Privacy Policy

Last updated [December 9, 2019]

Thank you for visiting the New Sun Road website. NEW SUN ROAD, P.B.C. and its affiliated companies and subsidiaries (the “Company”, “we”, “us” or “our”) respect the privacy of our
users and are committed to maintaining robust privacy protections. Our Privacy Policy (the
“Privacy Policy”) is designed to help you understand how we collect, use, disclose and safeguard your information and to assist you in making informed decisions when visiting our Site.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

By accessing our Site, you accept our Privacy Policy and Terms of Use, and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy. If you do not agree with the terms of the Privacy Policy, please do not access the Site. This Privacy does not apply to the extent that we process your personal information on your behalf as a customer of our integrated cloud based products and services. Information processed in this capacity shall be regulated by your Stellar Power Platform™ Terms and Conditions, and/or the Services Privacy Policy.

For purposes of this Privacy Policy:

“Site” refers to the Company’s website, which can be accessed at www.newsunroad.com.

“You” refers to you, as a user of our Site.

1. INFORMATION WE COLLECT
2. HOW WE MAY USE YOUR INFORMATION
3. HOW WE MAY DISCLOSE YOUR INFORMATION
4. HOW WE PROTECT INFORMATION
5. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION
6. LINKS TO OTHER WEBSITES
7. CHANGES TO OUR PRIVACY POLICY
8. CONTACT US

1. INFORMATION WE COLLECT
We may collect “Non-Personal Information” and “Personal Information” about you in a number of ways set out below.

Types of Information

Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your name, email, address, date of birth, contact information, location information and payment information we collect and process which you submit to us through the Site. Personal Information may also include information about transactions, both free and paid, that you may enter into on the Site, as well as information about you available on the Internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from services providers.

Information collected via Technology

In an effort to improve the quality and optimize your experience on the Site, we may track information provided to us by your browser, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Site, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about you and keep a record of the user’s preferences when using our Services, both on an individual and aggregate basis.

Information you provide us

If you express an interest in our products, services or events and use our “Contact Us” or similar function to contact us, or download certain information, interact with us via email, social media or our Site, you may provide us with you name, email, phone number, address, location, employer, job title. By providing you Personal Information in this manner, you authorize us to collect, store and use your Personal Information in the manner set out in this Privacy Policy.

Children’s Privacy

Our Site is not directed to anyone under the age of 16. Our Site does not knowingly collect or solicit information from anyone under the age of 16. In the event that we learn that we have gathered personal information from anyone under the age of 16 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at privacy@newsunroad.com, so that we may delete the information.
2. HOW WE MAY USE YOUR INFORMATION

General

In general, the Personal Information you provide to us is necessary for us to: perform in terms of a contract you have with us; notify you about changes to our Site, provide you with information about our products and services, and communicate with you. More specifically, we use your Personal Information to contact you in response to questions, solicit feedback from you, provide informational support, and inform you of promotional offers.

Use of Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties. We do share Personal Information with vendors who are performing services on our behalf to assist in the provision of information, products or services to you (such as the servers for our email communications) or in managing and improving our services or the Site. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. More specifically, we may use your Personal Information to:

 Create, administer and manage your account for the provision of services.
 Send you email correspondence in response to a request or interest in our products or services.
 Send you newsletters and marketing information relating to new products, services and projects.
 Improve the efficiency of our Site and services provided to you.
 Respond to and resolve issues and service requests.
 Process your payments.
 Request your feedback related to the Services and the Site.
 Protect against fraud and criminal activity through monitoring and fraud-detection activity.

Non-Personal Information

In general, we use Non-Personal Information to help us improve the Site, services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

3. HOW WE MAY DISCLOSE YOUR INFORMATION

We may disclose information collected about you for certain reasons and under certain situations. The reasons we may disclose your information are as follows:

Legal and Protection of Rights

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Use, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

Third-Party Service Providers

In providing the services to you, we may be required to share your information with third-party service providers who provide services for or on our behalf, or third parties providing services to you or on your behalf, including your equipment providers, payment processors, email and data hosting service providers.

Business Sale or Bankruptcy

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

4. HOW WE PROTECT INFORMATION

We implement strict security measures designed to protect your Personal Information from unauthorized access. We protect your Personal Information from potential security breaches by implementing certain administrative, technical and physical security measures. While we take commercially reasonable steps to ensure the security of your Personal Information, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed due to interception and misuse by unauthorized parties. By using our Site, you acknowledge that you understand and agree to assume these risks.

5. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

You have the right at any time to prevent us from sending you marketing or other correspondence. You may at any time opt out of further promotional correspondence by following the unsubscribe instructions provided in each promotional e-mail, or contacting us using the information provided below. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails related to the services we provide to you, as well as other updates, including to this Privacy Policy.

6. LINKS TO OTHER WEBSITES

Our Site may provide links to other websites or applications maintained by other third parties. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site. Therefore, this Privacy Policy does not apply to your use of a third party websites or API’s accessed by selecting a link on our Site or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage you to read the privacy statements of other websites and API services before proceeding to use them.

7. CHANGES TO OUR PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy and our Terms of Use at any time and for any reason. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Site. Significant changes will go into effect 30 days following such notification. Non- material changes or clarifications will take effect immediately. We encourage you to periodically check the Sites Privacy Policy page to stay informed of updates.

8. CONTACT US

If you have any questions or comments regarding this Privacy Policy or the privacy practices of this Site, please contact us at:

New Sun Road, P.B.C
1301 S46 Street, Building 112
Berkeley Global Campus,
Richmond, California 94804
U.S.A
privacy@newsunroad.com.

Last Updated: This Privacy Policy was last updated on December 9, 2019.

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