Privacy Policy

Date created: 5/10/2021
Last modified: 5/10/2021

nextSource, Inc. ("Company" or "We") understand the importance of protecting your information, and we provide this Website Privacy Policy ("Privacy Policy") to explain the types of information we may collect from you or that you may provide when you visit the website, <<www.nextsource.com>> (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through either the employee or supplier portals provided on the Website.

It does not apply to information we collect:

To information we collect offline or through any other means, including on any other website we may operate; or
To information we collect from a third party, including data third parties collect through websites or applications that may link to our Website; or
To information publicly available from government records; or
To de-identified or aggregated consumer information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see <<Changes to Our Privacy Policy>>). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect certain information from all users accessing the Website, and we collect additional information from particular categories of users, including our customers, employees, and suppliers. The information we collect includes information:

By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline] ("personal information");
That is about you but individually does not identify you, such as information regarding your order or the services you request or provide; and/or
That is about your internet connection, the equipment you use to access our Website, and usage details and does not personally identify you.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies or other tracking mechanisms.
From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website when you register as a user on our Website as an employee, customer or supplier, request or offer services through our Website, or post material to our Website. We may also ask you for information if you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders.
Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). You can review our <<Do Not Track>> information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This non-personally identifiable 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.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically.

Third-Party Use of 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 alone or in conjunction with web beacons or other tracking technologies 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. For information about how you can opt out of receiving targeted advertising from many providers, see our <<Choices About How We Use and Disclose Your Information.>>

In the past 12 months, we have collected the following types of information:

Category	Examples	Collected
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Yes, when you provide it to us.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	Yes, when you provide it to us.
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
Geolocation data.	Physical location or movements.	Yes
Inferences drawn from other personal information.	Profile reflecting a person's preferences, behaviors.	Yes

How We Use Your Information

We use or disclose the information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
To conduct tests, research, analysis, and product/service development.
To respond to law enforcement requests as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information is held by us about our Website users, including, but not limited to, our employees, customers and suppliers, is among the assets being transferred.
For any other purpose with your consent, or as legally permissible without your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please see <<Choices About How We Use and Disclose Your Information>>. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Sharing Your Information

We do not sell personal information.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosure sunder written contracts that describe the purpose, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing under the contract. Those business purpose disclosures may be:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see <<Choices About How We Use and Disclose Your Information>>.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our <<Terms of Use>> and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of nextSource, our customers, suppliers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
With your consent.

In the preceding 12 months, we have disclosed personal information for a business purpose to the categories of third parties indicated here.

Personal Information Category	Shared
Identifiers.	Yes
California Customer Records personal information categories.	Yes
Commercial information.	Yes
Internet or other similar network activity.	Yes
Geolocation data.	Yes
Inferences drawn from other personal information.	Yes

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us.

Opt-In/Opt-Out Rights

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 our Website may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. We do not currently share information with third parties for advertising purposes, and we will update this policy if we decide to do so.
Promotional Offers from the Company. If you do not wish to have your contact information used by us to promote our own or third parties' products or services, you can opt-out of such promotional offers by sending us an email stating your request to privacy@nextsource.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to, and you may not opt-out of, communications relate to your transactions with us.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by checking or unchecking the relevant boxes or by sending us an email at privacy@nextsource.com. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@netsource.com. However, we do not currently sell data triggering that statute's opt-out requirements.

Accessing and Correcting Your Information

You have the right to request that we disclose to you what information we have collected or shared about you over the last 12 months (the "right to know"). You must send us a verifiable request, and once we have confirmed it we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you.

We do not provide a right to know or data portability disclosure for business-to-business personal information.

Right to Delete

Subject to certain exceptions, you have the right to request that we delete personal information that we collected from you (the "right to delete"). Once we receive a verifiable request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Emailing us at privacy@nextsource.com

Calling us at: (800) 641-9987

Mailing your request to:

1040 Avenue of the Americas
24th Floor
New York, New York 10018

You may make a request to know or delete on your own behalf of on behalf of a minor for whom you are a parent or guardian. If you are an adult, only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized person to make requests on your behalf, you must send us a verifiable request.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Confirming you’re the name, email address, phone number and/or other information that we have on file for you.
- Providing answers to any security questions we assigned to you.
- Providing copies of documentation appointing you as a guardian for another individual.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

We will only use the personal information provided in such a request to verify the requestor's identity or authority to make the request.

Response Timing and Format

If you do not receive confirmation that we have received your request within 10-days of the date you submit it, please contact privacy@nextsource.com.

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

We will deliver our written response by mail or electronically, at your option. The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the applicable privacy law(s), we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by state privacy laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We do not currently provide any financial incentives.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, even with our best efforts and the care you exercise, the transmission of information via the internet is not completely secure. As a result, we cannot and do not 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.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 should provide any information to or on the Website or use the Website. We do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@nextsource.com.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or provide comment about this Privacy Policy and our privacy practices, contact us at:

privacy@nextsource.com

1040 Avenue of the Americas
24th Floor
New York, New York 10018

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