PRIVACY POLICY
This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
EUROPEAN VISITORS: Please do not electronically communicate with us through this website or by email. Instead, please exercise your rights under the General Data Protection Regulation (GDPR) by first calling our General Counsel at 001-602-228-2582 (ask for Nicholas C. Dranias) so that we are able to process your inquiry properly. Also, feel free to contact supervisory authorities within the EEA, including in your own Member State, about concerns you have related to our privacy practices. We recommend contacting the Dutch Data Protection Authority, also known as the Autoriteit Persoonsgegevens.
Who are “we”?
The servicemark ‘neWay’ refers to NeWay Capital LLC, a Wyoming limited liability company, and affiliated entities related by common ownership or control in whole or in part, including but not limited to Sociedad para el Desarrollo Socioeconómico de Honduras, LLC, a Delaware limited liability company. The neWay family of entities and our team (as well as persons acting at their direction) may use your PII (the title and role ascribed to designated members of the “team” may be applicable to their role at one or more entities other than NeWay Capital LLC in the neWay family of entities). If you wish to receive a current list of entities and principal persons who may use your PII, please contact NeWay Capital LLC General Counsel Nicholas C. Dranias at 001-602-228-2582.
What personal information do we collect from the people that visit our blog, website or app, if any?
When contacting us through our site, you may be asked to enter your name, email address, phone number or other details to help you with your experience.
When do we collect information?
We collect information from you when you fill out a form or enter information on our site. Social media, such as facebook, may also track and report to us information about you when you visit.
How do we use your information?
We may use the information we collect from you when you sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
To allow us to better service you in responding to your service requests.
To follow up after correspondence (e.g., live chat, email or phone inquiries).
To assess marketing efficacy of the site.
How do we protect visitor information?
We do not use vulnerability scanning and/or scanning to PCI standards.
We use regular Malware Scanning.
Do we use ‘cookies’?
We do not, but our website hosting service and social media sites may do so. This is beyond our control. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
Third-party disclosure
We may affiliate with fully disclosed independent “of counsel” attorneys and policy experts to whom we may refer your matter for review. We do not otherwise sell, trade, or otherwise transfer to outside parties your personally identifiable information.
Third-party links
We may affiliate with fully disclosed independent contractors or experts. We do not otherwise include or offer third-party products or services on our website.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.
According to CalOPPA we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes on our Privacy Policy Page.
Users are able to change their personal information: By calling or emailing us.
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. However, we cannot control the policies of our third party hosting service.
Does our site allow third-party behavioral tracking?
It’s also important to note that we allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email within 7 business days.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.
Process requests services and to send information and updates pertaining to orders.
We may also send you additional information related to our service.
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM we agree to the following:
NOT use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at ndranias@newaycapital.com and we will promptly remove you from ALL correspondence.
Privacy Officer for All Privacy Questions
Nicholas C. Dranias
General Counsel
NeWay Capital LLC
ndranias@newaycapital.com
001-602-228-2582
1875 Connecticut Ave NW
10th Floor
Washington, DC 20009