This State Consumer Privacy Statement (“Statement”) supplements the NewRetirement Privacy Policy. It applies solely to California, Colorado, Connecticut, Utah and Virginia consumers and addresses personal information the Site collects online and offline. This Statement does not apply to personnel or job applicants of NewRetirement.
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”), the Colorado Privacy Act, the Connecticut Personal Data Privacy and Online Monitoring Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act (collectively, the State Privacy Laws). The Site did not sell personal information of consumers in the 12-month period prior to the effective date of this Statement.
1. Notice of Collection and Use of Personal Information
The Site may collect the following categories of personal information about you as described in the CCPA:
- Identifiers: identifiers such as a real name, zip code, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: credit card number, debit card number, and other financial information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as age, gender, marital status and medical condition
- Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Site, other websites, or advertisements
- Geolocation Data
- Sensory Information: electronic and similar information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The Site may use your personal information for the purposes described in the NewRetirement Privacy Policy and for the following business purposes specified in the CCPA:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
2. Sources of Personal Information
The Site may obtain personal information about you from the following categories of sources:
- Directly from you, such as when you create an account through the Site
- Your devices, such as when you visit the Site
- NewRetirement’s affiliates and subsidiaries
- Vendors who provide services on the Site’s behalf
- Online advertising services and advertising networks
- Data analytics providers
- Operating systems and platforms
NewRetirement does not have actual knowledge that the Site sells personal information of minors under 16 years of age.
3. Sale of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain ad technology companies) to collect your personal information, including via automated technologies on our Site, in exchange for non-monetary consideration (such as an enhanced ability to serve you content and send advertisements that may be of interest to you). We may disclose in this manner the following categories of personal information to online advertising services and social networks: (1) Identifiers; (2) Commercial Information; (3) Online Activity; and (4) Inferences.
4. Sharing of Personal Information
The Site may disclose the following categories of personal information about you for a business purpose to the following categories of third parties:
| Category of Personal Information | Category of Third Party |
|---|
| Identifiers | NewRetirement affiliates
Third parties with whom you direct the Site to engage (e.g., social networks) |
| Commercial Information | NewRetirement affiliates |
| Online Activity | Third parties that provide content, advertising or functionality |
| Sensory Information | NewRetirement affiliates |
5. State Privacy Law Rights
You have certain choices regarding the personal information obtained about you in connection with the Site, as described below.
Access: You have the right to request, twice in a 12-month period, the personal information the Site has collected, used, disclosed and sold about you during the past 12 months.
Automated Decision-Making: You may have the right to opt out of automated decision making, including profiling, against any information collected about you.
Correction: You may have the right to request that certain personal information the Site has collected from you which is incorrect be updated or corrected.
Deletion: You have the right to request that certain personal information the Site has collected from you be deleted.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Opt-Out of Sharing: You may have the right to opt-out of the sharing of your personal information for cross-contextual behavioral advertising.Sensitive Information: You may have the right to limit the use of sensitive personal information.
Targeted Advertising: You may have the right to opt-out of targeted advertising.
“Do Not Track” Requests: The Site is not designed to respond to “do not track” signals or similar mechanisms received from browsers.
How to Submit a Request.
- To submit an access, deletion, or opt out of sale of your personal information request, click here.
- To submit a request as an authorized agent on behalf of a consumer, complete this form and follow the instructions for authorized agents.
For questions or concerns about the Site’s privacy practices, please contact NewRetirement as described in the Privacy Policy.
Verifying Requests. To help protect your privacy and maintain security, NewRetirement will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with the Site, NewRetirement may verify your identity by requiring you to sign in to your account. If you do not have an account with the Site and you request access to or deletion of your personal information, there is no reasonable method by which NewRetirement can verify your identity to the level of certainty required by the State Privacy Laws. As such, we will not be able to process your request at this time.
Additional Information. If you choose to exercise any of your rights under the State Privacy Laws, you have the right to not receive discriminatory treatment. If you require assistance in understanding this information for any reason, whether due to a disability or otherwise, please email us at privacy@newretirement.com.
6. Processing Activities
Some businesses engage NewRetirement as a processor or subprocessor of your information. In this situation, NewRetirement’s obligations and processes are governed fully or in part by the contract with, and instructions of, the NewRetirement customer.
Last Updated: March 1, 2024
