Privacy Policy
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New Start Capital LLC (“New Start Capital”) is committed to protecting the privacy of confidential and personal information (“Personal Information”), such as information that directly or indirectly identifies individuals and includes but is not limited to the categories of information described below in “Our Collection of Information” from clients, prospective clients and other sources.
This Privacy Policy is intended to summarize New Start Capital’s data protection practices generally, and to advise our clients, job applicants, website visitors and other third parties about New Start Capital’s privacy policies that may be applicable to them. This Privacy Policy is also specifically addressed to parties outside New Start Capital, including our clients and prospective clients who provide Personal Information to New Start Capital. This Privacy Policy covers persons who visit or use New Start Capital’s website and/or our social media sites and correspond with us by email, including messages that we may send to you containing a link to this Privacy Policy (collectively, “Internet Communications”). This Privacy Policy also describes how New Start Capital collects, uses, discloses and secures Personal Information obtained in connection with the provision of its services and Internet Communications (referred to together as the “Services”).
Collection, Use and Disclosure of Personal Information
New Start Capital collects Personal Information in the course of providing its services to our clients and prospective clients and as provided by visitors to our website and/or others who engage with us in Internet Communications. We may also collect Personal Information about you when you interact with us through Internet Communications and from third parties as described below.
Our Collection of Personal Information
By providing Personal Information to us, you are consenting to and expressly authorizing our collection of Personal Information such as the following:
- Information we receive from and/or about you, such as your name, dba(s), address, telephone number, email and social media addresses, date of birth in the case of individuals, credit card information, Employer Identification Number (“EIN”), Social Security number (“SSN”); and including, without limitation, other information that you provide to us online, via email, over the phone or in documents, applications and otherwise.
- Information about your financial, loan, debt and other related transactions, including without limitation, your income, expenses, account balances with your creditors, accounts with financial services companies, loan and payment histories, account activity, and other information provided to us by you or that may be contained in your credit card statements or other reports relating to your debts and any and all other financial information concerning you.
- Information we receive from entities such as the Better Business Bureau, Yelp, consumer reporting agencies and other sources, such as your credit bureau reports, collection agency reports or other communications, and other information relating to your payment histories, creditworthiness, annual income, expenses and/or ability to satisfy your obligations. In this regard, you expressly authorize us to access, obtain and use any information contained in all of the foregoing resources and credit reports.
Our Use of Personal Information
By providing Personal Information to us, you are consenting to and expressly authorizing us to use your Personal Information in a variety of ways, including, but not necessarily limited to, the following:
- To perform our Services for you and/or on your behalf.
- To develop and maintain a full picture of your financial status, including your credit-worthiness.
- To offer additional services to you.
We may use the Personal Information we acquire from you for any or all of the following purposes:
- to contact you and respond to your requests and inquiries
- to personalize your visit and use of our Services and to assist you while you use those Services
- to carry out, monitor and analyze our business or website operations
- to conduct our recruiting and selection process
- to provide you with Services, if you are or become a client of New Start Capital, and otherwise deal with you, and administer the matters you instruct us on
- to contact you regarding developments that may be of interest to you
- to enter into or carry out contracts of various kinds
- to comply with applicable laws, regulations, guidance or professional obligations that we may be subject to, including anti-money laundering requirements. Where Personal Information is necessary for New Start Capital to carry out its anti-money laundering obligations, failure to provide such information may result in New Start Capital not being able to provide the Services.
Our Disclosure of Personal Information
By providing Personal Information to us, you hereby consent to and expressly authorize New Start Capital, as we see fit in our sole discretion to the full extent permitted by law, to disclose and share your Personal Information to certain third-party individuals or entities, including, but not necessarily limited to, the following:
- Our service providers and related individuals and entities, including, but not limited to, independent contractors, marketing services providers, and other entities and individuals as necessary to effect, administer and perform our Services.
- Third parties such as law enforcement in connection with detecting and protecting against fraud, or in response to a criminal or civil subpoena, or as otherwise required by applicable Federal, State or local laws.
Notice Regarding Your Right to Opt-Out
It is important for you to understand that you have the right to affirmatively opt-out of your authorization of New Start Capital’s sharing of your Personal Information
However, you are not permitted to opt-out from our making use of or sharing your Information in the following circumstances:
- Information-sharing that is necessary for processing or administering a financial transaction requested or authorized by you.
- Information-sharing with service providers that perform business operations for us and companies that act on our behalf to market our Services.
- Information-sharing with your creditors, servicers, collectors and other entities and individuals specifically necessary to affect, administer and perform our Services and your transactions with us.
- Information disclosures for purposes of preventing fraud, responding to judicial process or a subpoena, or complying with federal, state, or local laws.
- Information-sharing and/or transfer in the event we sell or transfer your account or our business assets to another person or entity.
Please note that your opt-out will not be effective unless and until you affirmatively advise us that you wish to opt-out by sending an e-mail to [email protected] and notifying us that you wish to opt-out from such sharing.
Please also note that, unless we receive your opt-out within thirty (30) days of our providing this Policy to you, we will proceed with sharing your Information with non-affiliated third parties as set forth above unless and until we receive an opt-out instruction from you.
Confidentiality, Security, and Retention of Personal Information
It is New Start Capital’s policy to exercise the utmost discretion regarding the information our clients entrust to us. We maintain reasonable and appropriate, albeit not infallible, physical, electronic and procedural safeguards intended to maintain the confidentiality of Personal Information, including that provided by visitors to our website and provided while using our Services. We do not guarantee that our safeguards will always work.
We also require our consultants, suppliers and vendors to maintain data security protections consistent with reasonable and appropriate obligations of data processors, including, where applicable, data protection laws and regulations.
We may retain information provided by you, including Personal Information, for as long as necessary to comply with our legal obligations, or to achieve the purposes for which the information was originally collected and for the purposes described in this Privacy Policy and in our applicable policies.
Log Files
New Start Capital follows a standard procedure of using log files on its website. These files log visitors when they visit websites. All hosting companies do this as a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
Children’s Information
New Start Capital does not knowingly collect any Personal Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Third Party Privacy Policies
Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on New Start Capital’s website, which are sent directly to the users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that New Start Capital has no access to or control over any such cookies that may be used by third-party advertisers.
New Start Capital’s Privacy Policy does not apply to other advertisers or websites. Thus, you should consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You may find a complete list of these Privacy Policies and their links here: Privacy Policy Links.
You can choose to disable cookies through your individual browser options. To learn more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
For California Residents
Pursuant to California’s “Shine the Light” Law, if you wish to opt out from having your Personal Information shared with any third parties for direct marketing purposes, you may do so by sending an e-mail to [email protected] and notifying us that you wish to opt-out from such sharing.
Our website does not honor any “Do Not Track” signals that are provided by user’s browsers. However, we do not collect or authorize the collection by any third party of any nonpublic personally identifiable information about an individual consumer’s online activities over time and across different Web sites or online services.
Our Website uses Google Analytics, a web analytics tool provided by Google, Inc. (“Google”) that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with our Website so we can improve it. Google Analytics collects information anonymously. Google uses cookies and IP addresses, and it reports website trends without identifying individual visitors. For more information related to Google Analytics, click here:
http://www.google.com/analytics/learn/privacy.html.
You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-On. For information about and to install Google Analytics Opt-out Browser Add-on, go to:
https://tools.google.com/dlpage/gaoptout?hl=en.
For Nevada Residents
We are providing you this notice pursuant to state law. You may be placed on our internal “do not call” list by calling (888) 535-5560. Nevada law requires that we also provide you with the following contact information:
Bureau of Consumer Protection,
Office of the Nevada Attorney General,
555 E. Washington St.,
Suite 3900,
Las Vegas, NV 89101
Phone: 702‐486‐3132
Email: [email protected].
For Vermont Residents
In accordance with Vermont law, we will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent but we may share information about our transactions or experiences with our affiliates without your consent.
Changes
We reserve the right to change this Privacy Policy at any time with or without advance notice. Should any new policy go into effect for our Services, New Start Capital will post the updated Privacy Policy on its website and take any other steps it deems reasonable.
Contact Us
If you have any questions relating to our use of your Personal Information, please contact us at [email protected].
Last Updated: 4/12/2024