LLC (“we,” “our,” “Company”) Privacy Policy.

This Privacy Policy explains how we collect, store, and share your personal information and how we protect it. We do not sell your personal information or information collected about a customer or prospective customer to third parties. If you do not agree with our policies and practices, do not use our sites.

As used in this Privacy Policy, “personal information” means information that relates to an identified individual or to an identifiable individual. For example, this could include, among other things, your name, address, email address, business contact details, or information gathered through your interactions with us via our sites.

1. SCOPE

This Privacy Policy applies to personal information we collect from you on New Era Partners websites on newerapartners.com, computer, or mobile software applications (collectively, the “sites”) in your capacity as:

• A visitor and/or user of our sites;
• An individual who works for, or on behalf of, or who is a shareholder of our customer(s) and/or prospective customer(s); and/or
• A subscriber of New Era Partners services, publications and newsletters.

This Privacy Policy does not apply to personal information we collect from you offline or that you provide on any third party website that New Era Partners does not control.

2. INFORMATION WE PROCESS

The information we may process from you, depending on your interaction with us, may include:

• Your name, physical address, email address, and phone numbers;
• Business contact and other information (such as job title, department, name of organization and your dealings with us on behalf of yourself or the relevant customer);
• Transactional data, such as products and services ordered, financial details, and payment methods;
• Information and data regarding your business activities as provided in the course of using our services;
• Information in correspondence between you and us and/or our customer support team;
• Information you share through surveys conducted by us, New Era Partners-sponsored events, and industry associations you participate in;
• Information regarding your use of the sites (e.g., date and time of activities or the web search used to locate and navigate to a site); and
• Information from and about the device(s) you use to access our sites, including hardware and software information such as IP address, device ID and type, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

We do not store your credit card information. All credit card payments are processed through a secured third-party provider who is bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose to them.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

Certain online information about you or device information may originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties. To learn more about why we use cookies and similar technologies and how you can control their use, see Section 9 below.

3. HOW WE USE YOUR INFORMATION

We generally use the information we collect for the following business purposes:

• Fulfill the purpose for which you provide it;
• Communicate and respond to your requests and inquiries to us, including providing technical and/or customer support;
• Execute and enforce agreements with customers, including processing orders for our products and services, and billing and collections;
• Improve and develop our sites and conduct product development;
• Send you marketing information about our events, offers, products, and services; and
• Ensure legal compliance.

We will only send marketing information to you, on behalf of yourself or the customer(s) and prospective customer(s) you represent, if you opt in to our marketing communications. If you wish to opt out of such communications, you may do so by contacting us at consulting@newerapartners.com.

Failure to provide us with the information required will negatively affect our ability to communicate with you and/or the customer(s) you represent, and/or our ability to enter into a contract with such customer(s) or continue to contract with such customer(s). You may contact us at consulting@newerapartners.com and update the personal information you provide on our sites (such as your business contact information) so that we may maintain accurate records of you and/or the customer(s) you represent.

4. HOW WE SHARE YOUR INFORMATION

Sharing within New Era Partners

We may share your information within our corporate group, including a parent, subsidiary, or other affiliate of our corporate group. New Era Partners personnel are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share your information with the following third parties for a business purpose:

• Third-party service providers so that these services providers may perform business functions on our behalf (for example, payment processing and transaction fulfillment, database maintenance, sending communications, technology services, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing);
• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
• As required by law, we may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of New Era Partners, our affiliates, and our sites.

5. CONTROL OVER YOUR INFORMATION

We strive to provide you with choices regarding the information you provide to us. To that end, you may request:

• access to your personal information;
• correction or deletion of your personal information (we will honor your request to the extent such correction or deletion would not violate Section 8’s terms or any legal or regulatory requirement and your personal information is no longer required for a legitimate business purpose);
• that you no longer receive marketing communications on behalf of yourself and/or a customer; and/or
• that the processing of your personal information is restricted.

To make any of these requests, please contact consulting@newerapartners.com.

6. SECURITY

We use commercially reasonable measures to help protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, please be aware that, despite our measures, no data security measures or method of transmission over the Internet or means of electronic or physical storage, is guaranteed to be absolutely secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

7. CHILDREN

Our sites are not intended for children under the age of 16. We do not knowingly collect information from children. If we learn that we have collected personal information on our sites from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at consulting@newerapartners.com.

8. HOW LONG WE RETAIN YOUR INFORMATION

Any personal information that is required for the purposes of enforcing and executing agreements  with customers will be held for the duration of the contractual relationship and may be held for (a)  a longer period of time where there is a legal or regulatory reason to do so (in which case it will be  deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where you object to the processing of your personal information and there is no longer a legitimate business  purpose to retain it.

All other personal information will be retained for as long as necessary for record retention and legal compliance purposes.

9. COOKIES AND SIMILAR TECHNOLOGIES

We and our third party service providers use cookies and other similar technologies to track information about your use of our sites. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). If you do not want to receive cookies, you can change your browser settings on your computer or other device you are using to access our sites. Please be aware that removing or rejecting cookies could affect the availability and functionality of the sites. Most browsers also provide functionality that lets you review and delete cookies, including cookies from us.

• Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our sites, while others allow us to track your activities at our sites.  There are two types of cookies: session and persistent cookies.
• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session. This allows us to process your online transactions and requests and verify your identity as you move through our sites.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising on third-party sites.
• Clear GIFs, pixel tags and other similar technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our sites to, among other things, track the activities of site visitors, help us manage content, and compile statistics about site usage. We also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e mails are forwarded.

10. PRIVACY POLICY CHANGES

This Privacy Policy is effective as of the Effective Date provided above. We may update this Privacy Policy from time to time. When we update the Privacy Policy, we update the “Last Updated” date at the top of this policy, post the new Privacy Policy, and provide any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the sites to stay informed of our privacy practices. By continuing to utilize our services and our site, you agree to the “Last Updated” version of this policy.

11. CONTACTING US

By email: consulting@newerapartners.com

By post: 1201 2nd Ave, Suite 915, Seattle, WA 98101