NewAge Great Escape Tahitian Dream 2022 Incentive Trip Website Privacy & Data Protection Policy

(GDPR Article 13 Privacy Notice to Data Subject)

Last Updated: April 8, 2022

NewAge, Inc. and its affiliates and subsidiaries including but not limited to Morinda, Inc., ARIIX LLC, NewAge USA, Inc., Morinda Deutschland GmbH and ARIIX Europe B.V.(“NewAge”) are committed to respecting your privacy and protecting the privacy, confidentiality, and security of the personal information that we hold. This privacy policy is in connection with the NewAge Great Escape Tahitian Dream 2022 Incentive Trip Website (the “Website”). We have structured the Website so that you can visit the Website without identifying yourself or revealing any personal information. Once you choose to provide us personally identifiable information with us (any information by which you can be identified), you can be assured that it will only be used to support your customer relationship with NewAge or your business relationship as a NewAge Brand Partner (“Brand Partner”).  NewAge is a data controller and is registered with the relevant data protection regulators in the countries in which NewAge operates.

By visiting and using the Website, you acknowledge and agree to the practices described in this Policy.

1. AWARENESS

This Privacy & Data Protection Policy (the “Policy”) is to provide transparency into our practices, ensure fairness and accountability in our data processing and help you exercise your data privacy rights. In particular, this Policy explains what information we collect about you, what we use that information for, the lawful basis on which that information is used and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries. To make this notice easy to find, we make it available on the bottom of every page on the Website.

2. WHAT WE COLLECT AND WHY.

Visitors. Upon logging onto the Website, the Website automatically recognizes your domain name but not your E-mail address (where possible). We will collect the domain name from which you log on, aggregate information on what pages you access or visit, user-specific information on what pages you access or visit, and information volunteered by you from the way you interact with us (such as survey information and/or site registrations). We do not collect your E-mail address unless you contact us by E-mail or volunteer your E-mail address and other personal information.

The Website uses “cookies” (tiny text files stored on your hard disk by a web page server) for session management purposes. This enables you to sign into the Website’s services and helps personalize your online experience. Cookies cannot harm your computer and they do not contain any personally identifiable information. One of the primary purposes of cookies is to store your preferences and other information on your computer to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content on your later visits to websites. Cookies also help us to improve the Website and to deliver a better and more personalized service. Among other things, they enable us:

  1. To estimate audience size and usage pattern.
    To store information about your preferences, so the Website can tailor to your individual interests.
    To increase the speed of your searches.
    To recognize you when you return to the Website.

To provide social media features

3. HOW WE USE PERSONAL DATA.

NewAge uses your information to meet its contractual obligations to you, meet our legal obligations to the government of your jurisdiction, better understand your needs, and provide you with better service. Specifically, we use your information in relation to the registration process as part of the NewAge Great Escape Tahitian Dream 2022 Incentive Trip, to provide you with information about the NewAge Great Escape Tahitian Dream 2022 Incentive Trip, communicate with you, update you on services and benefits, and personalize our Web sites for you; to satisfy applicable legal or regulatory requirements and to respond to any requests/communications from competent regulatory or judicial authorities; and to provide you with marketing communications from us (subject to any consents that we are legally required to obtain from you to send such communications and which you can withdraw by opting out at any time) and such communications will from time to time include information on new products and initiatives run by NewAge. Credit card and bank account numbers are used only for receiving and remitting payment. We use industry-standard practices to protect this information. For example, credit card numbers provided to us are stored in a tokenized format.

4. WHOM WE SHARE IT WITH AND WHY.

NewAge will not sell, rent, or lease your personally identifiable information to others unless we have your permission. We will only share the personal data you provide online with other NewAge entities and/or business partners who are acting on our behalf. Such NewAge entities and business partners, including those in the United States and any/or other countries, are governed by our privacy policies with respect to the use of this data and, where applicable, are bound by the European Union’s standard contractual clauses for the transfer of personal data, a copy of which may be obtained by emailing our Legal Department at legal@newage.com.

We share personal data with these third-party business partners to fulfil our contractual obligations to our Brand Partners, employees, and customers. Specifically, we share your information with payment processing companies to collect payment; banks to facilitate commission payments; logistics companies to fulfil and deliver orders; a third-party email service to efficiently send business support materials, including product updates and promotions (you may easily unsubscribe at any time); a data backup service to maintain data integrity; payroll processing and pension plan companies (only for NewAge employees); a wholesale travel company for NewAge Travel users; and an app developer for NewAge Business Rewards (read-only access).

We also share personal data with your government to fulfil our legal obligations (e.g., tax reporting) in your jurisdiction. Please be aware that we may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. NewAge is liable for appropriate onward transfers of personal data to third parties.

5. CHOICE

NewAge will not use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without first letting you know and offering you a choice. As previously stated, we will also provide you the opportunity to unsubscribe (or otherwise easily opt out) if you do not wish to receive direct marketing materials from us. Following such a request, we will no longer process your personal data for such purposes.  Your permission is always secured first, should we ever share your information with third parties that are not acting on our behalf and governed by our Policy.

6. RIGHT TO ACCESS, RECTIFY, ERASE, TRANSFER, AND RESTRICT DATA.

NewAge strives to keep your personally identifiable information accurate and secure. You have the right to know what information we hold about you and why. To request this information, or to update, rectify, complete, erase, transfer, or restrict your information with NewAge, it will be necessary for you to contact us directly through the methods listed in the final section below. Such requests will be promptly processed. To protect your privacy and security, upon contacting us we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections.

You may also request confirmation as to whether or not your personal data is processed by NewAge and, if so, the categories of personal data concerned, the purposes of the processing, the recipients or categories of recipients to whom your data has been or will be disclosed, the anticipated length of time for which your data will be stored, safeguards used pursuant to cross-border data transfers, and a copy of the personal data undergoing processing.

Where rectification, restriction, transfer, or erasure of personal data has been granted, NewAge will communicate such with each recipient to whom such data has been disclosed, unless this proves impossible or involves disproportionate effort.

7. RESPONSE TO REQUESTS.

NewAge will respond to requests made under the previous section without undue delay and in any event within one month of receipt of the request unless the request is complex or a high number of requests have been made, in which case NewAge will notify you after one month that up to one additional month may be necessary. The reason for the delay will also be communicated at that time.

8. SECURITY

We take reasonable steps to ensure that the personal information we collect about you remains accurate and secure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100 percent secure, and while we strive to protect your personal information, we cannot guarantee or warrant its complete security. We shall not be responsible for harm that you or any person may suffer due to a breach of confidentiality in respect to your use of the Site or any information you transmit to the Site. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry-standard encryption technology when collecting or transferring sensitive data, such as credit card and bank account information.

9. EEA AND UK DATA TRANSFERRED TO THE U.S.

NewAge is a global organisation and we may transfer your personal data to our secure, PCI-compliant data center near our headquarters in the U.S. This transfer is necessary for us to process commissions, collect payment, fulfill and ship orders, perform compliance activities, disseminate product and business materials and meet our other contractual obligations to our customers and Brand Partners. U.S. law may not provide the degree of protection for information that is available in other countries. NewAge entities and business partners, including those in the United States and any/or other countries, are governed by our privacy policies with respect to the use of this data and, where applicable, are bound by the European Union’s standard contractual clauses for the transfer of personal data. Should you desire more detailed information regarding data transfers to the U.S. or if you wish to exercise your right, you may contact our data protection officer whose details are set out in Section 17 of this Policy or  email our Legal Department at legal@newage.com.

10. UNITED STATES AND REST OF WORLD

If you have any questions or complaints about this Policy, please contact Legal@newage.com

11. FUTURE DEVELOPMENTS.

If our information practices change at some time in the future, we will first post the policy changes to the Website to notify you of these changes and the lawful basis of our processing activities. If you are concerned about how your information is used, you should periodically check the current version of this Policy on the Website. By using the Website, you acknowledge acceptance of the version of this Policy in effect at the time of use.

12. NON-discrimination.

Exercising your rights under this Policy or the data privacy laws or regulations applicable to you will not result in any of the following by NewAge: denying you goods or services; charging (or suggesting we will charge) you different prices or rates for goods or services (whether through the imposition of fees or penalties, through denial of discounts or benefits, or through other means); providing (or suggesting we will provide) you a different level or quality of goods or services.

13. Protection of Children’s Privacy.

We take special care to protect the privacy needs of children. Our Site does not target and is not intended for children under the age of 18, and we will not knowingly collect personal information from them. You must be at least 18 years old to be a customer or Brand Partner.

14. DATA RETENTION.

Personally-identifiable information will be kept in active files or systems as long as needed to meet the purposes for which it was collected or as required to perform the contractual relationship with the Brand Partner and his/her up-line, the commercial relationship with the Customer, and our legal obligations.

15. THIRD PARTY LINKS.

NewAge may at times provide links to other websites. These sites are not controlled by NewAge and we are not responsible for any content contained on any such website. While we try to link only to sites that share our high standards and respect for privacy, NewAge is not responsible for the privacy practices employed by other sites. We recommend that you review the privacy and security policies of each website you visit.

16. Complaints and objections.

NewAge holds itself accountable to this Policy. We welcome inquiries, concerns, complaints, and objections via the method of contact listed in the following section and will work promptly and in good faith to resolve them in a fair manner. In addition, you have the right to lodge a complaint with a supervisory authority.

17. Contact Us.

NewAge, Inc. is located at 7158 S. FLSmidth Dr.,Suite 250, Midvale, UT 84047. ARIIX Europe B.V. has its registered address at President Kennedylaan 19, JK 2517, Den Haag, The Netherlands. Please direct all communications regarding this Policy our Legal team, via email to legal@newage.com.

© 2022 NewAge, All Rights Reserved.

© 2022 NewAge, All Rights Reserved.