1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. 2NNS LLC, doing business as Newr (“Newr,” “Company,” “we,” “us,” and “our”), respects your privacy and is committed to protecting it through compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website available at https://www.newrcompany.com/ as well as any websites and blogs directly owned by, or operated by or on behalf of, the Company where this Policy is linked (collectively, our “Website”);
• How you use, and the types of information we collect from you on, our mobile applications, including the Newr application, and any other mobile applications directly owned by, or operated by or on behalf of, the Company and where this Policy is linked (the “Applications”); and how the Newr 'Chef' battery-powered induction cooktop and any related Newr-branded hardware (the “Device”) interact with the Applications via Bluetooth. The Website, Applications, and Device together are the “Platform”;
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Platform or in emails and other electronic messages between you and the Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use the Platform. By using the Platform, you agree to the terms of this Policy. Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. If we make changes to this Policy, we may also provide notice through the Platform or by email to the address associated with your account See “Changes to this Policy” below for more information.

2. Other Newr Terms

This Policy should be read in conjunction with our Website Terms of Use and our App & Device Terms of Use, into which this Policy is incorporated by reference.

For any purchases on the Platform, our Product Purchase Terms and Conditions will apply.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Platform may collect the following categories of Personal Information from users of the Platform:

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you register yourself with the Platform; place an online order; subscribe to one of our e-newsletters; review or comment on one of our products; participate in a voluntary survey; or communicate with us, such as to request information.
• From your Device. The Device records Device Data (defined above) in its internal memory whenever it is powered on, whether or not the Application is connected and whether or not a cooking session is in progress. The Device has no internet connection of its own. When the Application next connects over Bluetooth Low Energy, the Device transfers its stored Device Data to the Application. No Newr account and no internet connection are required to cook or charge. From the Application, Device Data reaches Newr in two forms: (i) Analytics Data. Records of Device operation transmitted automatically when an internet connection is available. We use it for reliability, thermal and battery engineering, firmware quality, and fault-rate analysis. (ii) Support Data. When you contact us about a problem, or choose to send us a diagnostic or crash report, the Application sends a copy of your Device's recent Device Data together with the Device serial number, so that we can diagnose the issue and determine next steps for support, warranty, or return. Analytics Data contains no Device serial number and no account identifier, and Newr does not maintain a means of associating it with a purchaser. Records that identify a particular Device, such as Support Data, are transmitted only when you ask us for help.
• Directly and indirectly from activity on the Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Cookies and Similar Technologies” section below.
• Third-Party Sources. We may collect information about you from third-party sources, such as our business partners (for example, our payment processor Stripe, our shipping carriers, and our authorized resellers when we begin selling through those channels).

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free-text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, payment-card numbers in plain text, or other sensitive personal data, unless required for our services.

Username and Password. We may ask you to create a username and password that should only be known to you.

Bluetooth Permissions. Depending on your mobile device's operating system and version, the operating system may ask your permission for location access in order to permit Bluetooth scanning. Granting or denying that permission does not cause any location data to be collected, stored, or transmitted to Newr, and the Device itself has no location sensing capability.

Credit Card Information. For any credit-card information provided on the Platform, we utilize a trusted third-party PCI-DSS compliant payment processor to process your transactions. The payment processor collects and maintains the information needed to complete such transactions. We use Stripe, Inc. (“Stripe”) as our payment processor. Stripe may act as a data processor to process your payments. Stripe may act as a data controller for some of your payment processing information. You may read Stripe’s privacy policy and terms for more information. By processing payments from the Platform that use Stripe, you consent to Stripe’s privacy policy and terms.

Recording Use of the Platform. We may partner with trusted third-party vendors to analyze performance and traffic of the Platform. This may include things like buttons you click, mouse movements and other behavior on the Platform, date and time of access, pages visited, web beacons, and cookie or pixel-tag information. Please see our “Cookies and Similar Technologies” section below to learn more about cookies, pixel tags, and analytic technologies.

Aggregated and De-Identified Data. We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-identified data may be derived from your Personal Information but is not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. If we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

4. Cookies and Similar Technologies

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website.

The Applications collect only the operational data described in Section 3 above (account, device telemetry, and similar information necessary to operate the Platform and provide the services you have requested).

We may use the automatically collected Website information to: (i) conduct analyses about the Website; (ii) associate the different devices you use; (iii) remember your browser or device; (iv) remember your preferences and interactions; (v) deliver relevant advertisements or other content; (vi) market our services to you; (vii) collect information about our Website and services; and (viii) log activity on the Website.

Some of the tools we use to automatically collect information about you may include:

1. Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them: (1) session cookies, which do not stay on your device after you close your browser, and (2) persistent cookies, which remain on your device until you delete them or they expire.
2. Analytics Services. Our Website may use Google Analytics, Google Audiences, LinkedIn, and others for audience-measurement and analytics purposes. These analytics services may use cookies or similar technologies to collect information to help us analyze users and how they use our Website. You may review Google’s data privacy practices for Google Analytics and data privacy practices for Google Tag Manager. To opt out of Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on.
3. Advertising Services. We may use service providers and partners to serve advertisements on our behalf on the Website and across the internet, and to track and report on the performance of those advertisements. These service providers may include Google Ads, Facebook (Meta), LinkedIn, and others. These entities may use cookies or similar technologies to identify your device when you use the Website and interact with our electronic communications and ads, as well as when you visit other online services. Data collected and maintained by such third-party ad providers will be subject to the privacy policies and legal terms of those providers. You may learn more about online interest-based advertising by visiting this Federal Trade Commission website.
4. Web Beacons. A web beacon is an electronic image. Web beacons can track certain things from your computer and report activity back to a web server. If you choose to receive emails from us, we may use web beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage may use web beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information.
5. Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
6. Third-party Websites and Services. We work with a number of service providers of marketing-communications technology. These service providers may use various data-collection methods to improve the performance of the marketing campaigns we are contracting them to provide.

If you do not wish to have cookies on your devices, you may turn them off at any time by using cookie-management tools on the Platform, such as our cookie banner which pops up on new device or new browser accessing our Website, or by modifying your internet browser's or device's settings. Please refer to the help section of your browser or mobile device for additional information. Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID. By disabling cookies on your browser or device, you may be prohibited from full use of the Website's features or lose access to some functionality.

You may opt out of receiving interest-based advertisements from other companies that perform interest-based advertising services who are members of the Digital Advertising Alliance (DAA) by visiting the DAA website or YourAdChoices.

Mobile Application. The Newr Application communicates with your Device over Bluetooth Low Energy and does not require a Newr account or an internet connection in order to cook or charge. When you first connect a Device, the Application asks you to accept the App & Device Terms of Use and presents notice of the Device Data collection described in Section 3. Thereafter the Application transmits Analytics Data automatically when an internet connection is available.

5. How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Security, credit, or fraud-prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use the Platform;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of the Platform;
• Operating, maintaining, monitoring, and improving the safety and performance of the Device, including delivering firmware updates and security patches;
• Sending you safety notices, recall communications, and other communications required by the U.S. Consumer Product Safety Commission or other regulators;
• Inviting you to participate in surveys and providing feedback to us;
• better understanding your needs and interests;
• improving the content, functionality and usability of the Platform;
• improving our products and services;
• improving our marketing and promotional efforts; and
• Any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.

6. How We Disclose Your Information

We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties:

• Our Affiliates. We may disclose the information collected through the Platform with our affiliates, subsidiaries, and other related entities in order to provide our products, services and effective customer support.
• Third-party Service Providers. We disclose Personal Information collected through the Platform with third-party service providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. Service Providers may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information-technology and related infrastructure support, customer service, email delivery, and auditing.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons. We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order; to respond to duly authorized information requests from law enforcement or other governmental authorities; to enforce our agreements, policies, or Terms of Use; to investigate and prevent security threats, fraud, or other malicious activity; or to respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
• Sale of Business or Merger. If we engage in or contemplate a merger, acquisition, sale of assets, financing, reorganization, bankruptcy, or similar transaction, Personal Information may be disclosed to potential or actual counterparties (subject to confidentiality protections) and may be transferred to the successor entity as part of the transaction. We will use reasonable efforts to ensure the successor entity will be bound by privacy commitments at least as protective as this Policy.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company. Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.
• Service and Warranty Partners. Where a Device is serviced, repaired, or returned through a Newr service partner or authorized dealer, we may disclose the Support Data associated with that Device to that partner for service diagnosis, warranty administration, and safety follow-up.

7. Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery-confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions. These service communications may include warranty notices, safety bulletins, firmware-update notifications, and recall communications, which we may send regardless of your marketing preferences.

8. Text Messaging

We may send you account-related and transactional text messages, such as account-verification codes, order-status updates, warranty notifications, and safety/recall communications. We will send marketing text messages only to recipients who have provided prior express written consent through a separate opt-in mechanism. Message and data rates may apply. Message frequency varies. You may opt out of marketing text messages at any time by replying STOP to any such message; you may opt out of transactional messages by closing your account or contacting us at info@newrcompany.com. Not all mobile devices or handsets may be supported. Newr and any mobile carrier are not liable for delayed or undelivered messages. You further acknowledge that: (a) no purchase is required to opt into this service; and (b) you may opt out at any time by following the instructions provided above or in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

9. Access, Correct, and Delete Your Personal Information

If we provide you the option to create an account, you can access, correct, or delete some of the Personal Information we have collected or that you have provided to us by logging into your account and accessing the information displayed in your profile or account settings. If you do not have an account with us, please contact us at info@newrcompany.com to request the access, correction, or deletion of your Personal Information. Before we can process your request regarding your Personal Information, we may need to verify your identity to ensure the security and integrity of your Personal Information. Additionally, certain laws and regulations may require us to retain specific Personal Information or limit the scope of your request, even after verification. In such cases, we will inform you about any restrictions that apply.

10. Information of Minors

The Platform is intended for use by adults age eighteen (18) or older. We do not knowingly collect Personal Information from any individual under the age of eighteen (18), and the Platform is not directed to or marketed to children. We do not knowingly collect Personal Information from any child under the age of thirteen (13) within the meaning of the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq. If we learn that we have inadvertently collected Personal Information from a child under thirteen (13), we will delete it from our systems promptly. If you are a parent or guardian and you believe that your child has provided us with Personal Information, please contact us at info@newrcompany.com so that we can investigate and, if appropriate, delete that information.

11. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. The Platform may link to third-party websites and services. For example, if you click on an advertisement on the Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

12. Your Rights Under State Law

California

• Shine the Light. Pursuant to California Civil Code Section 1798.83, we will not disclose your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
• Do Not Track. Other than as disclosed in this Policy, the Platform does not operate any differently when it receives Do Not Track signals from your internet web browser.

Nevada law permits customers in Nevada to opt-out of the sale of certain kinds of Personal Information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and have any questions, you can contact us at info@newrcompany.com.

13. Location of Services

The Platform is offered only to residents of the United States. We do not currently market the Platform to, or knowingly process Personal Information of, individuals outside the United States. To provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

14. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

15. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through the Platform. We are continually improving and adding to the features and functionality of the Platform along with the products and services we offer through the Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen). We may also contact you by through the Platform or by email using the email that you have provided to us.

16. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at info@newrcompany.com. Our mailing address is:

2NNS LLC DBA NEWR

PO Box 7854

Greenwood, IN 46142