Your privacy is our priority. This policy explains the accepted privacy practices for our service and for our website at www.openBoM.com (the “Service”). It describes the ways we collect and use your personal information (“Client Data”) and the rights and options available to you with respect to this information. This policy is incorporated into the Service’s software (the “Service”) corporate and end-user (a “Client” and/or “User” of the Service) agreements (the “Software Agreements”).

Data Controller and Data Processor

Newman Cloud Inc does not own, control or direct the use of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Newman Cloud Inc. is largely unaware of what the Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and/or Users. Newman Cloud Inc. is not acting in the capacity of data controller in terms of the European Union’s Directive 95/46/EC on data privacy or the European Data Protection Regulation (“EU Law”) and does not have the associated responsibilities under the EU Law. Except as provided in this Privacy Policy, Newman Cloud Inc. does not independently cause Client Data containing Personal Data stored in connection with the Service to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Newman Cloud Inc in connection with Newman Cloud Inc provision of Service to Clients and/or Users.. Such actions are performed or authorized only by the applicable Client or User as necessary to provide Services to the Client and/or Users.

Personal Information that you provide

When you register with the Service, we will ask you to provide certain personal details such as your name, e-mail address, company name and phone number.

The Service is not intended for use by persons under the age of 18. If you are not 18 years old or older, then you may not register with the Service and must not provide us any personal details.

Additional personal Information that we collect

In addition to the information you provide, we may further collect information when you use the Service. For example, this information may include the frequency and scope of your use of the Service, the Internet protocol (IP) address and the name of the domain that serve you to access the Service, your browser type and the geographic location of the computer system that you are using to log-in.

When you visit our website (www.openbom.com)

You can visit our website without giving away your personal information. Newman Cloud Inc uses Google Analytics and Cookies in order to improve our service, user experience and analyse how the website is used. Aside from the approximate location (IP Address), the information collected by Google Analytics is mostly anonymous traffic data including browser information, device information, and language. We do not collect additional information, such as your age, gender, company name, bank details or clicksteam. The collected information is used to provide an overview of how people are accessing and using the Newman Cloud website. It is not used for any additional purpose, such as to profile those who access our website.

What do we do with your personally identifiable information?

We do not transfer or disclose your information to third parties for purposes other than those provided below:

• To operate the Service and enable you and other users to use it;
• To improve and customize your experience with the Service;
• To provide you with customer services and support;
• To send you Service-related updates, notices, and announcements;
• To contact you with respect to the Service and related issues;
• To send you marketing and advertising material directly from OpenBOM. You may opt out of the mailing lists at any time by changing your preferences in your account. In any case, we will not share your personally identifiable details with advertisers without your explicit consent.  We will never provide or transfer your user or personal account information for retargeting or internet-based advertising.  Furthermore, we will never transfer 3rd party data (for example:  Google, Dropbox, etc) to serve users ads, including personalized retargeted and internet-based advertising;
• To enforce the Software Agreements;
• To conduct surveys and questionnaires;
• To comply with any applicable law and assist law enforcement agencies under any applicable law, when we have good faith to believe that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards;
• To collect fees and debts;
• To prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service;
• To take any action in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties with respect to, or in relation with the Service;

If you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to the Service and for us to respond to your query.

How do we share information with others?

We do not sell, rent or lease your personally identifiable information. We may share personally identifiable information with others in any of the following instances, or subject to your explicit consent:

• We may provide your personal information to affiliated companies that provide services to help us with our business activities such as sending email messages, authorizing access to data stored in OpenBOM assets such as catalogs, BOMs, etc as well as to the data linked to these assets such as Google Drive. These companies are authorized to use your personal information only as necessary to provide these services to us;
• We may share your personal information with partners that may contact you to offer their services, but, we will never transfer 3rd party data (for example:  Google, Dropbox, etc).
• If we believe that you have breached the Software Agreement, or abused your rights to use the Service, or performed any act or omission that we believe to be violating any applicable law, rules, or regulations. In these cases, we may share your information with law enforcement and other competent authorities as well as with other third parties, as may be required to handle your wrongdoings;
• If we are required or believe that it is required by law to share or disclose your information;
• In any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties with respect to, or in relation to the Service. In these cases we will share your information to the extent required to handle the dispute or the proceedings;
• In any case where we believe that sharing information is necessary to prevent imminent physical harm or damage to property;
• If we organize the operation of the Service through a different legal structure or entity, or if we are acquired by, or merged with another entity, provided, however, that those entities agree to be bound by the provisions of this policy;
• We may also share personally identifiable information with affiliate companies such as subsidiaries, sister-companies and parent companies, that may contact you and provide you information about their products and services.

How do we use aggregated information?

We will use anonymous, statistical or aggregated information collected through the use of the Service to properly operate the Service, to modify and improve the Service’s features, to enhance your experience with the Service, to create new services and features, including customized services, and for other internal, commercial and statistical purposes.

We may share the information with third parties, such as suppliers, business partners, sponsors and affiliates, provided, however, that the information will not identify you and that we will not knowingly, or intentionally use the information to reveal your identity without your consent.

Your choice (Access, Correction, Deletion)

We respect you privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you that we have obtained from an integrated service, you may contact us as set forth in the ‘Contacting us’ section at the end of this document, below. At your request, we will have any reference to you deleted or blocked in our database.

You may update, correct, or delete your Account information and preferences at any time by accessing your account settings page on the Service. Please note that while any changes you make will be reflected in active user database instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so,

You may decline to share certain Personal Data with us, in which case we may not be able to provide you the Service.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.

For example, if you no longer wish to receive our promotional communications and Service related alerts, you may opt-out of receiving them by following the instructions included in each message, or by emailing us at: support@openBoM.com.

Where is your personal information processed?

We store and process the information on servers in the USA. If you are in the European Economic Area, or in any other jurisdiction that regulates the transfer of personal information outside that jurisdiction, then you hereby grant us your explicit and unambiguous consent to transfer your personal information to the USA, for the purposes described in this policy.

Accessing your personal information

At any time you may access your account and edit, or amend your personal information or by emailing our Customer Support at support@openbom.com or by contacting us by postal mail at the contact information listed below.

If you find that the information in your account is not accurate, complete or updated than you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering with the Service and prevent us from providing you with the Service.

Data retention

We will retain your information for as long as your account is active or as needed to provide you with the Service and as required to comply with any legal obligation, to resolve disputes and to enforce our Software Agreements. If you wish to cancel your account or request that we no longer use your information to provide you the Service, please contact us at: support@openbom.com

Cookies

We use cookies. Cookies are packets of information sent by a website’s servers to your web browser and then sent back by your browser each time you access the website’s servers. We may link the information we store in cookies to any personally identifiable information you submit while using the Service. For example, we may use cookies to make your log-in easier, by saving you the need to re-enter your username and password each time you log-in. In this case, the cookie that stores your log-in information will be linked to your personal account.

The cookies may contain a variety of information, such as session duration, the IP address that you use to access the Service and other pieces of data that help us maintain and enhance user interaction.

Some of the cookies may expire when your browsing session ends and you exit your browser, however other cookies are saved on your computer’s hard drive. If you wish to block the Service’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Service, or certain features of the Service.

Links to Other Sites

We may provide links to other sites that we do not own or control. We are not responsible for the privacy practices of these sites. Therefore, we encourage you to be aware when you leave the Service and to read the privacy statements of websites that collect personally identifiable information.

Information Security

We implement standard information security tools and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information, as provided by our cloud hosting services provider. Among such security, methods are the storing of information on cloud services, firewalls, encryption codes, hashing and authentication procedures. Furthermore, we implement employee supervision and prevent unnecessary access to data.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the information’s absolute security. If you have any questions about security on our Service, you can contact us at support@openBoM.com.

Please keep your log-in details safe. We strongly advise that you do not share this information with any third parties or leave it exposed. Furthermore, we strongly advise you to change your password from time to time.

International Privacy Laws

If you are using the Service from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back outside of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by Newman Cloud Inc and our contractors which include but not limited to Amazon Web Service. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will ask you to provide your consent, the next time you log-in to the Service.

If you do not provide your consent to the amended terms, you may not use of the Service.

Newman Cloud Inc Data Protection Officer

Newman Cloud Inc has a “Data Protection Officer” or its equivalent who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

Newman Cloud Inc

Attn Data Protection Officer

105 Redwood Road

Newton, MA 02459

support@openbom.com

Contacting us

You can contact us at any time to:

• Request access to information that Newman Cloud Inc. has about you;
• Correct any information that Newman Cloud Inc. has about you; and
• Delete information that Newman Cloud Inc. has about you.

You may send us requests, responses, questions, and complaints, by using the Contact Us form on our website, or by contacting us at support@openbom.com or by writing us at:

Newman Cloud Inc

105 Redwood Road

Newton, MA 02459

“OpenBOM” is a Trademarked brand wholly owned by Newman Cloud Inc.