Welcome to New Era Commodities - Your International Business and Trade Service Provider.

This Privacy Policy lets you know how we collect, use, share, and protect information about you when you interact with New Era Industries through this website, however accessed, (“Website”) or mobile applications (“App”) (which we will refer to together as the “Site”) to use or obtain any of our products or services (the “Services”). Where we post this Privacy Policy, we explain what information we collect through the Site, how we use it, with whom we share it, and the choices you have to control, access, and update your information. If you have questions about anything in our Privacy Policy, please contact us at info@neweraindustries.com.

As described above, this Privacy Policy also sets forth our privacy practices with respect to any Apps made available to you by us or our affiliates. If a separate privacy policy applies to a specific App or another website operated by New Era Industries (“Other Website”), we will indicate that by posting that separate Specific Privacy Policy on that App or Other Website (the “Specific Privacy Policy”), rather than this Privacy Policy, with respect to that App or Other Website, and such Specific Privacy Policy will apply and govern your use of that App or Other Website. To the extent there is a conflict between the terms of this Privacy Policy and the Specific Privacy Policy, the terms of the Specific Privacy Policy shall apply to your use of that App or Other Website.

By using our Site or Services you agree to the privacy practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please uninstall any Apps from your device and stop using the Site and Services. By continuing to use the Site and Services, you accept this Privacy Policy.

New Era Industries’ California Consumer Privacy Act (“CCPA”) Privacy Notice appears below within this Privacy Policy.

The information we collect from you varies, depending on the way you use our Services. We collect information from or about you in the ways described below.

When you use our Site or Services, we collect information that you choose to share with us. We collect several types of personal information from and about you when you use our Site or Services. This information may include:

• Name;
• Address;
• Company name;
• Email address;
• Telephone number;
• Fax number; and
• Credit or debit card information.

We collect personal information such as your name, address, e-mail, and phone number when you apply for employment with us through the Site. In addition, we may collect information relating to your education and employment history when you submit that information as part of an employment application. Not all requested information is required, however, and we specifically indicate what information is required in order to submit your employment application.

An App may utilize location services on your mobile device to collect and use location data, including the real-time geographic location of your device. If you consent to the App’s utilization of location services, we may use GPS, Bluetooth, your device’s unique identifier, and/or your IP Address, along with Wi-Fi and cell tower locations, and other technologies to determine your device’s geolocation. This location data is utilized to initiate notifications or deliver services requested by you. We maintain location data records for as long as necessary to deliver the services you request. We will collect geolocation data only if you consent, and you choose in your App settings whether the location services will be always running, or only when the App is in use. You may choose to disable location services through our App, but if you do so, you will not receive any notifications or services that require a geolocation. Most mobile devices provide users with the ability to disable location services. These controls are generally located in the device’s settings menu. You can also contact your mobile service carrier or your device manufacturer for more information on disabling location services.

You do not need to provide personal information in order to browse or use our Site or Services. Our Site, however, collects certain information automatically about you and your use of our Site and Services that does not necessarily personally identify you, your interactions with us, and information regarding the device you use to access our Site and Services (collectively “Other Information”). This information includes:

• Device information, such as hardware setting, web browser type and language;
• IP address, MAC address;
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g. device advertising ID);
• Times you have accessed pages;
• Pages you have viewed;
• Searches you have conducted; and
• Pages you visited before or after navigating to our Website.

We use your information (both on an aggregated and on an individualized basis), to provide, analyze, administer, enhance and personalize our Site and the Services we provide to you, including our marketing of Services to you. We also use your information to communicate with you, and to operate our business. More specifically, we may use your information to:

• Deliver our Services to you, including to provide access to our Site’s online features, complete and process your online purchases, or engage in other transactions with us;
• Communicate with you about the Services, including to respond to your customer service requests or respond to any other inquiry or correspondence you send to us, as well as respond to you using our Live Chat feature;
• Present you with marketing relating to our Services, including promotions, coupons and other discount offers, and more relevant display advertisements;
• Provide you updates, reminders, or other informational or educational content;
• Enable you to participate in a contest, sweepstake, promotion, or survey;
• Enable you to participate in blogs and post reviews or testimonials. If you provide a review or testimonial, your name will be publicly posted along with the review or testimonial. Please remember that blogs, reviews, and testimonials are located in the public areas of our Site. Do not share content that you would not want others to read, save, or share;
• Consider you for employment. When you apply for a job, we will notify you of any additional uses of your information relating to the information you provide us;
• Analyze and improve the Site and Services, including to develop and improve products and services, and to monitor and analyze trends and usage;
• Prevent, detect, investigate, or remediate security or other legal concerns, including fraud;
• Protect the rights, property, or safety of us our users, or any other person, or the copyright-protected content of the Services;
• Comply with applicable laws, regulations, or industry requirements, or respond to subpoenas or government requests;
• Analyze and better understand how users access and use our Services, including to monitor, evaluate, and analyze trends, determine which features and portions of our Services are most popular, how they are used, and the results that are obtained;
• Troubleshoot;
• Generate statistics including identifying geographic regions of visitors to our Services;
• Support our relationship with you, including to contact you about Service usage and assist you in better using our Services and to evaluate frequently asked questions;
• Improve our Services and develop new features and Services;
• Benchmark our Services against other products and services;
• Respond to law enforcement requests and as required by applicable law, court orders, or governmental regulations;
• As described to you when collecting your personal information as agreed to by you;
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of New Era Industries’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by New Era Industries about our customers is among the assets transferred;
• Conduct other internal business purposes as we may determine from time to time; and
• Fulfill any other purpose for which you provide it.

We may share information collected about you in the following situations:

• With service providers. We share information about you with service providers to perform functions and process your data and to help provide our Services including hosting and storage providers, payment processors etc.
• With third parties for legal or security reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
  • Comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
  • Investigate, remedy, or enforce potential violations of our End User License Agreement and Terms of Use;
  • Protect the rights, property, and safety of us, our users, or others; and
  • Detect and resolve any fraud or security concerns.
• With third parties as part of an acquisition or liquidation. If we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.
• We may disclose or share your personal information in connection with an employment application to verify the information you provide or in accordance with any relevant notice we provide relating to your employment application.
• With your consent. We may share information in other ways if you give us consent or direct us to do so.

We may also share with third parties—such as advertisers—aggregated, or de-identified information and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing aggregated or de-identified data or using such data for their own or someone else’s marketing purposes.

Cookies are small amounts of data which are sent to your browser from a website’s computers and stored on your computer or device. We and our research, technology, and marketing partners, affiliates, analytics, or service providers use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device, specifically:

• Remembering your preferences and allowing you to enter your user name less frequently;
• Uniquely identifying each user session when you access the Services;
• Compiling aggregated statistics to analyze how the Services are used;
• Presenting you with information targeted to your interests, including our content presented on another website and across devices; and
• Measuring the effectiveness of our Sites, Services, content, communications and advertising, including by placing web beacons (sometimes called single-pixel gifs) which emails and links have been opened by recipients.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to disable cookies on your browser (see below) but doing so may prevent you from using the full features of the services. For information about your choices regarding these technologies please see “Your Access and Choices regarding your Personal Information” below.

We may let third parties use cookies, web beacons, and similar tracking technologies on our Services. They may collect information about how you use our Services and other websites and online services over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. We use IBM Digital Analytics to assist us in understanding how visitors use our Website.

Some companies may use information collected on our Site to deliver advertisements on behalf of us or other companies, targeted to your interests and preferences, on our Site or on other websites or applications you may visit, on your various devices, or on your social media feed and to gauge their effectiveness. To learn about your choices regarding this sharing of your information please see “Your Access and Choices regarding your Personal Information” section below.

You can understand which third parties have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website at http://optout.networkadvertising.org/; or the Digital Advertising Alliance’s website at http://optout.aboutads.info or, if you’re located in the European Union (“EU”), at http://www.youronlinechoices.eu from your browser. For more information on mobile specific opt-out choices, please visit http://www.networkadvertising.org/mobile-choices and from your mobile device.

On your mobile device you may have features that allow you to opt out of some targeted advertising (“Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android)). To learn more about how these opt-out features work, please review your device settings.

Even if you disable the tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, though such advertising may not be based on your interests and preferences.

We may share data, such as technical identifiers derived from your registration information on our website or our CRM system with our trusted advertising partners: Criteo. This allows them to link devices or browsers and provide you a seamless experience across the different environments used or likely used by you. To read more about the technologies used by our partners and their linking capabilities, if applicable, please refer to their privacy policy listed in the above-mentioned platforms.

We work with service providers (including Google Analytics) who conduct analytics to help us track and understand how visitors use our Site. Google Analytics is a web analytics service provided by Google that uses cookies to help us analyze how users use our Sites. The information generated by the cookies about your use of the Services will be transmitted to and stored by Google on servers in the United States. If you access our Site through different devices, Google may associate your devices with one another. Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). You can prevent Google’s collection and use of the data it collects as defined in its policy by downloading and installing this browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en-GB. For more information about Google Analytics cookies, please see Google’s help pages (https://support.google.com/analytics/answer/6004245) and privacy policy (https://www.google.com/intl/en/policies/privacy/).

We take reasonable precautions to protect your information. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using our Services. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

We are not responsible for the practices employed by websites or services linked to or from the App, including the information or content contained in such websites or services, and this policy does not apply to them. Your browsing and interaction on any third-party website or service, including those that have a link on our Site, are subject to that third party’s own rules and privacy policies. Please read the terms of such websites carefully and exercise care when providing your personally identifiable information.

Social Media Features: Our Services may include links to social media features, such as links to our Facebook page. These features may collect your IP address, which page you are visiting while using our Services, and any Facebook cookies on your device (including your Facebook ID). These services may set cookies to enable the feature to function properly. Please note that the social media services may collect this information even if you are not logged in to the relevant social media account when you are using the Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Our Sites do not support Do Not Track (DNT) at this time. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us  (opens a new window).

If you have any questions about this policy or the services, please contact us at:

Email: info@neweraindustries.com;

Changes To Our Privacy Policy

We may make changes to this policy from time to time, in our sole discretion. We will provide you notice of material changes by indicating that the Privacy Policy has been updated on our homepage and will indicate the last date of update. Your continued use of any of the Services after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the policy, please uninstall any Apps and cease using the Site and Services.

This New Era Industries CCPA Privacy Notice (commencing here and continuing for the remainder of this document), and only this New Era Industries CCPA Privacy Policy Notice, sets forth our privacy practices as required by the CCPA. This CCPA privacy notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”).

There may be instances where we are engaged to provide a service on behalf of another business or third party who has a direct relationship with you (for example, your employer) involving the collection of your personal information (the “Data Controller”), including, without limitation, with respect to personal information subject to the California Consumer Privacy Act and other applicable privacy laws. In those instances, we may need to access or otherwise process your Personal Information in order to provide the service that we have been engaged to perform for the Data Controller. In performance of those services, we are acting in the capacity of a “data processor” or “service provider” as defined under applicable data privacy law. Where we are acting as a “data processor” or “service provider”, the privacy policy of the Data Controller (for example, of your employer), and not this New Era Industries CCPA Privacy Notice, applies. For example, refer to the privacy policy of the Data Controller for: (i) what Personal Information of yours is collected; (ii) the ways in which your Personal Information may be collected, used and shared; and (iii) any mechanisms available to you for exercising your rights with respect to your Personal Information.

When New Era Industries is not acting as a service provider, we may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, through the mail, and/or over the telephone, including with respect to job applicants. More specifically, New Era Industries collects the following categories of Personal Information from its Consumers, which will depend on the particular business purpose for which we collect it:

Category Examples of Personal Information Collected (not all examples listed are actually collected) A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. B. Financial and Health Information. A name, signature, Social Security number, address, telephone number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information. Note: Some personal information included in this category may overlap with other categories. C. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Some personal information included in this category may overlap with other categories. D. Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).E. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. G. Geolocation data Physical location or movements. H. Sensory  data Audio, electronic, visual, or similar information. I. Professional or employment-related information Job history or performance evaluations. J. Inferences drawn from other personal information Preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information does not include deidentified or aggregated Consumer information.

New Era Industries obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Site, or from information your computer or mobile device transmits when interacting with our Site or Apps, among other things.

We may use, or disclose the Personal Information we collect from you or about you to do one or more of the following:

• Deliver our Services to you, including providing access to our Site’s online features, completing and processing your online purchases or engaging in other transactions with us;
• Communicate with you about the Services, including to respond to your customer service requests or respond to any other inquiry or correspondence you send to us, as well as respond to you using our Live Chat feature;
• Present you with marketing relating to our Services, including promotions, coupons and other discount offers, and more relevant display advertisements;
• Provide you updates, reminders, or other informational or educational content;
• Enable you to participate in a contest, sweepstake, promotion, or survey;
• Enable you to participate in blogs and post reviews or testimonials. If you provide a review or testimonial, your name will be publicly posted along with the review or testimonial. Please remember that blogs, reviews, and testimonials are located in the public areas of our Site. Do not share content that you would not want others to read, save, or share;
• Consider you for employment. When you apply for a job, we will notify you of any additional uses of your information relating to the information you provide us;
• Analyze and improve the Site and Services, including developing and improving products and services, monitoring and analyzing trends and usage;
• Prevent, detect, investigate, or remediate security or other legal concerns, including fraud;
• Protect the rights, property, or safety of us our users, or any other person or the copyright-protected content of the Services;
• Comply with applicable laws, regulations, or industry requirements, or respond to subpoenas or government requests;
• Analyze and help us better understand how users access and use our Services, including monitoring, evaluating, and analyzing trends, which features and portions of our Services are most popular, how they are used, and the results that are obtained;
• Troubleshooting;
• Statistical purposes including identifying geographic regions of visitors to our Services;
• Support our relationship with you by contacting you about Service usage and assist you in better using our Services and evaluating frequently asked questions;
• Improve our Services and develop new features and Services;
• Benchmark our Services against other products and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or agreed to by you;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of New Era Industries assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by New Era Industries about our Consumers is among the assets transferred;
• For other internal business purposes as we may determine from time to time; and
• Fulfill any other purpose for which you provide it.

New Era Industries may disclose your Personal Information to a third party for a business purpose, including to our service providers. We share your Personal Information with service providers and as otherwise set forth in our full Privacy Policy set forth above.

In the preceding twelve (12) months, New Era Industries has disclosed all categories of Personal Information for a business purpose that are displayed in the table above. In addition, we disclose your Personal Information for a business purpose to service providers and as otherwise set forth in our full Privacy Policy set forth above.

The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Except in certain cases where the CCPA does not require us to do so, you have the right to request that New Era Industries disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Skip to Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business or commercial purpose for collecting that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific pieces of Personal Information we collected about you; and
• If we disclosed your Personal Information for a business purpose, a list disclosing: disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Except in certain cases whether the CCPA does not require us to do so or provides an exception, you have the right to request that New Era Industries delete any of your Personal Information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see Skip to Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies or the CCPA does not require us to do so.

Exceptions: In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by: calling us at 1-832-532-4048, emailing info@neweraindustries.com, or mailing an inquiry to: New Era Industries & Associates, Inc. Attn: Privacy Team, 77 Sugar Creek Center, Suite 600, Sugar Land, TX 77478.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you have any questions or comments about this notice, the ways in which New Era Industries collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 (307) 200-0600
Email: info@neweraindustries.com
Postal Address:
New Era Industries, Inc.  dba  New Era Commodities
ATTN: Privacy Team
1309 Coffeen Avenue
Sheridan, WY 82801