What this policy covers
Newo Inc. is committed to protecting your privacy. If you interact with Newo Services, you act as a Data Subject.
This policy is intended to help Data Subjects understand:
- What information we collect about Data Subjects
- How we use the information we collect
- How we share information we collect
- How we store and secure the information we collect
- How Data Subjects can access and control their information
- How we transfer information we collect internationally
- Other important privacy information
This Privacy Policy covers the information we collect about Data Subjects when they use our products or services unless a different policy is displayed. “Newo”, “we” and “us” refers to Newo Inc. a Delaware corporation with its principal place of business located at 2261 Market Street #5263 San Francisco, CA 94114 USA.
When processing Data Subject information, Newo acts on behalf of and under the instructions of the AI Agent Owner.
This policy also explains Data Subject choices about how we use information about them. These choices include how Data Subjects can object to certain uses of information about them and how they can access and update certain information about them. If Data Subjects do not agree with this policy, they should not access or use our Services or interact with any other aspect of our business.
What products and services does this Privacy Policy cover
This Privacy Policy covers:
- Newo Cloud Services
- Newo AI Agents, created using Newo Cloud Services
- Newo websites
collectively referred to as “Services”.
Notice to Data Subjects
Access to Services is made available to Data Subjects through an organization referred to as the AI Agent Owner. Data Subjects should direct any data privacy questions to their AI Agent Owner, as their use of Services is subject to the policies of their AI Agent Owner. Newo Inc. is not responsible for the privacy or security practices of the AI Agent Owner, which may differ from this policy.
What information we collect about Data Subjects
Account, Profile and Personal Identifiable Information
We collect information about Data Subjects when they interact with AI Agents created by AI Agent Owners through phone calls, SMS, email, webchat or other channels, when they register for an account, create or modify their profile, set preferences, sign-up for or make purchases through the Services. It may include, but is not limited to, name, email address, telephone number, postal or other physical address, title, or occupation.
Data Subject Activity Data
Newo may collect and process activity data such as Data Subject messages, calendar records, customer relationship management (“CRM”) data, corporate messenger data (e.g. Slack), corporate productivity platforms (e.g. GitHub, Jira) data, etc., further referred to as “Data Subject Activity Data”.
The AI Agent Owner is responsible for sources and third-party services over which it has control. Data Subjects should direct their data privacy questions to their AI Agent Owner, as their use of the Services is subject to their AI Agent Owner’s policies.
Data Subject use of the Services
We keep track of certain information about Data Subjects when they visit and interact with any of our Services i.e. the features they use, the links they click on, the teams and people they work with and how they work with them, like who they collaborate with and communicate with most frequently, etc.
Cookies and Other Tracking Technologies
Newo and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize Data Subjects across different Services and devices.
How we use the information we collect
To provide the Services
We use information about Data Subjects to provide the Services to them, authenticate them when they log in, provide customer support, and operate and maintain the Services. We use Data Subject contact information to send communications via messengers, email, business messengers and within the Services, including sending technical notices, updates, security alerts, and administrative messages.
Newo analyzes Data Subject Activity Data to deliver AI agent experience on behalf of the AI Agent Owner.
For research and development
Newo may analyze Data Subject Activity Data to deliver more accurate predictive analytics insights about best practices to make our Services faster, secure, integrated, and useful to Data Subjects.
For industry benchmarks
Newo Services may use information provided by Data Subjects to create de-identified data aggregated for benchmarking or marketing purposes.
To provide updates about the Services
We use Data Subject contact information and information about how they use the Services to send communications that may be of specific interest to them. These communications may include information about new features, survey requests, newsletters, and events we think may be of interest to them. We also communicate with Data Subjects about new product offers, promotions, and contests.
Customer support
We use Data Subject information to resolve technical issues they encounter, to respond to their requests for assistance, to analyze crash information, and to repair and improve the Services.
For safety and security
We use information about Data Subjects and their Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights
Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about Data Subjects in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
How we share information we collect
Google Workspace APIs
We explicitly affirm that Google Workspace APIs are not used to develop, improve, or train generalized Artificial Intelligence (AI) and/or Machine Learning (ML) models within our products or services.
Managers, co-workers or third-party
The AI Agent Owner may decide to provide Data Subjects, their managers, their co-workers or third-party access to dashboards, reports and API connection with aggregated, anonymized or deanonymized analytics and statistics based on collected and processed Data Subject Activity Data.
Data Subjects should direct their data privacy questions to their AI Agent Owner, as their use of Services is subject to their organization’s policies. We are not responsible for the privacy or security practices of their organization, which may be different from this policy.
Service Providers
We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use information about Data Subjects. If a service provider needs to access information about Data Subjects to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect Data Subject information.
Newo Partners
We work with third parties who provide consulting, sales, and technical services to deliver and implement customer solutions around the Services. We may share Data Subject information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where Data Subjects have agreed to that sharing.
Compliance with Law Enforcement Requests and Applicable Laws
Enforcement of Our Rights: In exceptional circumstances, we may share information about Data Subjects with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Newo, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Business Transfers
We may share or transfer the information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Data Subjects will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices they may have regarding their information.
How we store and secure the information we collect
Information storage and security
We use industry standard technical and organizational measures to secure the information we store.
While we implement safeguards designed to protect Data Subject information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If Data Subjects use our server or data center Services, responsibility for securing storage and access to the information they put into the Services rests with them and not Newo. We strongly recommend that server or data center users configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage points used.
How long we keep information
How long we keep information depends on the type of data. After such time, we will either delete or anonymize Data Subject information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store Data Subject information and isolate it from any further use until deletion is possible.
Account information: We retain Data Subject account information for as long as their account is active and a reasonable period thereafter in case they decide to re-activate the Services. We also retain some of their information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies Data Subjects, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about them.
The information Data Subjects share on the Services: If a Data Subject account is deactivated or disabled, some of their information and the content they have provided will remain in order to allow their team members or other users to make full use of the Services.
We retain Data Subject Activity Data and other information related to Services as long as required by the AI Agent Owner.
Marketing information: If Data Subjects have elected to receive marketing emails from us, we retain information about their marketing preferences for a reasonable period of time from the date they last expressed interest in our Services, such as when they last opened an email from us or ceased using their Newo account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control Data Subject information
Data Subjects have the right to object to our use of their information, request that we stop using their information, to request the deletion or restriction of their information, or to request their information in a structured, electronic format. Where the Services are administered for Data Subjects by an administrator, they may need to contact their administrator to assist with their requests first.
How we transfer information we collect internationally
Newo Services accessible through the domain name newo.ai are hosted in the United States by Google Cloud. If Data Subjects use the Services from the European Union or the United Kingdom, or any other region with laws governing data collection, protection and use that may differ from United States law, please note that they may be transferring their personal information outside of those jurisdictions to the United States. Where we transfer, store and process Data Subject personal information outside of the United Kingdom, European Union or EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws.
By using the Services, Data Subjects consent to the transfer of their personal information outside their home jurisdiction, including to the United States, and to the storage of their personal information in the United States, for the purpose of hosting, using and processing the personal information in accordance with this Privacy Policy. Data Subjects further acknowledge that these countries may not have the same data protection laws as the country from which they provided their personal information, and that Newo may be compelled to disclose their personal information to U.S. authorities. Data Subjects have the right to withdraw their consent at any time by contacting us as described in the “Contact Us” section below.
HIPAA Compliance and Protected Health Information (PHI)
If the AI Agent Owner is using our service in a HIPAA-compliant capacity, we act as a Business Associate under the Health Insurance Portability and Accountability Act (HIPAA) and process Protected Health Information (PHI) solely to provide the contracted services. We do not use PHI for marketing, research, profiling, or any unrelated purposes.
PHI submitted to our API is handled transiently and is not stored persistently, unless specifically agreed otherwise in writing. All PHI is processed using infrastructure that complies with the HIPAA Security Rule, including safeguards such as encryption, access controls, audit logging, and secure system design. We use Google Cloud infrastructure and services to process PHI.
In the event of a confirmed breach involving PHI, we will notify our partners via email within 60 calendar days, in accordance with HIPAA Breach Notification Rule requirements.
AI Agent Owners are responsible for ensuring that PHI submitted through our service is limited to the minimum necessary and that they are authorized to submit such data under HIPAA.
Other important privacy information
Our policy towards children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If Data Subjects become aware that a child has provided us with personal information, please contact our support services.
Changes to our Privacy Policy
We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending Data Subjects an email notification. We will also keep prior versions of this Privacy Policy in an archive for Data Subject review. We encourage Data Subjects to review our privacy policy whenever they use the Services to stay informed about our information practices and the ways they can help protect their privacy.
If Data Subjects disagree with any changes to this privacy policy, they will need to stop using the Services and deactivate their account(s), as outlined above.
Contact Us
If Data Subjects have any questions or concerns about how their information is handled, please direct inquiries to compliance@newo.ai.
Newo Inc.
2261 Market Street #5263
San Francisco, CA 94114