Privacy of Online Properties and Electronic Communications

Intent
Newgate 180 values visitors’ privacy, while utilizing its online properties and electronic communication. It is important to note that no computer system or online communication is perfectly secure, but Newgate 180 makes every effort to safeguard visitors’ privacy. The following policy outlines these efforts.

Definitions
Personal Information is information or an opinion that can be used to reasonably identify an individual. Personal Information can include information that visitors of Sites provide to organizations voluntarily, information organizations automatically collect when visitors visit their Site, and information collected when visitors register for organizations’ programs or services.

Certain information is excluded from this definition, such as specific business contact information, or information that has been made anonymous or has been permanently de-identified, which means that the visitor cannot be identify.

Policy
Newgate 180 does not collect personal, identifying information automatically from general visitors of the organization’s website or other online properties. Non-identifying information is collected via cookies and/or trackers to assist Newgate 180 to enhance the visitors’ experience on the website or other properties, by improving the design, layout, content and function. Visitors can opt out of the use of cookies, if they so choose.

Newgate 180 does not partner with or have special relationships with any ad server companies or vendors. No visitor information collected is shared or sold to such third-parties. However, a third-party analytics service gathers and analyses non-identifying information for Newgate 180.

Newgate 180 utilizes industry-standard encryption technologies when transferring and receiving visitor data exchanged with our Site, for security purposes.

Procedure
1. In administering the website, Newgate 180 automatically collects certain information from visitors via a third party analytics service. When Newgate 180 collects this information on visitors who browse our website, it is not personal information; it is non-identifying information. This information is anonymized and consists of aggregated usage data, such as how many individuals visited the Newgate 180 site, peak hours of visits, which page(s) were viewed, age and gender percentages of visitors, types of devices used, etc.

Newgate 180’s Site, like most other websites, uses cookies, which are small text files installed on visitors’ computers when they visit our Site. Cookies collect non-identifiable, non-personal information about visitors and help Newgate 180 understand how visitors use our Site, so the organization can improve its design, layout, content and function. We collect this information to better understand how our Site is being used and how we can better improve visitors’ experience on our Site.

Newgate 180 uses third-party cookies on our Site and engages a third-party to monitor and analyze the use of our Site. Newgate 180 uses Google Analytics to track, monitor and report on traffic to our Site. Google Analytics does not gather personal information on behalf of Newgate 180. Any such third-party cookies are governed by the respective terms of service and privacy policies of those providers. For more information on how Google Analytics collects and processes information, please visit Google’s site “How Google uses data when you use our partners’ sites or apps” located at Google/policies

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at devowl/dataprocessing.

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

If visitors wish to opt out of the use of cookies on Newgate 180 website, they can visit Google’s site at Tools.google/outout

2. In addition to the automatic collection of non-identifying information, visitors may voluntarily provide Newgate 180 with identifying information to seek service or further information about Newgate 180’s services. This is done via a form on the organization’s website or the organization’s Facebook page that the visitor chooses to fill out and provide to Newgate 180. We may collect personal information such as name, address, phone number and email address when voluntarily submitted by our visitors. This information provided is only used to fulfill visitors’ specific requests unless permission is explicitly given to use it in another manner. Personal information provided by visitors will not be shared with any third-party organization except with the visitors’ express consent.