Privacy Policy

NRL Media, Inc. d/b/a Newrich (collectively referred to as “Newrich,” “we,” or “us”) operates an online marketplace where digital goods and services are offered by independent sellers (“Sellers”) and purchased by customers (“Buyers”). All products available through the marketplace are created and provided by the applicable Seller. Newrich provides the platform that facilitates these transactions but does not create, control, or take responsibility for the products offered by Sellers.

In this Privacy Policy (“Policy”), we explain how we collect, use, disclose, and otherwise process personal information, as well as the rights and choices you may have regarding that information.

For more information about the options available to you with respect to your personal information, please see Section 7: Your Privacy Choices and Section 15: Additional Privacy Information for Certain Jurisdictions, which provides additional details about privacy rights available to residents of certain locations. If you are a resident of California, please also review our CCPA Privacy Notice, which explains our data practices and outlines your rights under California privacy law, including the right to opt out of the sale of personal information.

Additional details about our privacy practices, including your rights and available choices, are provided in the sections of this Policy described below.

1. Scope

This Privacy Policy applies to the personal information that Newrich collects, uses, and processes in connection with the following individuals and activities:

• Users of our websites and applications, including www.newrich.com, as well as any hosted applications, mobile apps, downloadable software, or other digital services operated by Newrich that reference or link to this Policy (collectively referred to as the “Services”).
• Current, former, and prospective Buyers who purchase products through the Services or who interact with us for customer support, troubleshooting, or other service-related inquiries.
• Current, former, and prospective Sellers who offer products, memberships, or other services through the Services, or who communicate with us regarding support, troubleshooting, or other platform-related matters.
• Participants in our affiliate or referral programs, including individuals who promote products available on our Services or refer new Buyers to the platform.
• Individuals who register for or participate in promotions, contests, sweepstakes, webinars, surveys, research initiatives, events, or other programs administered by Newrich.
• Individuals who subscribe to receive newsletters, updates, or marketing communications from Newrich.
• Anyone who communicates with us, interacts with our Services, or otherwise engages with Newrich in connection with the platform or our business operations.

Not Covered by This Policy

This Privacy Policy does not apply to personal information collected from job applicants, employment candidates, employees, or independent contractors through our hiring or employment processes. That information is governed by separate privacy notices.

Your use of the Newrich website and Services, as well as any disputes relating to privacy, are governed by this Privacy Policy and our Terms of Service, including provisions addressing limitations of liability and dispute resolution procedures. The Terms of Service are incorporated into this Privacy Policy by reference.

2. Personal Information We Collect

We collect personal information in several ways, including information you provide directly to us, information obtained from third parties, and information collected automatically when you interact with our Services.

A. Information You Provide Directly

The types of personal information we collect may vary depending on how you interact with Newrich and our Services. In general, this information may include the following:

Account Registration and Profile Information

When you create a user account, we may collect information such as your name, username, email address, and phone number. We may also collect information associated with your account profile, including connected accounts, account balances, payment details, purchase history, and other preferences or settings related to your account.

Communications and Customer Support

If you contact us or interact with us through the Site or Services—such as through email, chat, support requests, or other communication channels—we may collect and retain information related to those interactions. This may include your contact details, communication preferences, the content of messages or chat logs, and records of our responses. These interactions may occur when you request support, ask questions about our Services, subscribe to communications, or otherwise provide information to us.

Payment and Billing Information

In connection with user accounts and transactions, we may collect billing and payment information necessary to provide our Services. This may include billing contact details, addresses, and payment-related information. In certain cases, we may also collect payment and identification details related to participation in programs such as affiliate programs, bug bounty initiatives, or similar programs that involve payments.

Events and Programs

If you register for or attend an event hosted or sponsored by Newrich, we may collect information related to your registration and participation in that event.

Promotions and Surveys

When you participate in contests, promotions, sweepstakes, or similar programs, we may collect information such as your name, email address, and other registration details required to administer the promotion. We may also conduct surveys to better understand user preferences and improve our Services. If you choose to respond to a survey or feedback request, we may collect your contact information and any responses you provide.

B. Personal Information from Third-Party Sources

In addition to the information you provide directly, Newrich may collect personal information about you from other sources, including public databases, business partners, and third-party service providers. Examples of such information include the following:

Service Providers and Vendors

We work with third-party vendors and service providers to operate and support our Services. These providers may collect certain technical information in connection with delivering services on our behalf, such as IP addresses, device identifiers, and information about user activity, which may then be shared with us.

Lead and Prospect Information

We may obtain information about potential Buyers, Sellers, or other users from third-party sources that provide lead generation or marketing services. This information may help us identify individuals who may be interested in our Services. In some cases, we may also use third-party data sources to enhance or update existing user information.

Social Media and Third-Party Platforms

If you interact with Newrich through social media or other third-party platforms, or if you choose to link or sign in to your account using a third-party service (such as a Google account), we may receive certain information from that platform. The information shared with us is controlled by the third-party platform and may depend on your privacy settings and the permissions you grant. To understand how these platforms collect and share your information, you should review their respective privacy policies.

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C. Information We Collect Automatically or Derive

When you access or use the Newrich Services, we may automatically collect certain information about your interactions with the platform. This may occur through the use of cookies, pixels, analytics tools, or other tracking technologies. We may also derive certain insights from this information, such as approximate location or patterns of platform usage.

Device and Browsing Information

We may use cookies, software development kits (SDKs), pixel tags, and similar technologies to collect information about your device and browsing activity when you use our Site or Services. This information may include your IP address, device identifiers, general location data (and in some cases device-level location), browser type, domain names, access times, page views, timestamps, operating system, language settings, device type, internet service provider, referring URLs, exit pages, and other similar usage data.

Additional details about how we use cookies and tracking technologies are available in the “Cookies, Targeting, and Analytics” section of this Policy.

Usage and Activity Information

We also collect information about how users interact with the Services. This may include details such as links clicked, searches performed, features used, pages visited, time spent on the platform, and files uploaded.

We may also collect system logs and technical activity data in order to:

• Identify the source and destination of communications

• Maintain and optimize the performance of our platform and services

• Monitor for fraud, abuse, or security incidents

• Detect unauthorized access or misuse of the Services

• Investigate system issues or suspicious activity

3. Purposes of Collection and Use

The reasons we collect and process personal information may vary depending on how you interact with Newrich, the Services you use, and the specific circumstances involved.

A. Legal Bases for Processing

Certain privacy laws—including the European Union General Data Protection Regulation (GDPR) and similar data protection laws in the United Kingdom and other jurisdictions—require us to explain the legal grounds on which we process personal information.

Under these laws, Newrich may process personal information on the following legal bases:

Performance of a Contract

We process personal information when it is necessary to enter into, administer, or fulfill a contract with you. This includes providing access to our Services, facilitating transactions on the platform, and fulfilling obligations associated with your account.

Compliance with Legal Obligations

We may process personal information when necessary to comply with applicable laws, regulations, or legal processes. This may include obligations related to employment and labor laws, taxation, financial compliance, data protection requirements, corporate governance, or responding to legal claims or regulatory inquiries.

Legitimate Business Interests

We may process personal information when it is necessary for our legitimate business interests, provided that these interests do not override your fundamental rights and freedoms. These interests may include:

• Performing contracts with customers, partners, and service providers

• Operating, maintaining, and improving our Services and related infrastructure

• Providing customer support and technical assistance

• Managing customer relationships and communications

• Monitoring, detecting, and preventing fraud, abuse, security threats, and unauthorized activity

• Maintaining the security of our systems, networks, and facilities

• Protecting users, their accounts, and their data from harm or misuse

• Conducting internal investigations where necessary

• Enhancing and developing new products, services, and features

• Performing data analysis, research, market studies, and trend analysis

• Supporting business transactions such as mergers, acquisitions, reorganizations, or other corporate activities

Consent

In certain situations, we may rely on your consent to process personal information. Where consent is required under applicable law, you have the right to withdraw your consent at any time by contacting us using the information provided at the end of this Privacy Policy. In some jurisdictions, your continued use of our Services may be interpreted as consent to the data practices described in this Policy.

Protection of Vital Interests

We may also process personal information when necessary to protect the vital interests of an individual, such as situations involving the protection of life, safety, or physical well-being.

B. Purposes for Processing Personal Information

In general, Newrich processes personal information for the purposes described below. Where applicable laws such as the GDPR apply, we also identify the legal basis for the processing activity in parentheses.

Providing Services and Customer Support

We use personal information to operate and maintain our Site and Services, process transactions, communicate with users regarding their accounts, and provide customer support or technical assistance. This includes responding to questions, troubleshooting issues, and facilitating payments or other account-related activities.

Service Communications

We may send users administrative messages related to the Services, such as notices, updates, security alerts, and other service-related communications. We may also contact users regarding applications, program participation, or to distribute surveys and questionnaires for research purposes.

Analytics and Service Improvements

We analyze how users interact with the Services to better understand usage patterns, improve performance, develop new features, and enhance our overall offerings. This may include internal research, product development, and quality control activities.

Advertising and Ad Measurement

We may promote Newrich services through advertising on third-party websites and platforms. Personal information may be used to evaluate the reach and effectiveness of advertising campaigns and to generate analytics or reporting for advertising partners.

Marketing and Promotional Communications

We may use personal information to send newsletters, product announcements, updates, or promotional communications that may be relevant to you. We may also analyze marketing performance to improve future communications and outreach. When you apply for a job we may contact you with marketing about our products and services and that you can opt out anytime.

General Business Operations

Personal information may be processed in connection with internal business operations such as accounting, auditing, recordkeeping, compliance activities, and the evaluation or execution of business transactions including mergers, acquisitions, or reorganizations.

Security and Protection of Rights

We may process personal information to maintain the security and integrity of our platform. This includes detecting and preventing fraud, misuse, unauthorized access, or other harmful activity, as well as investigating violations of our Terms of Service or this Privacy Policy.

Legal Compliance

We may process personal information when necessary to comply with applicable laws or legal obligations, including responding to lawful requests from regulators, courts, or law enforcement authorities.

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Disclosure of Information

We may share or disclose the personal information we collect with others when necessary for the purposes described above or when authorized by you. This may include the following categories of recipients:

Service Providers and Vendors

We may share information with vendors, contractors, and service providers that perform services on our behalf. These may include providers of hosting, analytics, payment processing, data services, or technical support.

Affiliates and Subsidiaries

Personal information may be shared with affiliated companies or subsidiaries. Any such use will remain subject to this Privacy Policy.

Sellers, Affiliates, and Fulfillment Providers

To complete purchases made through the marketplace, we may share certain information with Sellers or affiliates involved in fulfilling the transaction. This may include information such as purchase confirmation, username, contact information, and limited account profile details relevant to the order.

Other Users of the Platform

Certain platform features allow users to publish or share content within the Services. This may include comments, product descriptions, images, reviews, or other user-submitted content (“User Content”). Information shared in these areas may be visible to other users of the Services.

Advertising and Analytics Partners

We may share information with advertising measurement providers or analytics partners that help us understand how content and advertisements perform. These partners may collect or receive information about your interaction with content or ads on our Services and on third-party platforms where our advertisements appear.

Protection of Rights and Safety

We may disclose information to law enforcement agencies or other third parties when we believe it is necessary to protect the Services, our rights or property, or the rights, property, or safety of others. This may include disclosures made in order to:

• Prevent, detect, investigate, or respond to fraud, unauthorized access or activity, illegal conduct, or misuse of the Services;

• Address situations that present potential risks to the health, safety, or legal rights of any individual or third party; or

• Enforce our Terms of Service, including investigating and responding to violations of our policies or agreements.

We may also disclose personal information when necessary in connection with legal proceedings, litigation, or claims involving the company, as well as for purposes related to our internal accounting, auditing, compliance, recordkeeping, and legal obligations.

Legal Compliance

Information may also be disclosed in order to comply with legal obligations or lawful requests, including subpoenas, court orders, regulatory inquiries, or other legal processes.

Business Transfers

If Newrich is involved in a merger, acquisition, asset sale, bankruptcy, or similar corporate transaction, personal information may be transferred to the relevant parties as part of that process, including during negotiations related to the transaction.

5. Aggregate and Non-Identifiable Information

We may collect, generate, and use aggregated, anonymized, or otherwise non-identifiable information related to the operation of our business and Services. This type of information does not identify an individual user and may be used for purposes such as quality assurance, analytics, marketing, advertising, research, product development, compliance, and other business operations.

When information has been de-identified, we will maintain and use that data in its de-identified form and will not attempt to reidentify the information, except where permitted or required under applicable privacy laws.

6. Cookies, Targeting, and Analytics

Newrich and our third-party service providers use cookies, pixels, JavaScript, and other similar technologies to automatically collect information about how users interact with our Services. This may include browsing behavior, device information, and activity data. We use this information to better understand how users access and use the platform, how they interact with features or other users, and to help identify and resolve bugs or technical issues. These tools also assist us in maintaining security, optimizing performance, and improving the overall functionality of our Services.

Additional details about cookies and similar technologies can be found in our Cookie Policy, which applies to websites that reference or link to that policy.

Cookies

Cookies are small alphanumeric files that are stored on your device when you visit a website. They allow us to recognize your device and store certain information about your preferences or activity.

Some cookies help improve your experience by allowing easier navigation within the Services, while others enable us to measure usage patterns, support security functions, and analyze platform performance.

Most browsers accept cookies automatically. However, you can typically adjust your browser settings to block cookies, notify you when cookies are set, or delete stored cookies. Instructions for managing cookies can usually be found in your browser’s help section.

Pixel Tags

Pixel tags (sometimes referred to as web beacons or clear GIFs) are small graphics embedded within webpages or emails. They function similarly to cookies but are not stored directly on your device.

We may use pixel tags to monitor website traffic, understand how users interact with content, and generate statistical data about the use of our Services. Pixel tags may also be used in email communications to measure engagement, such as whether a message was opened or forwarded.

Third-Party Analytics

We may use third-party analytics providers, such as Google Analytics, to help analyze how users interact with our Services. These providers may use cookies and similar tracking technologies to collect information about usage patterns, which helps us improve platform performance, evaluate marketing campaigns, and enhance the user experience.

Do Not Track Signals

Some web browsers include a “Do Not Track” feature that signals to websites that the user does not wish to have their online activity tracked. At this time, our systems do not respond to browser-based “Do Not Track” signals. However, users may limit tracking by managing cookies and other tracking technologies through their browser settings.

Advertising and Targeting

We may work with third-party advertising networks, analytics providers, and measurement partners to deliver advertising and promotional content. These partners may use cookies, pixel tags, and other technologies (sometimes referred to collectively as targeting cookies) to collect information about activity within our Services and across other websites or platforms.

Information collected may include IP address, approximate location data, device identifiers, cookie identifiers, advertising identifiers, and browsing activity. This data helps us and our advertising partners provide more relevant advertisements and measure the effectiveness of advertising campaigns.

Managing Your Preferences

You have several options for managing your preferences related to cookies and targeted advertising. Many of these settings are browser-specific, which means you may need to adjust preferences separately for each browser or device you use.

If you delete cookies or clear your browser data, you may need to reapply your preferences.

Opting out of certain tracking technologies does not necessarily mean you will stop seeing advertisements entirely. You may continue to see general or contextual advertisements that are not based on personalized data.

Cookie Preference Manager

Where available, you may review or modify cookie preferences directly through the cookie settings available on our Site.

Browser Settings

You may configure your browser to block or delete cookies, or to notify you when cookies are being set. Please note that some features of the Services may not function properly if cookies are disabled.

Industry Advertising Opt-Out Programs

You may also control how certain advertising networks use information collected about your browsing activity through the following industry programs:

United States:

https://aboutads.info/choices (Digital Advertising Alliance)

Mobile users may also download the DAA AppChoices tool to manage interest-based advertising within mobile apps.

European Union:

https://youronlinechoices.eu (European Interactive Digital Advertising Alliance)

Please note that opting out through these programs only affects participating advertising networks. You may still receive advertising from companies that do not participate in these programs, and you may continue to see non-personalized advertising within our Services.

7. Your Privacy Choices

Users have several options for managing their personal information and privacy preferences, as described below.

Marketing Communications

We may send promotional emails, newsletters, or other marketing communications from time to time. You may opt out of receiving these communications by following the unsubscribe instructions included in the email or by contacting us at support@newrich.com. Please note that it may take up to ten (10) business days for opt-out requests to be fully processed.

Even if you opt out of marketing communications, we may still send you important service-related messages, such as communications about your account, purchases, or other services you have requested or received from us.

Cookies and Targeted Advertising

As described in the “Cookies, Targeting, and Analytics” section of this Privacy Policy, you can manage your preferences related to cookies—including targeting or advertising cookies—by adjusting the cookie settings available on our Site or through your browser settings.

Mobile Device Settings

Some of our mobile applications may send push notifications to inform you about updates, features, or promotions. With your permission, we may also collect location information from your mobile device.

If you no longer wish to receive these notifications or share location information, you can adjust your mobile device or application settings at any time.

Accessing and Updating Your Account Information

If you have created a Newrich account, you may review and update certain personal information associated with your account through your profile settings.

Please note that we may retain copies of information you modify or delete where necessary for legitimate business purposes, recordkeeping, or legal compliance.

Additional Information for Certain Jurisdictions

Additional information about privacy rights under certain data protection laws—including the GDPR, UK data protection laws, and certain U.S. state privacy laws—is provided in Section 15: Additional Information for Certain Jurisdictions.

Residents of certain jurisdictions may have additional rights regarding their personal information. If you are a California resident, please review Section 15.C: CCPA Privacy Notice for California Residents, which provides details about your rights under California privacy law and how to exercise them.

For additional questions about our privacy practices or your privacy choices, you may contact us using the details provided in the Contact Us section of this Privacy Policy.

8. Information About Children

Our Services are not designed for or directed toward children under the age of 13. We do not knowingly collect or process personal information from individuals under 13 years old.

If we become aware that personal information from a child under the age of 13 has been collected without appropriate authorization, we will take steps to delete that information as soon as reasonably possible.

If you believe that a child under 13 may have provided personal information to us through the Services, please contact us at support@newrich.com, and we will take appropriate action to investigate and remove the information where necessary.

9. Third-Party Sites and Services

Our Services may include links to websites or services operated by third parties. If you choose to access these external sites, your use of those websites will be governed by the privacy policies and terms of the respective third parties, not by this Privacy Policy.

We do not control and are not responsible for the privacy practices, content, or policies of third-party websites or services. We encourage you to review the privacy policies of any external sites you visit before providing personal information.

10. International Data Transfers

Newrich is headquartered in the United States and works with service providers and partners located in various countries around the world. As a result, your personal information may be transferred to, stored in, or accessed from jurisdictions outside your country of residence, including the United States. These jurisdictions may have data protection laws that differ from those in your home country.

When transferring personal information internationally, we take reasonable steps to ensure that your information receives an appropriate level of protection. This may include implementing contractual safeguards, data processing agreements, or other legally recognized mechanisms designed to protect personal information when it is transferred across borders.

If you are located in the European Economic Area (EEA) and your personal information is transferred to a country that the European Commission has not determined to provide an adequate level of data protection (sometimes referred to as a “third country”), we will implement appropriate safeguards. These safeguards may include the use of Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms recognized under applicable data protection laws.

Individuals in the EEA have the right to request additional information about the safeguards used when transferring personal information outside of the EEA. If you would like further details about these mechanisms, you may contact us using the information provided in the Contact Us section of this Privacy Policy.

11. Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect the personal information we maintain from unauthorized access, use, alteration, or disclosure.

Despite these safeguards, no security system can guarantee complete protection. As a result, we cannot ensure or warrant the absolute security of personal information.

Users should also take steps to protect their own accounts and devices. For example, you should keep your password confidential, avoid sharing access to your account, and sign out of your account when using shared or public devices.

12. Data Retention

In general, we retain personal information for as long as it is reasonably necessary to fulfill the purposes for which it was collected and processed, as described in this Privacy Policy.

Where permitted or required by applicable law, we may also retain personal information for additional periods in order to meet legal or regulatory obligations, resolve disputes, maintain appropriate business and financial records, and enforce our agreements or policies.

13. Changes to This Privacy Policy

This Privacy Policy is effective as of the date indicated above. We may update or modify this Policy from time to time, so we encourage you to review it periodically.

If changes are made, the updated version will be posted on our Site. If we make material changes that significantly affect how we handle personal information previously collected from you, we will make reasonable efforts to notify you in advance. Such notice may be provided through email or through a prominent notice on our Site.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or about how your personal information is collected, used, or processed, you may contact us at support@newrich.com.

You may also reach us by mail at the following address:

NRL Media Inc.

16192 Coastal Hwy

Lewes, DE 19958

United States

15. Additional Information for Individuals in Certain Jurisdictions

Residents of certain jurisdictions may have additional privacy rights under applicable data protection laws. The following sections provide information about these rights and how they may apply.

A. Residents of the European Union, European Economic Area, and the United Kingdom

Individuals located in the European Union (EU), the European Economic Area (EEA), and the United Kingdom (UK) may have certain rights regarding the personal information we process about them, subject to applicable legal conditions and limitations.

These rights may include the following:

Right of Access

You may request confirmation of whether we process your personal information and request a copy of the information we hold about you, along with certain related details about how it is used.

Right to Rectification

You may request that we correct or update any personal information that is inaccurate or incomplete.

Right to Erasure

In certain circumstances, you may request that we delete your personal information—for example, when the information is no longer necessary for the purposes for which it was collected or when consent has been withdrawn (where applicable). In some cases, deletion may involve closing or deleting your account.

Right to Restrict Processing

You may request that we limit the processing of your personal information in certain situations, such as when you dispute its accuracy or object to the legal basis on which we process it.

Right to Data Portability

You may request a copy of certain personal information that you have provided to us in a structured, commonly used, and machine-readable format. Where technically feasible, you may also request that we transfer this information to another organization.

Right to Object

You may object to the processing of your personal information where the processing is based on our legitimate interests. If you object, we will stop processing the information unless we demonstrate compelling legitimate grounds that override your interests or unless the processing is necessary for legal claims.

Right to Object to Marketing

You may object at any time to the use of your personal information for direct marketing purposes. If you exercise this right, we will stop processing your personal information for marketing communications.

Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing where the decision produces legal effects or similarly significant consequences, unless such processing is necessary for a contract or permitted by law.

Right to Withdraw Consent

If our processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Right to Lodge a Complaint

You have the right to file a complaint with a relevant data protection authority if you believe your personal information has been processed in violation of applicable laws.

Exercising Your Rights

To exercise any of the rights described above, please contact us using the contact information provided in the Contact Us section of this Privacy Policy. Please note that some requests may be limited where we have legal obligations or legitimate reasons to retain certain information.

B. Residents of Certain U.S. States

Residents of certain U.S. states—including Virginia, Colorado, Connecticut, and Utah—may have additional rights regarding their personal information under applicable privacy laws, subject to certain limitations.

These rights may include:

Right to Correction

You may request correction of inaccurate personal information, taking into account the nature of the data and the purposes for which it is processed.

Right to Deletion

You may request that we delete personal information we have collected from or about you.

Right of Access

You may request confirmation of whether we process your personal information and obtain a copy of that information in a portable and, where feasible, readily usable format.

Right to Opt Out

You may have the right to opt out of certain types of data processing, including:

• The sale of personal information
• Targeted advertising or cross-context behavioral advertising
• Processing of personal information for automated decision-making that produces significant effects
• Certain uses or disclosures of sensitive personal information

Right to Appeal

If we deny a privacy request, you may appeal our decision by contacting us at support@newrich.com.

Submitting a Privacy Request

You may submit requests related to your privacy rights by contacting us at support@newrich.com. To process your request, we may need to verify your identity by matching information you provide with information in our records.

If an authorized agent submits a request on your behalf (where permitted by law), we may require documentation demonstrating the agent’s authority and may also require verification from the individual whose information is involved.

We will respond to requests in accordance with applicable law.

C. CCPA Privacy Notice for California Residents

This section provides additional disclosures required under the California Consumer Privacy Act (CCPA) and related regulations, as amended. These laws require businesses to provide California residents with specific information about how personal information is collected, used, and disclosed.

This section applies to personal information collected from California residents, whether collected online or offline, and does not apply to publicly available information made lawfully available by government records or other categories of information exempt under California privacy law.

Categories of Personal Information Collected

The categories of personal information we collect and disclose about California residents may vary depending on the nature of the interaction with Newrich. The following sections of this Privacy Policy describe the types of personal information that may be collected and how that information may be used or disclosed for business or commercial purposes.

Category	Description	Categories of Third Parties to Whom Information May Be Disclosed (for Business or Commercial Purposes)
Identifiers	Includes direct identifiers such as name, username, mailing address, email address, phone number, device ID, Internet Protocol (IP) address, and other unique identifiers such as tax identification numbers or employer identification numbers (EIN).	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; advertising networks; data analytics providers; Sellers; internet service providers; operating systems and platforms
Government Identifiers	In certain circumstances, we may collect government-issued identifiers such as Social Security numbers (SSN), driver's license numbers, passport numbers, tax identification numbers, or similar identifiers where necessary to verify identity or comply with legal obligations.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries
Customer Records	Includes account and profile information such as username and password, email address, mailing address, phone number, account credentials, communication preferences, billing and payment information, and other details provided when registering for or using our Services.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; platform operators; advertising networks; data analytics providers; Sellers; internet service providers; operating systems and platforms
Commercial Information	Includes records relating to products or services purchased, obtained, or considered, as well as transaction history and purchasing preferences or patterns.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; advertising networks; data analytics providers; Sellers; internet service providers; operating systems and platforms
Usage Data	Includes browsing history, clickstream data, search history, access logs, and information regarding interactions with our websites, applications, Services, marketing emails, advertisements, and other online services.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms
Location Data	Includes information about the approximate location of a device or user, which may be derived from IP address or other location-enabled technologies.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; internet service providers; operating systems and platforms
Audio, Video, and Electronic Data	Includes audio recordings, visual content, photographs, call recordings (such as customer support calls), chat logs, and other electronic communications or media submitted through our Services.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries
Inferences	Includes profiles or insights derived from personal information, such as preferences, behaviors, interests, or characteristics inferred from activity on the platform.	Vendors and service providers; advisors and agents; government entities and law enforcement; affiliates and subsidiaries; advertising networks; data analytics providers; internet service providers; operating systems and platforms

Sales and Sharing of Personal Information

California privacy laws define a “sale” as disclosing or making personal information available to a third party in exchange for monetary or other valuable consideration. The term “sharing” includes disclosing or making personal information available to a third party for purposes of cross-context behavioral advertising.

Although we do not sell personal information in exchange for money, we may “sell” or “share” certain categories of personal information (as defined under the CCPA) with third parties such as advertising networks, analytics providers, and social media platforms. These categories may include:

• Identifiers
• Customer Records
• Commercial Information
• Audio, Video, and Electronic Data
• Usage Data

We do not sell or share sensitive personal information, and we do not knowingly sell or share personal information of individuals under 16 years of age.

Sources of Personal Information

We may collect the categories of personal information described above from the following sources:

• Directly from you
• Our affiliates and subsidiaries
• Third-party platforms
• Third-party websites and services
• Advertising networks
• Analytics providers
• Social media platforms
• Internet service providers
• Operating systems and device platforms
• Vendors and service providers

Purposes for Collecting and Disclosing Personal Information

As described in Section 3: Purposes of Collection and Use, we collect and process personal information in order to provide and operate our Services and to respond to user requests. Personal information may also be used for the following business or commercial purposes:

• Providing and operating our Site and Services, including customer support
• Communicating with users about the Services
• Analytics, research, and service improvements
• Advertising and marketing activities
• Promotional communications
• General business operations
• Security, fraud prevention, and protection of rights
• Compliance with legal and regulatory obligations

Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes beyond those permitted under the CCPA.

Sensitive personal information is used only as reasonably necessary for the following purposes:

• Providing services requested by users
• Maintaining the security and integrity of our systems
• Detecting, preventing, and investigating fraudulent or unlawful activity
• Maintaining the quality and safety of our Services
• Complying with legal obligations
• Working with service providers that perform services on our behalf
• Other permitted purposes that do not involve creating profiles about individuals

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy.

If you request that we stop using your personal information to provide Services, you may contact us using the contact information provided in this Policy. Please note that if you withdraw consent or object to certain processing activities, some Services may no longer be available to you.

Where permitted by law, we may retain personal information for additional periods to comply with legal obligations, resolve disputes, maintain business records, and enforce our agreements.

California Residents’ Privacy Rights

California residents have the right to receive information about how their personal information is used and disclosed and have the right to exercise certain privacy protections under the California Consumer Privacy Act (CCPA). Exercising these rights will not result in discriminatory treatment.

Subject to certain limitations, California residents may have the following rights:

Right to Opt Out of Sales or Sharing

You have the right to opt out of the sale or sharing of your personal information.

Right to Deletion

You may request that we delete personal information we have collected about you, subject to certain legal exceptions.

Right to Know or Access

You may request access to the specific personal information we have collected about you and request that it be provided in a portable format. You may also request information about:

• The categories of personal information collected
• The categories of sources from which the information was collected
• The business or commercial purposes for collecting, selling, or sharing personal information
• The categories of third parties with whom personal information has been disclosed
• The specific pieces of personal information collected about you

Right to Correct

You may request that inaccurate personal information about you be corrected.

Right to Limit the Use of Sensitive Personal Information

You may request limits on how sensitive personal information is used or disclosed. However, we only use sensitive personal information for purposes permitted under California law.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your privacy rights.

Submitting Requests Under the CCPA

California residents may submit verifiable requests to exercise their privacy rights using the following methods:

Email: support@newrich.com

Mail:

NRL Media, Inc.

16192 Coastal Hwy

Lewes, DE 19958

United States

When you submit a request to access, delete, or correct your personal information, we will take steps to verify your identity by matching the information provided with information in our records. We may request your name, email address, and other contact details, and in some cases additional information may be required to verify your identity.

Authorized agents may submit requests on behalf of another individual where permitted by law. In such cases, we may require proof of authorization and may also require the individual to verify their identity directly.

We will respond to verified requests in accordance with applicable law. If we cannot verify a request, we will notify the requester.

Requests to Opt Out of Sales or Sharing

California residents may request to opt out of the sale or sharing of personal information, including targeted advertising, by contacting us at:

support@newrich.com