Effective date: February 1, 2024
Welcome to the Neway Privacy Statement. This is where we describe how we handle your “Personal Data”, which is information that is directly linked or can be linked to you. It applies to the Personal Data that Neway, Inc. processes as the “Data Controller” when you interact with websites, applications, and services that display this Statement (collectively, “Services”). This Statement does not apply to services or products that do not display this Statement, such as Previews, where relevant.
When a school or employer supplies your Neway account, they assume the role of Data Controller for most Personal Data used in our Services. This enables them to:
Should you access a Neway Service through an account provided by an organization, such as your employer or school, the organization becomes the Data Controller, and this Privacy Statement's direct applicability to you changes. Even so, Neway remains dedicated to preserving your privacy rights. In such circumstances, Neway functions as a Data Processor, adhering to the Data Controller's instructions regarding your Personal Data's processing. A Data Protection Agreement governs the relationship between Neway and the Data Controller. For further details regarding their privacy practices, please refer to the privacy statement of the organization providing your account.
In cases where your organization grants access to Neway products, Neway acts as the Data Controller solely for specific processing activities. These activities are clearly defined in a contractual agreement with your organization, known as a Data Protection Agreement. For those limited purposes, this Statement governs the handling of your Personal Data. For all other aspects of Neway product usage, your organization's policies apply.
When you use third-party extensions, integrations, or follow references and links within our Services, the privacy policies of these third parties apply to any Personal Data you provide or consent to share with them. Their privacy statements will govern how this data is processed.
Personal Data is collected from you directly, automatically from your device, and also from third parties. The Personal Data Neway processes when you use the Services depends on variables like how you interact with our Services (such as through web interfaces, desktop or mobile applications), the features you use (such as pull requests, Codespaces, or Neway Copilot) and your method of accessing the Services (your preferred IDE). Below, we detail the information we collect through each of these channels:
The Personal Data we process depends on your interaction and access methods with our Services, including the interfaces (web, desktop, mobile apps), features used (pull requests, Codespaces, Neway Copilot), and your preferred access tools (like your IDE). This section details all the potential ways Neway may process your Personal Data:
When carrying out these activities, Neway practices data minimization and uses the minimum amount of Personal Information required.
We may share Personal Data with the following recipients:
Neway processes Personal Data in compliance with the GDPR, ensuring a lawful basis for each processing activity. The basis varies depending on the data type and the context, including how you access the services. Our processing activities typically fall under these lawful bases:
Depending on your residence location, you may have specific legal rights regarding your Personal Data:
To exercise these rights, please send an email to Clyde.he[at]newayprecision[dot]com and follow the instructions provided. To verify your identity for security, we may request extra information before addressing your data-related request. Please contact our Data Protection Officer at Clyde.he[at]newayprecision[dot]com for any feedback or concerns. Depending on your region, you have the right to complain to your local Data Protection Authority. European users can find authority contacts on the European Data Protection Board website, and UK users on the Information Commissioner’s Office website.
We aim to promptly respond to requests in compliance with legal requirements. Please note that we may retain certain data as necessary for legal obligations or for establishing, exercising, or defending legal claims.
Neway stores and processes Personal Data in a variety of locations, including your local region, the United States, and other countries where Neway, its affiliates, subsidiaries, or subprocessors have operations. We transfer Personal Data from the European Union, the United Kingdom, and Switzerland to countries that the European Commission has not recognized as having an adequate level of data protection. When we engage in such transfers, we generally rely on the standard contractual clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights and enable these protections to travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Neway processes personal data, see this article on the European Commission website.
Neway also 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. Neway 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. Neway 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 statement 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/.
Neway has the responsibility for the processing of Personal Data it receives under the Data Privacy Framework (DPF) Principles and subsequently transfers to a third party acting as an agent on Neway’s behalf. Neway shall remain liable under the DPF Principles if its agent processes such Personal Data in a manner inconsistent with the DPF Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Neway commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF should first contact Neway at: Clyde.he[at]newayprecision[dot]com.
If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of the International Centre for Dispute Resolution are provided at no cost to you.
An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. For additional information visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
Neway is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under Section 5 of the Federal Trade Commission Act (15 U.S.C. § 45), an organization's failure to abide by commitments to implement the DPF Principles may be challenged as deceptive by the FTC. The FTC has the power to prohibit such misrepresentations through administrative orders or by seeking court orders.
Neway uses appropriate administrative, technical, and physical security controls to protect your Personal Data. We’ll retain your Personal Data as long as your account is active and as needed to fulfill contractual obligations, comply with legal requirements, resolve disputes, and enforce agreements. The retention duration depends on the purpose of data collection and any legal obligations.
Neway uses administrative, technical, and physical security controls where appropriate to protect your Personal Data.
Contact us via our contact form or by emailing our Data Protection Officer at Clyde.he[at]newayprecision[dot]com.
Our Services are not intended for individuals under the age of 13. We do not intentionally gather Personal Data from such individuals. If you become aware that a minor has provided us with Personal Data, please notify us.
Neway may periodically revise this Privacy Statement. If there are material changes to the statement, we will provide at least 30 days prior notice by updating our website or sending an email to your primary email address associated with your Neway account.
Neway uses cookies to provide, secure and improve our Service or to develop new features and functionality of our Service. For example, we use them to (i) keep you logged in, (ii) remember your preferences, (iii) identify your device for security and fraud purposes, including as needed to maintain the integrity of our Service, (iv) compile statistical reports, and (v) provide information and insight for future development of Neway.
For Enterprise Marketing Pages, we may also use non-essential cookies to (i) gather information about enterprise users’ interests and online activities to personalize their experiences, including by making the ads, content, recommendations, and marketing seen or received more relevant and (ii) serve and measure the effectiveness of targeted advertising and other marketing efforts. If you disable the non-essential cookies on the Enterprise Marketing Pages, the ads, content, and marketing you see may be less relevant.
Our emails to users may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email communications more effective and to make sure we are not sending you unwanted email.
The length of time a cookie will stay on your browser or device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay until they expire or are deleted. The expiration time or retention period applicable to persistent cookies depends on the purpose of the cookie collection and tool used. You may be able to delete cookie data.
We use cookies and similar technologies, such as web beacons, local storage, and mobile analytics, to operate and provide our Services.
Cookies are small text files stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called “single-pixel” or “clear GIFs”) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content.
Mobile identifiers for analytics can be accessed and used by apps on mobile devices in much the same way that websites access and use cookies.
We may also use so-called “flash cookies” (also known as “Local Shared Objects” or “LSOs”) to collect and store information about your use of our Services. Flash cookies are commonly used for advertisements and videos.
The Neway Services use cookies and similar technologies for a variety of purposes, including to store your preferences and settings, enable you to sign-in, analyze how our Services perform, track your interaction with the Services, develop inferences, combat fraud, and fulfill other legitimate purposes. Some of these cookies and technologies may be provided by third parties, including service providers and advertising partners. For example, our analytics and advertising partners may use these technologies in our Services to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) related to your online activities over time and across Services for various purposes, including targeted advertising.
We and/or our partners also share the information we collect or infer with third parties for these purposes.
The table below provides additional information about how we use different types of cookies:
Purpose | Description |
---|---|
Required Cookies | Neway uses required cookies to perform essential website functions and to provide the services. For example, cookies are used to log you in, save your language preferences, provide a shopping cart experience, improve performance, route traffic between web servers, detect the size of your screen, determine page load times, improve user experience, and for audience measurement. These cookies are necessary for our websites to work. |
Analytics | We allow third parties to use analytics cookies to understand how you use our websites so we can make them better. For example, cookies are used to gather information about the pages you visit and how many clicks you need to accomplish a task. We also use some analytics cookies to provide personalized advertising. |
Social Media | Neway and third parties use social media cookies to show you ads and content based on your social media profiles and activity on Neway’s websites. This ensures that the ads and content you see on our websites and on social media will better reflect your interests. This also enables third parties to develop and improve their products, which they may use on websites that are not owned or operated by Neway. |
Advertising | In addition, Neway and third parties use advertising cookies to show you new ads based on ads you've already seen. Cookies also track which ads you click or purchases you make after clicking an ad. This is done both for payment purposes and to show you ads that are more relevant to you. For example, cookies are used to detect when you click an ad and to show you ads based on your social media interests and website browsing history. |
You have several options to disable non-essential cookies:
Specifically on Neway Enterprise Marketing Pages
Any Neway page that serves non-essential cookies will have a link in the page’s footer to cookie settings. You can express your preferences at any time by clicking on that linking and updating your settings.
Some users will also be able to manage non-essential cookies via a cookie consent banner, including the options to accept, manage, and reject all non-essential cookies.
Generally for all websites You can control the cookies you encounter on the web using a variety of widely-available tools. For example:
These choices are specific to the browser you are using. If you access our Services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
This section provides extra information specifically for residents of certain US states that have distinct data privacy laws and regulations. These laws may grant specific rights to residents of these states when the laws come into effect. This section uses the term “personal information” as an equivalent to the term “Personal Data.”
These rights are common to the US State privacy laws:
We may collect various categories of personal information about our website visitors and users of "Services" which includes Neway applications, software, products, or services. That information includes identifiers/contact information, demographic information, payment information, commercial information, internet or electronic network activity information, geolocation data, audio, electronic, visual, or similar information, and inferences drawn from such information.
We collect this information for various purposes. This includes identifying accessibility gaps and offering targeted support, fostering diversity and representation, providing services, troubleshooting, conducting business operations such as billing and security, improving products and supporting research, communicating important information, ensuring personalized experiences, and promoting safety and security.
To make an access, deletion, correction, or opt-out request, please send an email to Clyde.he[at]newayprecision[dot]com and follow the instructions provided. We may need to verify your identity before processing your request. If you choose to use an authorized agent to submit a request on your behalf, please ensure they have your signed permission or power of attorney as required.
To opt out of the sharing of your personal information, you can click on the "Do Not Share My Personal Information" link on the footer of our Websites or use the Global Privacy Control ("GPC") if available. Authorized agents can also submit opt-out requests on your behalf.
We also make the following disclosures for purposes of compliance with California privacy law:
Under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by emailing (Clyde.he[at]newayprecision[dot]com). Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please submit a Private Information Removal request. Alternatively, to request that we remove such content or information, please send a detailed description of the specific content or information you wish to have removed to Neway support. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances. If you have any questions about our privacy practices with respect to California residents, please send an email to Clyde.he[at]newayprecision[dot]com.
We value the trust you place in us and are committed to handling your personal information with care and respect. If you have any questions or concerns about our privacy practices, please email our Data Protection Officer at Clyde.he[at]newayprecision[dot]com.
If you live in Colorado, Connecticut, or Virginia you have some additional rights:
We do not sell your covered information, as defined under Chapter 603A of the Nevada Revised Statutes. If you still have questions about your covered information or anything else in our Privacy Statement, please send an email to Clyde.he[at]newayprecision[dot]com.