Privacy Policy

Effective Date: May 23, 2017

New Origin Capital LLC ("Us" or "We", "NOC", "Nettrons") is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of (a) our websites, including those located at nettrons.com (“Site“) (b) our Services, including the Nettrons Chrome Extension and the Nettrons cross-platform AI Assistant. Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at www.nettrons.com/accounts/terms.

User Consent

By submitting Personal Data through our Site or Services you agree to the terms of this Privacy Policy, you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy, and you represent and warrant that you have all rights necessary to submit such Personal Data.

A Note about Children

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please cont​act us at team@nettrons.com.

Types of Data We Collect

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

(A) Information You Provide to Us

We may collect Personal Data from you, such as your first and last name, gender, phone number, e-mail addresses, mailing addresses, professional title, company name, account password, and third­ party account credentials (for example, your log­in credentials for Outlook, LinkedIn, or other third party sites) when you create an account and/or through your account settings.

If you provide your third­party account credentials to us, you understand some content and/or information in those accounts ("Third Party Account Information") will be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, if you link your Outlook, Gmail, or LinkedIn account to your Nettrons account, certain information from those third party accounts will be transmitted to and displayed within your Nettrons account. Certain information may be required to register with us or to take advantage of some of our features.

When you order Services on our Site, we (or our third party service provider) will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

When you participate in one of our surveys, we may collect additional profile information

We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected.

(B) Information Collected via Technology

To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions.

We may collect, and we allow third parties to collect, information about how you use and interact with our Site and Services. For example, Google Analytics, Optimizely, and MouseFlow.

(C) Information Collected via Nettrons Site and Services.

When you use the Nettrons Site or Services, our software backend will collect End User Contact Data from your address books. “End User Contact Data” means information about your contacts that we collect from your address book(s) or your email and includes first name, last name, birth date, age, email address, gender, company, job title, photos, website urls, social network handles, instant messenger handles, physical address (but does not include any information that you provide when you register for any of our Site or Services)(collectively, “End User Contact Data”).

(D) Information Collected Through Your Email Service.

We make available a feature for certain email services or email software whereby our systems will collect End User Contact Data from your email. This is a feature that you must choose to activate via the Nettrons Site/Services or your account, and you may choose to deactivate this feature at any time. When this feature is activated, your email is copied to our servers and automatically scanned for contact information (i.e., End User Contact Data). The copy of the email is automatically deleted promptly after the scan. We use IMAP (Internet Message Access Protocol) for accessing email from your email provider (e.g., Outlook, Gmail). IMAP is an Internet standard protocol used by email clients to retrieve email messages from a mail server over a TCP/IP connection. For some email services, you may need to provide your username and password for us to access your email to enable this feature. We use industry-standard security practices for the security of your username and password.

(E) Information Collected from Third Parties.

We collect the information about you and other individuals (including those in your End User Contact Data) from the following third party sources: (a) third parties who license, sell or otherwise provide data they have collected; or (b) information from publicly available sources, such as via the Internet and social networks, including through public or licensed APIs (“Public Data”). We do not collect data from webpages that have been designated (in a standards-based way) as private.

(F) How We Combine Data.

We will not process your End User Contact Data for purposes of cookie tracking, ad exchanges, ad networks, or sending electronic communications (including email). We may, however, combine your End User Contact Data with Public Data to create more complete data records (“Completed Contact Data”). When we do this, we separate data into two different groups: data elements, such as an actual email address, twitter handle, or facebook user name, and data associations, which are the links we make between different data elements to assign multiple data elements to the same person. We do not sell your End User Contact Information or disclose your End User Contact Information to any third party; provided, however that we may use your End User Contact Information to make data associations between data elements (provided the data elements constitute Public Data) and disclose these data elements as Completed Contact Data even if the data association was previously undisclosed. For example, if a person has a twitter handle, an email address and a facebook page, all of which constitute Public Data, and you provide End User Contact Data that includes the data association to tie those three elements of Public Data together, we can disclose that connection. Further, nothing shall restrict our right to use, access, process, collect, disclose, share or distribute any Public Data, even if such Public Data is duplicative of your End User Contact Data.

Use of Your Personal Data

(A) End User Contact Data and Completed Contact Data. We use End User Contact Data and Completed Contact Data as described above.

(B) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

Facilitate the creation of and secure your account on our network;

Identify you as a user in our system;

Provide improved administration and quality of experience of our Site and Services;

Provide the Services you request;

Send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;

Send you administrative e-mail notifications, such as security or support and maintenance advisories;

Respond to your inquiries related to employment opportunities or other requests; and

Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Nettrons.

(C) Creation of Anonymous Data.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. Nettrons reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

Disclosure of Your Personal Data

We disclose your Personal Data, End User Contact Data and Completed Contact Data as described below and as described elsewhere in this Privacy Policy.

(A) Third Party Service Providers.

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to Nettrons. These third party service providers are required not to use your Personal Data other than to provide the services requested by Nettrons.

(B) Affiliates and Acquisitions.

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(C) Other Disclosures.

Regardless of any choices you make regarding your Personal Data (as described below), Nettrons may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Nettrons; (c) to protect or defend the rights or property of Nettrons or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use.

Third Party Websites

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

Your Choices Regarding Your Personal Data

(A) Email Choices.

We offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a registered user, we will periodically send you free newsletters and e-mails that promote our Site or Services as well as products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

(B) Access, Correction, and Deletion.

Nettrons allows individuals to access, modify, and set permissions with respect to End User Contact Data that it holds about them. For example, Nettrons also provides certain features that allow you to publish and share some of your Personal Data, End User Contact Data or Completed Contact Data with others, but these features are totally optional and whether or not you use them is up to you. If you choose to connect your Nettrons account with one of our development partners, you may be giving the partner access to your Personal Data, End User Contact Data or Completed Contact Data. We will tell you how the partner application will access your account and you can turn off access whenever you want. Finally, Nettrons provides you with the ability to export your Personal Data, End User Contact Data or Completed Contact Data from our systems at any time using industry standard formats.

(C) Additional Choices For California Residents

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. Alternately, such businesses may have in place a policy not to disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As described in Section 8(b) above, you can opt-out of our sharing of your personal information with third parties for the third parties’ direct marketing purposes by claiming your profile and selecting how your personal information is used. To find out more about your opt-out rights, please contact us at the address listed in the Contact section below. Please note that under California law businesses are only required to respond to a customer making such a request once during any calendar year.

Data Integrity

Nettrons will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Nettrons will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. Nettrons depends on you to update and correct your Personal Data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.

Disputes

Generally, Nettrons takes its users’ privacy concerns seriously. If you believe that Nettrons has not adhered to this Privacy Policy, please contact Nettrons as described in Section 13 below. In your email, please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

Security of Your Personal Data

Nettrons is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Nettrons uses reasonable efforts to protect your Personal Data, Nettrons cannot guarantee its absolute security.

Contact

Nettrons welcomes your comments or questions regarding this Privacy Policy. Please contact us at this address or phone number:

Address: New Origin Capital LLC, 3505 El Camino Real, Palo Alto, CA 94306

Phone Number: (607)379-5084

Changes to This Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the nettrons.com Site, by sending you an email, and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

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