Privacy Policy

The following documentation explains how and why NewAge ADS, its affiliates, advertising, and other third-party partners, collectively referred to as “we” for the purposes of this documentation, collect and use personal, identifiable, and other information (“User Information”) about users through use of our website, jingleways.com, our applications, and other online services (“Services”).

Definitions

GDPR	Means the General Data Protection Regulation.
Privacy Policy	Refers to the present document which constitutes our policy regarding your personal, non-personal and usage information.
Register of Systems	Means a register of all systems or contexts in which personal data is processed by the Company.
Responsible Person	Means the nominated individual responsible for data protection within the Company.
Services	This website, any other distribution channel for the content on this website like our RSS and Atom feeds, our desktop or mobile applications, and any other online services offered by NewAge ADS, LLC.
Usage Data	IP address, mobile device identifier or other unique identifier, browser and computer type, access time, the Web page users’ came from, the URL they go to next, the Web page(s) accessed during their visit and users’ interaction with content or advertising on the Services.
User Information	Any personal, non-personal, user information, and usage data are called User Information in this Privacy Policy.
We	Refers to NewAge ADS, affiliates, advertising partners and other third-party partners.

1. Data Protection Principles

The Company is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General Provisions

1. This policy applies to all personal data processed by the Company.
2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually, or sooner if needs dictate.

3. Lawful, Fair and Transparent Processing

1. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.

4. Lawful Purposes

1. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. The Company shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.

5. Data Minimisation

1. The Company shall ensure that personal data is adequate, relevant and limited to what is necessary, in relation to the purposes for which it is processed.

6. Accuracy

1. The Company shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / Removal

1. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and the reasons for which it is being retained.

8. Security

1. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to users’ rights and freedoms.

10. Information Collected by the Company

1. Information We Collect Automatically
   1. When users visit one of our Services, we may automatically collect information about them such as IP address, mobile device identifier or other unique identifier, browser and computer type, access time, originating web page, next URL, web page(s) accessed during a user’s visit, and interaction with content and/or advertising on the Services (“Usage Data”).
   2. When users share our articles on social media platforms, we may also receive Usage Data and User Information shared with the platform.
   3. We also use third-party pixel tags which are small graphic files which allow ourselves and our partners to get Usage Data on users.
   4. We and our third-party advertising, affiliate, and analytics partners also use cookies to keep a record of the information stated above in users’ local browser cache. This helps us collect Usage Data upon subsequent visits, linking previous activity with current and future visits.
2. Information Users Provide
   1. When users subscribe to our newsletter, we collect and save the email address associated. When comments are submitted, we receive the poster’s profile information through our partner, Disqus. When users apply for a job in the Careers section of our website, or send a message through our Contact section, we receive the user’s name, email, website, and other information disclosed in the comment.
3. Information We Get From Others
   We may get User Information about users from third-party (advertising, affiliate, and advertising) partners in the following circumstances:
   1. When users signup at our affiliate partners to purchase something, or participate in a campaign
   2. From our advertising partners about users’ activity on our website
   3. When users utilize a third-party partner’s system to log into our website

11. How Information Is Used

The data collected from users may be used in the following ways:

1. Our third-party advertising partner may use Usage Data to show users advertisements that may be more suited to them.
2. We use users’ information in an aggregate, (i.e. non-personally identifiable) form to identify viewership trends on our website. We also use it to improve the interface and content of the website.
3. We use users’ email addresses to send a daily email summarizing the news we cover.
4. We use third-party advertising companies who serve ads to help keep content free. For these partners, we put additional restrictions on how users’ data can be used to protect it from misuse. For instance, we do not allow these partners to take users’ information for profiling and personalizing ads on other websites.

12. How long is information stored?

1. Email addresses and submissions made through the ‘Contact’ and ‘Careers’ sections of our website are kept for the same duration as we are in operation.
2. We ask our analytics partner, Google Analytics, to remove personally-identifiable information after a period of 36 months in which there has been no interaction from the user. After this occurrence the only information that is kept is done so in an aggregate form, devoid of any personal identifiers.

13. How We Share Your Information

1. No user information is sold to any third-party.
2. We may share the information we have about you with our third-party (advertising, affiliate, and analytics) partners, including when you connect with third-party apps and widgets. This information is shared to improve functionality or make advertisement possible on the website.
3. We share user email addresses with a third-party partner to send users our daily newsletter.
4. We reserve the right, and terms of customer usage of the website expressly authorize the company, to share User Information in the following circumstances:
   1. In response to subpoenas, warrants, court orders, or legal processes.
   2. To establish, protect, or exercise our legal rights or defend against legal claims.
   3. If we believe it is necessary to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property.
   4. If we believe it is necessary to investigate, prevent, or act regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information).
   5. To protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the public.
   6. To our parent company, subsidiaries, joint ventures, or other companies under common control with us, and as such, are responsible under the same Privacy Policy herein.

14. Users’ Rights

It is important to note that by accessing the website, users consent to our terms and conditions. User consent is vital to the company and the way in which we seek to collect, store and use data.

1. Every email we send to users contains an unsubscribe link. Users can click on it to stop receiving any further communications from us.
2. You can request a permanent deletion of the information you have explicitly provided us through our ‘Contact’ or ‘Career’ pages.
3. Some of the third-party service providers and/or advertisers may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. If so, you may want to visit 
4. http://www.networkadvertising.org/managing/opt_out.asp 
5. which provides information regarding targeted advertising and the “opt-out” procedures of NAI members.
6. You can opt-out of our use of your Web site viewing behavior data to serve you interest-based advertising on third-party sites and email newsletters at https://www.aboutads.info/choices/. If you are accessing the Services through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device’s application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information visit 
7. https://youradchoices.com/appchoices.
8. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.
9. Further user rights are delineated in Articles 12-23 of the GDPR, adherence with is a corollary to the present Privacy Policy.

15. Security

We have implemented commercially-reasonable security measures to help protect your Personal Information from loss, misuse, or unauthorized access or disclosure; however, as no data transmission over the Internet can be guaranteed to be 100% secure, whilst we strive to protect your User Information, we cannot guarantee its security. Usage of the Site and provision of information is done at your own initiative and risk with strict adherence to the spirit and principles of General Data Protection Regulation.

16. Links

The Services may contain links to other websites that we do not have any control over. Additionally, the Services may contain videos, advertising and other content hosted and served by third-parties. We are not responsible for the privacy practices of any third-party.

17. Children’s Privacy

The Services are intended for a general audience and are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target the Services to children under the age of 13. We advise that children of any age should be supervised by their parents or guardians when browsing and bear no liability for the alternative.

18. Changes

We may update this Privacy Policy from time to time as per the Company’s discretion and needs. Users will be notified of any material changes in the way in which we treat Personal Information. This will be done by way of posting a notice on relevant areas of the Services. We may also provide notice to you in other ways in accordance with our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy, unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without users’ consent, use Personal Information in a manner materially different than what was stated at the time your Personal Information was collected. In any event, this present policy will be reviewed at a minimum of annually, or more frequently if needs dictate, or there is a material change in the areas of legislative governance pertaining to users’ rights.

19. Contact

If you have any questions about this Privacy Policy, please feel free to contact us by email at contact@jingleways.com.