This Privacy Policy governs the manner in which NewlineNoosh, Inc. (dba Noosh, referred to herein as “Noosh,” “we,” “our,” “us”) collects, uses, maintains and discloses information collected from users (each, a “User”) of the www.noosh.com website (“Site”). This privacy policy applies to the Site and all products and services offered by Noosh.

If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

Personal identification information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

Noosh never collects, stores, or processes sensitive personal information such as financial information, social security number or other government identification numbers, race, religion, social media related data, political opinions, trade union membership, sexual orientation, health information, biometric data, or genetic data.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information

Noosh may collect and use Users personal information for the following purposes:

• To improve customer service. Information you provide helps us respond to your customer service requests and support needs more efficiently.
• To personalize user experience. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
• To improve our Site. We may use feedback you provide to improve our products and services.
• To run a promotion, contest, survey or other Site feature. To send Users information they agreed to receive about topics we think will be of interest to them.
• To send periodic emails. We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc.
• If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information with others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Third parties who may receive personal data

Noosh uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers perform database monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may access, process, or store personal data in the course of providing their services. Noosh maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Data Privacy Frameworks obligations, including the onward transfer provisions, and Noosh remains liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

How to access or control User information

Users have certain choices available when it comes to information Noosh has stored. Below is a summary of those choices, how to exercise them and any limitations.

User Choices

Users have the right to request a copy of their information, to object to our use of the information (including for marketing purposes), and to request the deletion of information. Below, we describe the tools and processes for making these requests.

If Users have unresolved concerns, they may have the right to complain to a data protection authority in the country where they live, where they work or where they feel their rights were infringed.

Request a copy of/update your information

Users may request via the info@noosh.com email address that we provide a copy of or update the information we have on file for them. A Noosh representative will respond via email with the information on file and confirmation of any update.

Delete your information

If Users no longer wish to use our Site, they can request via the info@noosh.com email address that User Site data be deleted. In this case we will remove any data we have on file for the User. Note that this may limit Site functionality for the User, and it is always possible for Users to re-register to continue to receive communications from Noosh.

Request that we stop using your information

In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information. Where you previously gave us consent to use your information for a limited purpose, you can contact us at info@noosh.com to withdraw that consent, but this will not affect any processing that has already taken place at the time.

Opt-out of communications

You can also opt-out of our use of your information for marketing purposes by contacting us at info@noosh.com. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved (where applicable).

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, or by contacting us at info@noosh.com to have your contact information removed from our promotional email list or registration database.

Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Compliance with children’s online privacy protection act

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

Changes to this privacy policy

Noosh has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site, revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Inquiries and complaints

Noosh complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Noosh has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Noosh has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to info@noosh.com. If requested to remove data, we will respond within a reasonable timeframe. 

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@noosh.com.  

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Noosh’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Noosh remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Noosh proves that it is not responsible for the event giving rise to the damage. 

In compliance with the Data Privacy Framework Principles, Noosh commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Noosh by email at info@noosh.com  

If you believe Noosh maintains your personal data in one of the services within the scope of our Data Privacy Frameworks certification, you may direct any inquiries or complaints concerning our Data Privacy Frameworks compliance to info@noosh.com. Noosh will respond within 45 days.

Noosh has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. 

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See  https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf  

U.S. Federal Trade Commission enforcement

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Noosh is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. 

Compelled disclosure

Noosh may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

NewlineNoosh, Inc. (dba Noosh)
www.noosh.com
NewlineNoosh, Inc. 625 Ellis St. Suite 300 Mountain View, CA 94043
650.637.6000
info@noosh.com

This document was last updated on January 29, 2024