PRIVACY POLICY

This Privacy Policy ("Privacy Policy") governs the privacy practices of New World Web Solutions Holdings LLC and its parents, subsidiaries, and affiliated entities (collectively, "Company," "New World Web Solutions," "we," "us," or "our"). This Privacy Policy applies to all personal information and data collected, processed, stored, or transmitted through our websites, user portals, administrative dashboards, software applications, artificial intelligence tools, digital marketing systems, and online services (collectively, the "Services").

By accessing, browsing, subscribing to, or using our Services, or by submitting information to us, you ("Client," "User," or "you") acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms and Conditions of Service.

1. GENERAL STRUCTURE AND CONTROLLER/PROCESSOR ROLES

Under applicable privacy statutes, the legal role regarding data processing depends on the context of the interaction:

• Company as Data Controller: The Company acts as a Data Controller with respect to personal information collected directly from visitors, prospective clients, and users of our public websites, portal accounts, and billing interfaces. This includes information provided during registration, contact submissions, account setup, payment processing, and direct business communications.
• Company as Data Processor: When providing managed digital services, CRM administration, client portals, AI workflows, or digital marketing tools, the Company acts as a Data Processor executing instructions on behalf of our business clients (the Data Controller). In such scenarios, processing is governed by our client agreements, applicable Orders, and our integrated Data Processing Agreement (DPA).

2. INFORMATION WE COLLECT

We collect information from and about users through direct submissions, automated technologies, and third-party integrations.

A. Information You Provide Directly to Us

• Contact & Account Information: Full name, business name, job title, email address, physical mailing address, telephone number, and account login credentials.
• Billing & Payment Details: Payment card numbers, bank account details, billing addresses, and transaction histories. (All electronic payment card processing is securely managed by PCI-compliant third-party payment processors.)
• Business & Client Data: Brand assets, creative materials, campaign strategies, customer lists, API keys, administrative access credentials, and operational records submitted to fulfill our Scope of Services.
• Communications & Feedback: Inquiries submitted via online forms, email correspondence, customer support tickets, phone recordings, and survey responses.

B. Information Collected Automatically

When you interact with our websites, software portals, and digital interfaces, we automatically collect technical usage data via cookies, web beacons, server logs, and analytics scripts:

• Device & Network Data: IP address, operating system, browser type, device identifiers, domain servers, and hardware characteristics.
• Usage & Browsing Metrics: Pages viewed, time spent on pages, clickstream data, referring websites, bounce rates, navigation paths, and platform interaction logs.
• Location Data: Non-precise geographic location inferred from your IP address.

C. Information Received from Third Parties

We may receive information about you or your business from third-party sources, including advertising networks, public business registries, joint marketing partners, identity verification services, and integrated Third-Party Vendors and Tools.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for legitimate commercial and business purposes, including:

• Delivering and Managing Services: Provisioning accounts, setting up websites, executing digital advertising campaigns, hosting platforms, deploying AI workflows, configuring CRMs, and performing technical support.
• Payment & Order Processing: Processing transactions, managing recurring billing subscriptions, verifying account details, and enforcing our payment and chargeback policies.
• Communication & Support: Responding to inquiries, delivering operational alerts, sending system notices, providing customer support, and transmitting administrative communications under Section 12 of our Terms.
• System Security & Performance Optimization: Monitoring technical performance, patching vulnerabilities, preventing cyberattacks, verifying user credentials, detecting fraudulent activity, and ensuring system availability.
• Analytics & Business Development: Analyzing aggregate usage trends, evaluating campaign performance, enhancing user interfaces, and refining our service offerings.
• Legal & Regulatory Compliance: Enforcing our Terms and Conditions of Service, complying with tax and accounting obligations, responding to valid legal process, and defending against legal or financial claims.

4. COOKIES, TRACKING TECHNOLOGIES, AND ANALYTICS

We utilize standard tracking technologies, including session/persistent cookies, web beacons, tracking pixels, and software development kits (SDKs), to operate and optimize our digital platforms.

• Essential Cookies: Necessary for account authentication, security, load balancing, and portal access.
• Functional & Preference Cookies: Remember user configurations, language choices, and administrative preferences.
• Analytics Cookies: Track site activity, user movement, and engagement performance using tools such as Google Analytics to help us evaluate and improve site usability.
• Marketing & Advertising Pixels: Measure advertising effectiveness and deliver targeted promotions across third-party social media and search networks (e.g., Google, Meta).

Managing Cookie Settings: Most web browsers allow you to manage or disable cookies through browser settings. Disabling essential cookies may impair the functionality or accessibility of certain portals and Services.

5. DISCLOSURE OF YOUR INFORMATION

We do not sell, rent, or lease your personal information to third parties. We disclose personal information solely under the following circumstances:

• Third-Party Vendors, Sub-Processors, and Trade Partners: We share information with trusted third-party technology providers, host servers, cloud platforms, CRM software vendors, analytics providers, payment gateways, and specialized fulfillment contractors who perform operational functions on our behalf under strict confidentiality obligations.
• Corporate Affiliates: We may share information with parent entities, subsidiaries, or legal affiliates to support business operations, administrative workflows, and integrated service delivery.
• Legal Requirements & Law Enforcement: We may disclose information if required to do so by applicable law, court order, subpoena, administrative warrant, or statutory mandate, or when necessary to protect the rights, property, and safety of the Company, our clients, or the public.
• Business Transfers: In the event of a merger, acquisition, corporate reorganization, asset sale, financing transaction, bankruptcy, or insolvency, client records and operational data may be transferred to an acquiring entity or corporate successor as part of the asset transfer.
• With Your Explicit Consent: We may share information for specific purposes when explicitly directed or authorized by you.

6. ARTIFICIAL INTELLIGENCE, AUTOMATION, AND DATA BOUNDARIES

In providing AI Search Visibility, AI Systems, automated agents, prompt engineering, and document intelligence workflows:

• Supervision & Client Input: The Company processes data and prompts supplied by clients to build custom AI workflows, agents, and automations. Client Data submitted into proprietary or enterprise AI tools is managed in accordance with secure API guidelines.
• No Public AI Training: As affirmed in Section 29 of our Terms and Conditions of Service, the Company does not sell Client Data or use proprietary Client Data to train public, unencrypted third-party AI models.
• Supervision Obligation: Clients remain legally responsible for auditing, testing, and verifying all AI-generated outputs, chatbot communication streams, and automated messages before public distribution.

7. DATA SECURITY MEASURES

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, destruction, loss, alteration, or disclosure. These safeguards include encrypted data transmissions (SSL/TLS), firewalls, access control protocols, multi-factor authentication requirements, and secure credential management practices.

Security Disclaimer: While we enforce commercial security controls, no internet transmission, database, cloud server, or electronic storage system is 100% secure. In accordance with Section 17 of our Terms, we cannot guarantee absolute protection against unauthorized access, hacking, malware, or data breaches. Users are responsible for maintaining the security of their own account credentials and passwords.

8. DATA RETENTION AND PURGE SCHEDULES

We retain personal information and Client Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, complete active project scopes, comply with accounting and tax standards, enforce contractual agreements, and resolve legal disputes.

• Post-Termination Retention: Following contract termination, account cancellation, or service suspension, we maintain and purge records in accordance with internal schedules.
• Client Backup Responsibility: Pursuant to Section 31 of our Terms, clients are strictly responsible for exporting or downloading all business data, customer lists, content, and website assets prior to account termination. Following thirty (30) calendar days from termination, we have no obligation to maintain, export, or restore client files. Automated system backups are subject to a standard scheduled 35-day purge cycle.

9. THIRD-PARTY LINKS AND EXTERNAL PLATFORMS

Our websites and portals may contain links to third-party websites, external software applications, plugins, ad platforms, and digital directories (such as Google, Meta, Yelp, and payment processors). This Privacy Policy applies strictly to our own platforms and Services. We have no control over, and assume no legal responsibility for, the privacy practices, content, security, or data collection policies of any third-party website or application. We encourage you to review the privacy policies of any third-party service you visit or interact with.

10. COMMUNICATIONS AND COMPLIANCE (CAN-SPAM & TCPA)

By using our Services or submitting information, you consent to receive electronic communications, emails, portal updates, and phone/SMS notifications regarding your account, active services, billing, and system operations in accordance with Section 12 of our Terms.

• Email Marketing Opt-Out: You may unsubscribe from promotional email communications at any time by clicking the "Unsubscribe" link located at the bottom of our marketing emails. Transactional, billing, and service-related communications necessary for contract execution will continue regardless of marketing preferences.
• TCPA & SMS Opt-Out: You may opt out of receiving automated SMS marketing messages at any time by replying "STOP" to any text message received.
• Client TCPA Warranties: When using our CRM, automated communication tools, or lead capture platforms, clients represent and warrant that all uploaded contact numbers and customer lists were gathered in full compliance with the Telephone Consumer Protection Act (TCPA), CAN-SPAM Act, and applicable state privacy laws.

11. CHILDREN'S PRIVACY

Our Services are designed exclusively for commercial entities and individuals who are at least eighteen (18) years of age. The Company does not knowingly solicit or collect personal information from children under sixteen (16) years of age. If we learn that we have inadvertently collected personal data from a minor without verified parental consent, we will take immediate steps to delete that information from our active databases.

12. YOUR DATA RIGHTS AND CHOICES

Depending on your legal jurisdiction or state of residence (including applicable state privacy legislation), you may possess specific statutory rights regarding your personal information:

• Right to Access & Review: Request details regarding the categories and specific pieces of personal information we maintain about you.
• Right to Correction: Request corrections to inaccurate or incomplete personal records.
• Right to Deletion: Request the deletion of your personal information, subject to statutory retention exceptions (e.g., tax records, ongoing contract enforcement, legal defense).
• Right to Opt-Out: Opt out of the processing of your personal data for targeted advertising, profiling, or non-essential analytics.

To exercise any of these rights, please submit a written request to privacy@newworldwebsolutions.com. We will verify and process your request in accordance with applicable statutory timelines.

13. CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to update, amend, or modify this Privacy Policy at any time in its sole discretion. Any revisions will become effective immediately upon posting the updated policy to our website with a revised "Last Updated" date. Your continued access to, browsing of, or use of our website or Services following the publication of changes constitutes your explicit acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

14. GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy, along with all data collection, processing, and handling practices, is governed by and construed strictly in accordance with the internal laws of the State of Michigan, without regard to conflict-of-law principles. Any legal claim, dispute, or proceeding arising out of or relating to this Privacy Policy shall be governed by the mandatory dispute resolution, binding individual arbitration, and class action waiver provisions established in Section 54 of our Terms and Conditions of Service.

15. CONTACT INFORMATION AND NOTICES

If you have questions, concerns, or legal inquiries regarding this Privacy Policy or our data privacy practices, please contact us at: