Last Updated: May 26, 2021
What Information Do We Collect?
Contact information and other identifiers (names, addresses, phone numbers, e-mail addresses, and other data you may provide us so that we can contact you).
How Do We Use and Share Your Personal Information and Other Information?
Newflow has a legitimate interest in using the information we collect for the purposes outlined above. Specifically, Newflow has a legitimate interest in ensuring that its website continues to function efficiently and effectively, and to enhance the functionality of its website in response to how visitors use the website and collects data to that end. When you submit contact information to receive our newsletters or other communications, we use that data to fulfill your request. We also have a legitimate interest in using data about the individuals who visit this website and the companies for which they work to cultivate business relationships that may benefit Newflow or our portfolio companies. For some processing activities, such as communicating with you about opportunities to learn from or work with Newflow, we seek your consent to process that data.
We may also share your information with third parties as permitted or required by law, including: (a) with service providers that assist in operating our business; (b) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (c) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (d) to protect the interests, rights, safety, or property of Newflow or others; (e) to enforce any terms of service or other legal disclosures on or related to this Website; (f) in connection with a sale or other transfer of all or some of the assets of Newflow and/or in connection with a sale or merger of Newflow or any division of Newflow; (g) to provide you with the services or products requested by you, and to perform other activities related to such services and products; (h) to operate Newflow’s systems properly; or (i) any other sharing with your consent.
We do not sell your information to third parties.
For Users of Newflow-Sponsored Surveys
What Information Do We Collect?
Contact information (including name, test-event ID, and email address);
Test results (including score, report or other performance evaluation); and
Other personal information you may provide as part of the employment application process.
In addition, if you live in the United States, we may also collect demographic or ethnicity information (“sensitive information”) to monitor compliance with applicable non-discrimination laws. You do not have to submit this sensitive information and, where you have submitted this information and given us consent to use the information, you may withdraw your consent at any time. If you wish to withdraw your consent, please contact us at info@Newflowpartners.com.
Note that we will not share with the Employers any of this sensitive information, except in anonymized and aggregated form. The Employer will never know if you do or do not submit this information, and your decision to provide the information or not, or to consent or not (or to withdraw consent) will play no role in any hiring decisions by the Employer.
How Do We Use and Share Your Personal Data?
Newflow and third-parties working on our behalf use the information collected via your use of the Service to:
Monitor and improve the Service;
Monitor compliance with applicable non-discrimination and anti-bias laws and requirements; and
Communicate with you solely in connection with your use of the Service.
Newflow has a legitimate business interest in performing these limited processing activities to ensure that the Service continues to perform as expected by Newflow and the Employers. To the extent that certain processing activities, or the processing of certain data, requires us to seek your consent, we have done so — for example, with respect to the sensitive information mentioned above.
Newflow may also process or share your information in connection with a sale or other transfer of all or some of the assets of Newflow and/or in connection with a sale or merger of Newflow or any division of Newflow, or to operate Newflow’s systems properly. Newflow has a legitimate interest in such processing activities.
Lastly, Newflow may share your information with third parties as permitted or required by law, including: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) to protect the interests, rights, safety, or property of Newflow or others; or (d) to enforce any terms of service or other legal disclosures on or related to the test. To the extent any of this processing takes place, Newflow will only perform such processing to the extent necessary for compliance with applicable legal requirements.
The collection, use, and disclosure of the information by third parties is governed by their own privacy policies and is not the responsibility of Newflow. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information.
Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or how to disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. You may also opt out of our third party partners’ cookies by following the instructions provided by DAA AdChoices – http://optout.aboutads.info/#!/. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of this Website will not function properly.
To protect your personal information from unauthorized access and use, we use reasonable administrative, technical, personnel, and physical measures. These measures include computer safeguards and secured files and buildings.
Links to Third-Party Websites
This Website may contain links to third-party websites, including social networking sites. Since we do not control third-party websites and are not responsible for any information you may provide while on such websites, we encourage you to read the privacy policies on those websites before providing any of your information on such websites.
Accessing and Updating Your Personal Information
To access, review, rectify, or delete your name, e-mail address, phone number, or physical address, or your business name, business e-mail address, business address, or business phone number Newflow has collected about you that is subject to this policy, please contact us at info@Newflowpartners.com. Please include the following information in all requests: first name, last name, and e-mail address. While Newflow will make reasonable efforts to fulfill your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.
Consent to Transfer of Personal Information to Other Countries
Your Rights to Under Certain Data Privacy Laws
European Union and United Kingdom Residents
If you are viewing this website from the European Union or United Kingdom, under the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA 18”) you have a number of rights with regard to your “personal data” (as defined in the GDPR or the DPA 18). For example, you have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing and (in certain circumstances) the right to data portability. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time; however, such withdrawal will not affect the lawfulness of the processing before your consent was withdrawn. You also have the right to lodge a complaint if you believe that we have not complied with the requirements of the GDPR or the DPA 18 regarding your personal data.
Likewise, if you are a resident of the Cayman Islands, the Cayman Islands’ Data Protection Law, 2017 provides you with certain rights as regards your personal information.
To learn more about these rights, make a request for your information, or to lodge a complaint with respect to your personal data, please contact us at info@Newflowpartners.com.
How we respond to Do Not Track signals