Privacy Policy

Data Privacy and Website Policy

Effective Date: 5th of June 2013, Amended 22nd of September 2016

What is this Policy?

Newton Consulting, LLC and its affiliates (collectively, “Newton”) acknowledge and respect the importance of protecting the privacy of personal data (“Personal Data”) collected by us.  Newton collects and uses Personal Data to provide world-class services for our employees, clients and partners.  This Policy is designed to set forth how Newton will handle Personal Data that it collects in the normal course of business.  Newton strives to be global and consistent in how it handles personal data.

Our privacy policy applies to:

  1. All individuals who provide personal information, such as consumers, customers, research subjects, business partners, members, job applicants, employees, retirees and others;
  2. All locations where we operate, even where local regulations do not exist; and
  3. All methods of contact, including in person, written, via the Internet, direct mail, telephone, or facsimile.

Newton has in the past received the U.S.-EU Safe Harbor self-certification.  This Policy describes Newton’s standard global procedure governing access to and use of Newton Personal Data across borders.  Newton has submitted this policy for review under the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Newton self-certifies that it adheres to the Privacy Shield Principles, including the seven commonly recognized principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

This Policy does not necessarily describe how local management may handle personal data in order to comply with local privacy laws.  Local management in conjunction with the responsible human resources manager(s) will be responsible for accessing and complying with local/unique laws and/or rules regarding the processing of personal information in that particular locale.

This Policy is also designed to inform all employees about their obligation to protect the privacy of all individuals (whether co-employees, independent contractors, or sub-contractors) and the security of their personal information.  The violation of this Policy, whether negligent or intentional, may be subject to disciplinary action by Newton.

Scope

This is a Global Policy.  Newton will extend the protection of the Privacy Shield Principles to all personal data originating outside of the United States, which is transferred to Newton facilities in the United States.  Outside of the United States, Newton facilities are required to comply with this Policy as well as the privacy laws in force in their local jurisdictions.

Affiliates

Our affiliates who may receive Personal Data as described within this Policy are: Newton Talent; Newton Institute, LLC; Newton Enterprise, Ltd.; Center for Serving Leadership.

Each of those affiliates is committed to complying with the EU-U.S. Privacy Shield Framework Principles, including the Supplemental Principles.

DEFINITIONS

Personal Data:  Information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

Sensitive Data:  Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that information that concerns an individual’s health.

Privacy Shield Principles (the “Principles”): The seven principles (notice; choice; accountability for onward transfer; data security; data integrity and purpose limitation; access; and resource, enforcement, and liability) issued by the Department of Commerce to diminish data privacy uncertainty and provide a more predictable framework for data transfers.

Policy

This privacy policy outlines Newton’s general policy and practices for implementing the Principles, including the types of information Newton gathers, how Newton uses it and the notice and choice affected individuals have regarding Newton’s use of and their ability to correct that information.  The following are the details of the coverage of Newton’s privacy program.

  1. Any information Newton obtains is used only for specified and lawful purposes in the performance of the services for which Newton has been engaged.
  2. Newton only asks for information that is reasonably adequate, relevant, and not excessive to allow Newton to perform the services for which Newton has been engaged.
  3. Newton maintains information accurately and where necessary takes steps to maintain and/or ensure its accuracy.
  4. Newton processes information in accordance with individual rights (which are detailed below) and by the explicit permissions given to Newton to use individual data on their behalf.
  5. Newton keeps data in secure locations.

To ensure the privacy of Personal Data, Newton has implemented measures to address the Principles.

Seven Principles

Notice

Excluding our Employee Information, which is detailed below, Newton processes and uses your Personal Data only as part of our business relationship with you and/or your company; including contract and billing administration; fulfilling business obligations to you and/or your company; marketing communications; and other business-related activities of which you are informed of at the time your Personal Data is collected or as soon thereafter as is practical.  We may be required to disclose Personal Data to our agents, contractors, vendors, and business partners or to protect and defend the rights or property of Newton.  Newton must reply to lawful requests from law enforcement for disclosure of Personal Data.

Newton does not sell, lease or rent Personal Data to third parties.

Online Information.

In general, you may visit the Newton Site without providing any Personal Data.  However, you may choose to provide us with Personal Data by completing online forms.  At the point of collection, we will inform you of how your Personal Data will be used; apart from these uses, Newton will only use Personal Data in accordance with the terms of this Policy.  We use a third-party vendor, Constant Contact, Inc. (“Constant Contact”) to collect email and other address information.  Constant Contact’s privacy policy is located at: http://www.constantcontact.com/legal/privacy-statement and Constant Contact utilizes Model Clauses to facilitate the transfer of personal information from European Union member countries to the United States.  We collect Personal Data about from those who provide their information through the Constant Contact information form (the “Form”).   In certain areas of the Form, we require that you provide us with Personal Data, in order to be able to use that portion or those portions of the site.

Employment Applications.

Internal:

We use a third-party vendor, MyStaffingPro, a Paychex, Inc. company (“MSP”) to track applications for Newton roles.  Their privacy policy is located http://www.paychex.com/corporate/privacy.aspx.  We collect personally identifiable information about applicants who provide their information through the employment application portal (the “Portal”).  In certain areas of the Portal, we require that you provide us with personally identifiable information, in order to be able to use that portion or those portions of the site.

External:

We use a third-party vendor, CATS Software, Inc. (“CATS”) to track employee applications for our clients.  Their privacy policy is located at: http://www.catsone.com/privacy-policy.  We collect personally identifiable information about applicants who provide their information through the employment application portal (the “Portal”).  In certain areas of the Portal, we require that you provide us with personally identifiable information, in order to be able to use that portion or those portions of the site.

Employee Information.

Newton collects Employee Data from prospective and present employees only for legitimate business purposes, including the administration of insurance benefits.  Our European Union employees, at the time of their employment, are notified in detail how their Personal Data will be used.  Employee Data on health, performance evaluations, and disciplinary actions, as well as other sensitive employee matters, is accessible by other Newton employees or third party agents only if necessary with respect to legitimate human resource functions or issues.

An employee may choose to provide a picture and other Personal Data to be placed on the Newton intranet.  New employees may decline to provide this consent, and all employees may withdraw their consent to such publications at any time.

For legitimate human resource purposes, employees may choose to voluntarily disclose Personal Data about family members.  If an employee chooses to do so, their family member’s Personal Data shall be treated, for the purposes of this Policy, the same as an employee’s Personal Data.  Unless otherwise noted or excluded by context, “Employee Data” is included within the definition of “Personal Data” for the purposes of this Policy.  Employee Data is never sold, leased, or rented to a third party.  Employee Data will never be disclosed to third parties, except as follows: (1) to those retained by Newton for processing only for the purposes set forth above; (2) where required pursuant to an applicable law, governmental, or judicial order, law or regulation, or to protect the rights or property of Newton; (3) where authorized in writing by the Employee; (4) where the Employee voluntarily provides Personal Data and the context makes it clear that Employee Data will be provided to a third party; and/or (5) Employee resumes/bios may be provided to Clients or prospective Clients.

Newton may require certain Employees and applicants to maintain a resume or bio, including name, title, education, and areas of expertise.  These resumes or bios may be provided to Clients or prospective Clients of Newton in support of Newton’s efforts to secure new and/or continuing business. Where Personal Data is transferred from the EU to the US in the context of the employment relationship, we will cooperate in investigations by and to comply with the advice of the competent EU Authorities.

Choice

Newton will offer individuals the opportunity to choose (opt out) whether their Personal Data is (1) disclosed to a third party (other than a Newton agent) or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.  Although, we do not anticipate disclosing Sensitive Data to a non-agent third party, Newton will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.  The only exception to this choice for both sensitive and non-sensitive Personal Data would be a situation where we are required to disclose Personal Data pursuant to governmental or judicial order, law, or regulation.

At a minimum, you will be able to opt-out from receiving marketing materials.  If we determine that applicable national law requires more stringent requirements (opt-in), those will be applied.

Accountability for Onward Transfer

Newton will not transfer Personal Data originating in the EU to a third-party agent, unless the agent has entered into an agreement with Newton requiring that Personal Data be protected in accordance with the Principles.  Personal Data will only be transferred for limited and specific purposes.  We acknowledge our liability for such data transfers to third parties.

Transfer of Personal Data originating in countries outside the EU will be conducted according to the laws of the countries from which the Personal Data is being transferred.

Data Security

Newton shall take reasonable steps to protect information from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Newton has put in place appropriate physical, electronic and managerial procedures to safeguard and secure information from loss, misuse, unauthorized access or disclosure, alteration or destruction.  Newton cannot guarantee the security of information on or transmitted via the internet.

Data Integrity and Purpose Limitation

Newton shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.  To the extent necessary for those purposes, Newton shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

Access

If you wish to access, amend, or confirm that Newton has Personal Data relating to you, or if you wish to correct or delete your Personal Data if it is inaccurate, please notify us at: legal@newtonconsulting.com. We will respond to your request within a reasonable time.

Employees may review their personnel files and any Personal Data concerning them upon request.

Recourse, Enforcement, and Liability

Newton uses a self-assessment approach to assure compliance with this privacy policy and annually verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the principles.  Any Newton employee who violates this Policy will be subject to disciplinary action up to and including termination of employment.

We encourage individuals to raise any concerns and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data in accordance with the Principles.  Please contact us at legal@newtonconsulting.com – we will investigate your compliant, take appropriate action and report back to you within forty-five (45) business days.

If a complaint or dispute cannot be resolved through our internal process, we agree to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (“DPA’s”) to resolve disputes pursuant to the Principles.  The EU DPA’s may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. Newton will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints brought under the EU-U.S. Privacy Shield.

These recourse mechanisms are available at no cost to you.  Damages may be awarded in accordance with applicable law.  Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

Will there be Amendments to this Policy?

 We may amend this Policy at any time by posting the amended terms on the Newton Site.  All amended terms shall be effective immediately upon posting.  We encourage you to periodically review this page for the latest information on our privacy practices. In case of the sale of the company, acquisition or merger, bankruptcy, or other change in corporate status, this Policy could change.  In addition, other company policies and statements may supplement this Policy.

How to Contact Us?

If you have any questions or suggestions regarding our privacy policy, you may contact us at legal@newtonconsulting.com or via postal mail at 4632 State Route 40, Suite 200, Claysville, PA 15323, Attn: Legal.


Website and Cookies Policy

Newton respects the privacy of our employees, customers, contractors and visitors to our Web sites:

(collectively, the “Newton Site”).  While offering our web site users the advantages and convenience of web-based technologies, we also strive to employ practices that ensure information collected about affiliates, customers, and visitors is used conscientiously and appropriately.  Information obtained and shared with you through the Newton site is our confidential information unless expressly indicated otherwise.

By visiting this website, you agree to be bound by the terms and conditions of this Cookies Policy (the “Policy”).  If you do not agree, please do not use or access the Newton Site.  By accepting the Policy, you expressly consent to our use and disclosure of your personal information in accordance with this Policy.

This Privacy Policy outlines the use of personally identifiable information collected on the Newton Site.  The Newton Site contains links to third-party web sites.  This privacy notice does not encompass other Web Sites referenced by us in print, online, or in e-mail.  We do not own, operate or control the web sites of our third party service providers.  Accordingly, this Policy does not apply to a third party website or to a third party service provider’s collection, use, storage, and disclosure of your personal information.

When you click on those links to third-party websites, you will go to a third-party site where you will be subject to that site’s privacy statement and we encourage you to read that policy.  Please be aware that we are not responsible for the privacy practices of those other websites and we expressly disclaim any liability for their actions, including any actions that relate to the use and disclosure of Personal Information.

What information is collected on the Newton Site?

Generally, information is used to help us better serve our employees, affiliates and customers.

Google Analytics: 

Google Analytics is a web analytics tool that helps website owners understand how visitors utilize and engage with their website.  Google Analytics customers can view a variety of reports about how visitors interact with their website so they can improve it.  Google Analytics collects this information anonymously.  Google Analytics reports website trends without identifying individual visitors.

All website owners using Google Analytics are required to have a privacy policy that discloses the use of Google Analytics.  This website uses Google Analytics.

Google Analytics uses first-Party cookies to track visitor information.  These cookies are used to store information, such as the time the current visit occurred, if the visitor has been to the site before, and what site, if any, referred the visitor to the web page.  Browsers do not share first-party cookies across domains.

Every computer and device connected to the Internet is assigned a unique number known as an Internet protocol (“IP”) address.  Since these numbers are usually assigned in country-based blocks, an IP address can often be used to identify the country, state, and city from which a computer is connecting to the Internet.  Google Analytics collects the IP address of website visitors in order to provide website owners a feeling of where their website visitors are located.  This method is known as IP geolocation.

Google Analytics does not report the actual IP address information to Google Analytics customers.  Additionally, using a method known as IP masking, website owners that use Google Analytics have the option to tell Google Analytics to only use a portion of the IP address, rather than the entire IP address, for geolocation.  Whether or not website owners use Google Analytics, they have access to IP addresses for visitors to their site.

Personal Information is information that personally identifies you, such as your name, email address, or billing information, or other data, which can be reasonably linked to such information.  The Google Analytics Terms of Service, which all analytics customers must adhere to, prohibits the tracking or collection of this information using Google Analytics or associating personal information with web analytics information.  This website does not utilize Google Analytics to collect any personal information.

Employment Applications:

Internal:

We use a third-party vendor, MyStaffingPro, a Paychex, Inc. company (“MSP”) to track applications for Newton Consulting roles.  Their privacy policy is located http://www.paychex.com/corporate/privacy.aspx.  We collect personally identifiable information about applicants who provide their information through the employment application portal (the “Portal”).  In certain areas of the Portal, we require that you provide us with personally identifiable information, in order to be able to use that portion or those portions of the site.

External:

We use a third-party vendor, CATS Software, Inc. (“CATS”) to track employee applications for our clients.  Their privacy policy is located at: http://www.catsone.com/privacy-policy.  We collect personally identifiable information about applicants who provide their information through the employment application portal (the “Portal”).  In certain areas of the Portal, we require that you provide us with personally identifiable information, in order to be able to use that portion or those portions of the site.

Do we use “Cookies”?

A “cookie” is a packet of information that a Web server sends to a user’s computer to identify that specific user the next time he or she visits the site.  Our use of “cookie” technology is restricted to tracking by Google Analytics and as used by MSP, CATS, and Constant Contact.  By using our website, you explicitly agree to our use of cookies.

How do I turn off “Cookies”?

Changing your browser’s settings so that it will not accept cookies may restrict the functionality of the Newton Site.  If you wish to change your cookies settings, please follow the steps below for select browser instruction:

Internet Explorer:

  1. Click the tools button and then click Internet Options.
  2. Click the Privacy tab, then under Settings, move the slider to the top to block all cookies or to the bottom to allow all cookies.
  3. Then click OK.

Google Chrome:

  1. Select the Chrome menu icon .
  2. Select Settings.
  3. Near the bottom of the page, select Show advanced settings.
  4. In the “Privacy” section, select Content settings.
  5. Select Block sites from setting any data to turn off cookies (select Allow local data to be set to turn on cookies).
  6. Select Done.

Firefox:

  1. In the top Firefox window, click on the Firefox button and then click Options
  2. Select the Privacy panel
  3. Set Firefox will: Use custom settings for history.
  4. Check mark Accept cookies from sites to enable cookies and Uncheck it to disable them.
  5. Click OK.

Safari:

  1. Go to the Safari pull down menu.
  2. Select Preferences.
  3. Select Privacy
  4. Under “Cookies and Website data”, set it to always block, allow from current website only, allow from websites I visit, or always allow.

Will there be Amendments to this Policy? 

We may amend this Policy at any time by posting the amended terms on the Newton Site.  All amended terms shall be effective immediately upon posting.  We encourage you to periodically review this page for the latest information on our privacy practices. In case of the sale of the company, acquisition or merger, bankruptcy, or other change in corporate status, this Policy could change.  In addition, other company policies and statements may supplement this Policy.

How to Contact Us?

If you have any questions or suggestions regarding our privacy policy, you may contact us at legal@newtonconsulting.com or via postal mail at 4632 State Route 40, Suite 200, Claysville, PA 15323, Attn: Legal.