NEWLAB.COM PRIVACY POLICY

Last updated February 2024

Welcome to our website (the “Website”) operated by Newlab LLC and its Affiliates (collectively, “Newlab” or “us”). Our Website provides information about our community of members, our organization and its focus areas, our newsletters, our application process, as well as profiles of our partners and our pilots and other initiatives that have been launched to date (collectively, “Services”).

This Privacy Policy tells you what Personal Information we may collect when you visit the Website, how we may use, protect and disclose that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Use.

By accessing or using this Website, you agree to our Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Website or otherwise use the Services.

1.PERSONAL INFORMATION WE COLLECT

We collect, use, share or otherwise process data that alone or in combination with other information in our possession could be used to identify you (“Personal Information”). The categories of Personal Information that we collect depends on how you interact with us. For example, you may provide us Personal Information when you sign-up or activate a Newlab membership, contact us or inquire about our services, access our locations, interact with the Website, or attend or take part in events.

We may collect Personal Information:
Directly from you when you provide it to us.
• When you create an account.
• When you subscribe to a newsletter.
• When you fill out a form on our Website.
• When you submit a membership application to us. We will collect Personal Information relating to the founders of the applicant company, including names, emails, website URLs, telephone numbers, social media (e.g., Linkedin) accounts, and information on where they live. We will also collect information about the applicant company including its theme and areas of industry and its stage of growth. Additionally, we will collect information about the applicant’s knowledge of and interest in us to assist us in processing and reviewing the application.
• When you activate a Newlab membership.
• When you access our locations.
• When you take part in events provided by us.
• When you interact with our pages on social media sites such as LinkedIn, X (formerly Twitter), or Facebook (collectively, our “Social Media Accounts”).

Information Collected Through Automatic Data Collection Technologies. We also may receive your Personal Information automatically as you navigate through the Website. Information collected automatically may include traffic data, location data, usage details, IP addresses, device information, and information collected through cookies, web beacons, and other tracking technologies. Collecting this information helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

2.HOW WE USE PERSONAL INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information:
• To present our Website and provide Services.
• To respond to your questions, comments or feedback.
• To send administrative information to you, including information about the Services and changes to our Website, terms or other policies.
• To analyze how you interact with our Services.
• To ensure compliance with sanctions regulations.
• To comply with legal obligations and legal process and to protect our rights.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may aggregate Personal Information to help us analyze the effectiveness of the Services and for similar purposes. We may collect aggregated information through the Services and through other means set out in this Privacy Policy.

3.SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
• To our Affiliates, meaning any entity that controls, is controlled by, or is under common control with us Our Affiliates will use any Personal Information we share in a manner consistent with this Privacy Policy.
• To our professional advisors, including our lawyers, bankers, auditors and insurers who provide services to us. Our professional advisors are subject to appropriate obligations of confidentiality with respect to Personal Information.
• To contractors, service providers, and other third parties we use to support our business and who, pursuant to our instructions, will access, process, or store Personal Information in the course of performing their duties to us.
• If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or Affiliate as part of that Transaction along with other assets.
• If we are required to do so by law or, if it is our good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Website, or the public, or (v) protect against legal liability.
• To third parties upon your request, at your direction or with your consent.

Disclosures of Application Information.
Because Newlab receives and expects to continue in the future to receive a high volume of applications from prospective founders, investors and agency partners we cannot accept responsibility for protecting against the disclosure or unauthorized use of any general information or related materials that may be included in any application information provided to us. We ask that you take this into consideration and use special care when you choose what application information to send us. If and when you do submit any general information to us, you do so at your own risk. Any such information may be used or disclosed by us or any person with whom we share your application for any purpose and in any manner. We implement commercially reasonable measures to protect application information; however, internet and email transmissions (including through the Website) are never fully secure or error-free, so we ask you to exercise caution in deciding what application information you send us.

4.YOUR CHOICES, UPDATING YOUR INFORMATION, DELETION REQUESTS 
 
 
We strive to provide you with choices regarding your Personal Information. In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Services, you may be unable to use those features. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Accessing and Correcting Your Information. You may also send us an email at privacy@newlab.com to request access to, correct, or delete any personal information or any application related information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Account Updates. You can log into your Newlab membership account to change or correct Personal Information

5. YOUR STATE PRIVACY RIGHTS   
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide their state residents with rights to:
• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
• targeted advertising (excluding Iowa);
• sales; or
• profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data. The exact scope of these rights may vary by state. To exercise any of these rights please contact us at privacy@newlab.com.

6. DATA SECURITY   

We have implemented commercially reasonable measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

7. INTERNATIONAL USERS   

By using our Website and Services, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.

8. CHILDREN   

Our Website is not intended for or directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Website, please contact us at privacy@newlab.com and we will endeavor to delete that information from our databases.
  
9. CHANGES TO OUR PRIVACY POLICY   
 
Our business and the Services may change from time to time, and we may change this Privacy Policy at any time. If we change this Privacy Policy, we will post an updated version on this page, unless another form of notice is required by applicable law. By continuing to use the Website or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

10. CONTACT INFORMATION   

To ask questions or comment about this Privacy Policy or our privacy  practices, you can contact us at: privacy@newlab.com.