Privacy Policy
NEWGAIN is operated by Upperate Digital Marketing Solutions Ltd., Company No. 516657301, with its registered address at 3 Shulamit St., Tel Aviv, Israel (“NEWGAIN”, “Upperate”, “we”, “us”, or “our”).
We respect your privacy and are committed to protecting the personal information of visitors to our website.
This Privacy Policy explains what information we may collect when you visit the NEWGAIN website, contact us, request information, submit a business inquiry, or otherwise interact with us, and how we use and protect that information.
1. Information We Collect
We may collect information in the following ways:
Information You Provide to Us
When you contact us, request information, submit an inquiry, or communicate with us, you may provide information such as:
- Your name
- Business email address
- Phone number
- Company name
- Job title
- Website or company URL
- The contents of your message
- Any other information you choose to provide
You are not required to provide personal information simply to browse our website.
You are not under any legal obligation to provide us with personal information. However, if you choose not to provide certain information, we may be unable to respond to your inquiry.
Information Collected Automatically
When you visit our website, we may automatically collect certain technical and usage information, subject to your
cookie choices, including:
- IP address
- Browser type and version
- Device type
- Operating system
- Approximate geographic location
- Referring website or source
- Pages viewed
- Time and date of visits
- Time spent on pages
- Website interactions
- Cookie and similar technology identifiers
This information helps us understand how visitors use our website and improve its performance and usability.
2. How We Use Your Information
We may use the information we collect to:
- Operate and maintain our website
- Respond to inquiries and requests
- Communicate with prospective customers, customers, and business partners
- Provide information about NEWGAIN and our services
- Evaluate potential business relationships
- Improve our website, products, services, and user experience
- Understand website traffic and usage patterns
- Perform analytics and measurement
- Detect and prevent fraud, abuse, or security incidents
- Maintain the security and integrity of our systems
- Comply with legal and regulatory obligations
- Establish, exercise, or defend legal claims
With your consent, or where otherwise permitted by applicable law, including the Israeli Communications Law (Telecommunications and Broadcasts), we may send you business communications about NEWGAIN.
You may unsubscribe at any time using the link in each message or by contacting us.
3. Google Analytics
We use Google Analytics 4 (GA4) solely to measure and understand how visitors use our website.
Google Analytics may collect information such as:
- Pages you visit
- Time spent on the website
- How you arrived at the website
- General device and browser information
- Approximate location
- Website interaction and usage information
Our Google Analytics implementation is configured for measurement purposes only. Google Signals is disabled, Google Ads is not linked to our Google Analytics account, and advertising personalization is disabled.
We do not use advertising pixels or retargeting technologies on our website.
Google Analytics is controlled by our cookie consent mechanism and is loaded only after you provide consent through the cookie consent banner. We use the information collected through Google Analytics to measure website traffic, understand visitor behavior, identify trends, and improve the website.
Google's processing of information is also subject to Google's applicable privacy terms and policies.
4. Cookies and Similar Technologies
Our website may use cookies and similar technologies.
Cookies are small files stored on your device that may help websites function properly, remember preferences, understand usage patterns, and measure performance.
We may use:
-Essential cookies
These cookies are necessary for the website to function properly.
-Analytics cookies
These cookies help us understand how visitors use the website. Our analytics cookies relate to Google Analytics 4.
-Functional cookies
These cookies may remember preferences and improve website functionality.
Google Analytics does not load until you provide consent through our cookie consent banner.
We do not use advertising or retargeting cookies on our website.
You may manage or withdraw your cookie preferences through the cookie controls available on our website. You may also manage or disable cookies through your browser settings.
Disabling certain cookies may affect some website functionality.
5. Legal Bases for Processing
Where the GDPR, UK GDPR, or similar privacy laws apply, we process personal information based on one or more of the following legal bases:
- Consent, where you have provided consent
- Contractual necessity, where processing is necessary to take steps at your request or perform an agreement
- Legitimate interests, including operating our business, responding to business inquiries, improving our website and services, and protecting our systems
- Legal obligations, where processing is required by applicable law
Analytics cookies, including Google Analytics, are used based on your consent where required by applicable law.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
6. How We Share Information
We may share personal information with third parties that help us operate our business and website, including:
- Website hosting providers
- Cloud and infrastructure providers
- Analytics providers, including Google Analytics
- Communication and email service providers
- Customer relationship management providers
- IT and security providers
- Professional advisers, including lawyers, accountants, and auditors
These providers may process information only as necessary to provide services to us or as otherwise permitted under applicable law.
We may also disclose information where required to:
- Comply with applicable law or legal process
- Respond to lawful requests from authorities
- Protect our rights, property, or security
- Investigate fraud or security incidents
- Enforce our agreements
If NEWGAIN or Upperate is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction, information may be transferred as part of that transaction.
7. Sale and Sharing of Personal Information
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act, as amended. We use service providers, such as hosting and analytics providers, solely to operate and improve our website.
8. International Data Transfers
Our service providers may process information in countries outside your country of residence.
This may include processing in Israel, the European Economic Area, the United States, or other locations where our service providers operate.
Israel benefits from an adequacy decision issued by the European Commission for transfers of personal data from the European Economic Area to Israel.
Where personal information is transferred to service providers in the United States, and where required by applicable law, we rely on recognized transfer mechanisms such as the EU-U.S. Data Privacy Framework for participating organizations or the European Commission's Standard Contractual Clauses, as applicable.
We may also use other legally recognized safeguards where appropriate.
9. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.
The applicable retention period may depend on factors such as:
- The nature of the information
- The reason it was collected
- The duration of our business relationship
- Legal, accounting, or regulatory requirements
- The need to resolve disputes or enforce agreements
When information is no longer required, we may delete, anonymize, or securely dispose of it.
10. Data Security
We use reasonable technical, organizational, and administrative measures designed to protect personal information from:
- Unauthorized access
- Loss
- Misuse
- Alteration
- Disclosure
- Destruction
However, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure.
11. Your Privacy Rights
Depending on where you live, you may have rights regarding your personal information.
These may include the right to:
- Request access to your personal information
- Request correction of inaccurate information
- Request deletion of your information
- Request restriction of certain processing
- Object to certain processing
- Withdraw consent
- Request data portability, where applicable
- Opt out of certain marketing communications
- Lodge a complaint with an applicable data protection authority
Certain rights may be subject to exceptions or limitations under applicable law.
To exercise a privacy right, contact us at:
contact@new-gain.com
We may need to verify your identity before completing certain requests.
12. California Privacy Rights
If you are a California resident, applicable California privacy laws may provide additional rights regarding your personal information, including rights to:
- Know what personal information is collected
- Request access to personal information
- Request deletion
- Request correction
- Receive information regarding disclosures of personal information
- Exercise any applicable rights relating to the sale or sharing of personal information
As described above, we do not sell personal information and do not share personal information for cross-context behavioral advertising.
We will not discriminate against you for exercising applicable privacy rights.
13. Israeli Privacy Law
Where applicable, personal information is processed in accordance with the Israeli Privacy Protection Law, 5741-1981, its regulations, and other applicable Israeli privacy requirements.
Individuals may have rights under the Israeli Privacy Protection Law, including the right to review personal information held about them and, where applicable, to request its correction or deletion.
To exercise these rights, you may contact us at contact@new-gain.com.
14. Children's Privacy
Our website is intended for businesses and professional users and is not directed toward children.
We do not knowingly collect personal information from children through our website.
If you believe that a child has provided personal information to us, please contact us at contact@new-gain.com so that we can review the matter and take appropriate action.
15. Third-Party Websites
Our website may contain links to third-party websites or services.
We are not responsible for the privacy practices, content, or security of third-party websites.
We encourage visitors to review the privacy policies of any third-party websites or services they use.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our website, services, business practices, technologies, or legal requirements.
When we make changes, we will update the “Last Updated” date at the top of this page.
Material changes may be communicated through the website or by other appropriate means where required by law.
17. Contact Us
If you have questions about this Privacy Policy, our privacy practices, or your personal information, or if you would like to exercise an applicable privacy right, please contact us:
NEWGAIN
Operated by Upperate Digital Marketing Solutions Ltd.
Company No. 516657301
Registered Address: 3 Shulamit St., Tel Aviv, Israel
Email: contact@new-gain.com