Welcome to the New Heritage Capital website. With this privacy notice (“Privacy Notice”), New Heritage Capital, LLC (“we”, “us,” “our”) informs you of the collection, use and protection of your information, including individuals who use our website (https://www.newheritagecapital.com), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, job applicant, representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Notice.  Please note that the Services are designed for users in the United States only and are not intended for users located outside the United States.

If you are an investor and you wish to know more about the information we collect and use about you (e.g., through our investor portal), you are kindly referred to our privacy notice for investors, which is accessible through the investor portal.

Please read this Privacy Notice carefully.  By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice.  If you do not agree to this Privacy Notice, please do not use or access the Services.

1.  CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law.  If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF YOUR INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. 

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

  • Basic contact details, such as name, address, phone number, and email. We use this information to communicate with you (including to tell you about products or services that may be of interest to you).
  • Applicant details, such as information included in your resume or CV, references, and job history. We use applicant details to process your application for employment and to evaluate your candidacy.
  • Any other information you choose to include in communications with us, for example, when send us a message or fax.

Information We Collect Automatically

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies or other tracking technologies (“Tracking Technologies”). Usage Data includes:

  • Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
  • Location information, such as approximate location.
  • Other information regarding your interaction with the Services, such as browser type, log data and date and time stamps.

We use Usage Data to run analytics and better understand user interaction with the Services. For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources 

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

  • Analytics data we receive from analytics providers such as Google Analytics.
  • Information we receive from career websites, such as LinkedIn, Monster, or Indeed, which we use to process your application for employment.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

To opt out of tracking by Google Analytics, click here.

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites.  Like many websites, our website is not designed to respond to such signals, and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference signals. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. 

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties: 

  • Our affiliates or others within our corporate group.
  • Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
  • Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration.
  • Professional advisors, such as auditors, law firms, or accounting firms.
  • Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

5. SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third Party Websites and Links.

6. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms.  We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7. CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

8. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information. 

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

9. CALIFORNIA RESIDENTS

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information

In the preceding 12 months, we collected and disclosed the following categories of personal information about residents:

  • Identifiers such as name, e-mail address, IP address.
  • Personal information categories listed in the California Customer Records statute such as name, address, telephone number.
  • Internet or other similar network activity such as information regarding your interaction with the website.
  • Geolocation data such as IP address.
  • Professional or employment-related information such as title of profession, employer, professional background.
  • Non-public education information collected by certain federally funded institutions such as education records.

The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, Collection and Use Your Information. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the section above, Data Security and Retention. 

We disclosed personal information over the preceding 12 months for the following business or commercial purposes:  

  • to communicate with you
  • to evaluate your candidacy and process your application for employment.  

Selling and/or Sharing of Personal Information 

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information: 
    • categories of personal information we have collected, disclosed for a business purpose; 
    • categories of sources from which we collected personal information; 
    • the business or commercial purposes for collecting personal information; 
    • categories of third parties to whom the personal information was disclosed for a business purpose; and 
    • specific pieces of personal information we have collected.

  • Right to Delete. You have a right to request that we delete personal information we maintain about you. 
  • Right to Correct. You have a right to request that we correct inaccurate personal information we maintain about you. 

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your investor portal access credentials before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at admin@newheritagecapital.com or contact us by mail at New Heritage Capital, Prudential Tower, 800 Boylston Street, Suite 2200, Boston, MA 02199 or by phone at (617) 439-0688.

Last Updated: January 2025

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