1.0 Introduction

This Privacy Policy describes how Newbook Pty Ltd and Newbook International, Inc. and each of their wholly owned affiliates (collectively referred to as “Newbook”, “we”, “our” or “us”) and its corporate parent Storable Inc. and their affiliates (“Storable”) collect, use, and disclose personal information, and what choices you have with respect to your personal information.

Newbook provides a cloud-based property management solution, channel manager and universal booking engine designed for property rentals of all types, including hotels, resorts, apartments, holiday parks, and marinas. 

Newbook is a technology company headquartered in Surfers Paradise, QLD, Australia, which focuses on providing services to the tourism industry.

For more information about our services, please refer to our website:
https://www.newbook.cloud

This Privacy Policy is applicable to Newbook, including as related to our services, and Storable which collectively include:

• the use of https://www.newbook.cloud (“website”)
• the use of the application website via https://login.newbook.cloud or other wildcard URL’s under newbook.cloud, i.e. https://*.newbook.cloud (“application”) 
• social media messages and marketing campaigns and 
• the use of our products and services. 

This Privacy Policy sets out the essential details relating to your personal data relationships with Newbook and Storable, including as:

• A website visitor
• An end user of the application (“end user”)
• A prospective client or client
• A job applicant and
• Partners

Clients contract the use of our application and give access to their employees and other third parties, as solely decided by them, by creating end users who access the application with their email address and credentials. The clients’ administrators grant end users roles, which result in different permissions and access rights to the information held in the Client account. 

If you are an end user, please note that we only process your personal information on behalf of our clients in accordance with their instructions. As such, all queries and requests that you make of us in relation to your personal information (including under section 6 of this policy) will be re-directed by us to the client. We encourage you to reach out to the relevant client directly in relation to the processing of your personal information.  

2.0 Personal Information We Collect 

2.1 Information You Choose to Provide to Us

WHEN

We may ask you to provide personal information when:

• You use the website to download articles, data sheets or eBooks.
• You request a free trial or demo.
• You refer a friend to us.
• You connect with us directly via phone calls or video conferencing platforms.
• We or Client Account Administrators grant you access to the application.
• You or Client Account Administrators upload or enter personal information into the application.
• You participate in a marketing/sales promotion.
• You attend trade events and other industry networking events.
• You register or attend a webinar or other event.
• You participate in programs we may offer from time to time.
• You participate in chats.
• You pay for our services. 

If you choose to provide us with a third-party’s personal information (e.g. an end user’s name, email and company) including when taking part in our referral program, you represent that you have the third-party’s permission to do so. 

WHAT

We collect personal information that may include first and last name, business email address, phone number and/or company name, and any other personal information that you choose to provide to us (including via information fields). 

As an end user of the application, we collect your log in details, name, business email address, booking related details and any comments you make in the application.

In addition, we may collect data provided or uploaded by you or provided by a third party (particularly where you are an end user), such as but not limited to by your employer, a client, another booking management application (like booking.com) or other users of the application. We expect all users to take note of all applicable privacy policies and any applicable regulatory requirements when uploading, accessing and using personal information in our application. The data uploaded may include personal information like: 

• Employee names, email addresses and contractual agreements
• Vendor names, email addresses, contractual agreements or other personal data necessary for Newbook services
• Customer names and email addresses used to provide services within Newbook’s platform
• Booking related details

As a job applicant, we may also collect your resume and cover letter, and other personal information provided in relation to your application. In some cases, for example when completing pre-employment background checks, we may collect information about you from third parties like your referees (including about your work history).   

We will not collect sensitive information about you (such as information concerning race, ethnicity, political opinions, religious beliefs, or details of health or sexual orientation) unless required by law or with your express prior consent.

You have the option of not identifying yourself or to use a pseudonym when dealing with us. However, in many cases (e.g. where you are using our services to make a booking), it will not be practicable to deal with you anonymously or using a pseudonym, in which case we may not be able to provide you with materials or services if you do not identify yourself.

2.2 Information We Collect Automatically

WHEN

We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology. 

For further information about the types of cookies we use, you can access our Cookie Policy at this link: https://www.newbook.cloud/cookie-policy/

WHAT

The information collected includes:

• access times
• the pages you view
• the links you click on 
• the search terms you enter 
• actions you take in connection with any of the visited pages
• your device information such as IP address, location, browser type and language
• the Uniform Resource Locator (URL) of the website that referred you to our website and 
• the URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

2.3 Information We May Collect From Third Parties

WHEN

We collect personal information from third parties, including as described in section 2.1.

We may combine the information we collect from your direct interactions with us with information obtained through other third-party sources, such as Google Analytics.

WHAT

The personal information collected includes your name, email address, business address, job title, company name, and telephone number and booking related details.

3.0 How We Use Personal Information  

We and Storable use your personal information to:

• Deliver our services and allow full use of the application functionality as purchased by the clients.
• Deliver training and support to our application end users and/or carry out the transactions you have requested.
• To communicate with you directly through emails, calls, chats, video conferencing. 
• Process payments for application subscriptions.
• Send communications to you about:
  • New application features and upgrades.
  • Services and offerings. 
  • Event announcements. 
  • Product notices and changes to our terms and policies.
  • Particular programs in which you have chosen to participate. 
  • Promotional offers and surveys.
  • Scheduling demos and managing free trials.
• Advertise and market products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.
• Carry out market research to understand how to improve services and their delivery.
• Create and manage marketing campaigns.
• Generate sales leads and increase our market share.
• Analyze user clicks and usage of the application and website to improve user experience and maximize usage of services.
• Manage our website and application to maintain and deliver the contracted functionality and services.
• Enforce our website and application terms and/or separate contracts (if applicable) with you
• Prevent fraud and other prohibited or illegal activities.
• Protect the security or integrity of the website, application, our business or services.
• Operate and improve our business and our relationship with you.
• Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.

Please note that sometimes we may record the video conferencing call in which you participate to analyze and improve our staff’s communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page. 

We may also use your personal information for reasonably expected secondary purposes and other purposes not listed above which will be made clear to you at the time we collect your personal information.

We do not sell your information to any third party. 

4.0 How We Share Personal Information

We may share your personal information to others that you have been informed of at the time the personal information is collected from you, and otherwise as set out in this section 4 or with your consent (express or implied).

Affiliates

We may share your personal information within Newbook and within Storable.

Our Application and Services

If you are an end user of our application, your personal information may be viewed by other users with access to the application (e.g. our clients, and their employees and service providers), or who you direct access to be given to (e.g. in some cases, third party payment processors).

Service Providers

We, along with Storable, use third parties to help us provide our services, including IT services providers and payment processors. They will have access to your information as collected by the website or the application, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission. 

Some of our and Storable’s key service providers are as described in the table below.

Service Provider Name	Business Purpose	Data Location
Amazon Web Services	Cloud Hosting	Australia United States of America
Google Cloud	Website Hosting	United States of America
Merchant Warrior	Payment Processing	Australia
Stripe	Payment Processing	United States of America
WP Engine	Website Hosting	United States of America
Datadog	Data Analytics	United States of America
Tableau	Data Analytics	United States of America

Legal Disclosures

It is possible that we may need to disclose personal information when required or authorised by law, subpoena or other legal processes as identified in the applicable legislation. 

We attempt to notify our clients about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

Change in Control

We can also share your personal data as part of a sale, merger, change in control or in preparation for any of these events. 

Any other entity which buys us or part of our business will have the right to continue to use your data (on the basis that the personal information is kept within the business).

Cross border disclosures

We process personal information in Surfers Paradise QLD Australia, Sydney NSW Australia and United States, and rely on legally-provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations. 

Your personal information may be processed by, or disclosed to:

• employees, representatives or other third parties operating outside of Australia who work for, or are engaged by Newbook, Storable or their affiliated companies in other countries, including in the USA; and
• our service providers who may be located outside of Australia, including in the places specified in the ‘service providers’ section above.

Third party links

Newbook may offer links to websites and applications that are operated by third parties, including in the services. If you visit one of these third party links, you should review their privacy policy carefully before providing them with any personal information. We are not responsible for the privacy policies and practices of any third party.

5.0 How We Secure Personal Information

We are committed to protecting the security of all of the personal information we collect and use. 

We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit. 

6.0 Your Rights

We provide the same suite of services to all of our clients and end users worldwide.

We offer the following rights to all individuals regardless of their location or applicable privacy regulations, subject to the jurisdiction specific provisions in the Appendix.

This section 6 only applies in relation to personal information that we collect directly from you, and not to personal information that we process on behalf of our clients in accordance with their instructions.

For personal information we have about you, you can:

• Access your personal information or request a copy.

You have the right to obtain information about what personal information we process about you or to obtain a copy of your personal information. 

If you have provided personal information to us, you may contact us to obtain an outline of what information we have about you or a copy of the information. 

If you are an end user of the application, you can log in to see the personal information in the account or approach your employer or booking provider (our client) for more information.

• You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it.

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

• Change or correct your personal information.

You have the right to update/correct your personal information or ask us to do it on your behalf. 

You can edit your information through the user account in the application or ask us to change or correct it by contacting us at pr*****@*****ok.cloud.

• Delete or erase your personal information.

You have the right to request the deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you.

• Object to the processing of your personal information.

You have the right to object to our processing of your personal information, including for direct marketing purposes (see section 8 below). If you object to our use of your personal information for direct marketing purposes, we will stop using your personal information for these purposes.

• Ask us to restrict the processing of your personal information.

You may have the right to ask us to limit the way that we use your personal information. 

• Export your personal data.

You have the right to request that we export to you in a machine-readable format all of the personal information we have about you.

Privacy queries and complaints

If you would like to exercise any of the rights described above, please contact us at pr*****@*****ok.cloud.

You also have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory. In Australia, this is the Office of the Australian Information Commissioner.

7.0 How Long We Keep Your Personal Information

We retain personal information as long as it is necessary to provide the services to you and our clients, subject to any legal obligations to further retain such personal information.

We may also retain personal information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law. 

The personal information we retain will be handled following this Privacy Policy.

Personal information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data, except to the extent this is prohibited in our client agreements. De-identified personal information may provide insights that are commercially valuable to Newbook and Storable, such as statistics of the use of the services. 

8.0 Other Important Information

Newbook and Storable will only collect and process your personal information where we have a lawful reason for its collection.

You can review the terms and conditions of use here: https://www.newbook.cloud/terms-and-conditions/

Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal information, please contact us at pr*****@*****ok.cloud.

How to select your communications preferences 

You may choose to receive or not receive direct marketing communications from us. Please click the “Unsubscribe” link in the email we sent you to stop receiving marketing communications. 

You may choose which personal information we collect automatically from your device by controlling cookie settings on your browser or by selecting your preferences through our Cookie Policy, https://www.newbook.cloud/cookie-policy/.

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate. 

9.0 Contact Information

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at pr*****@*****ok.cloud.

Appendix 

A.1 For Individuals Based in the United Kingdom (UK), European Union (EU), European Economic Area (EEA) and Switzerland

If you are based in one of these jurisdictions, Newbook is the controller of your personal data collected in the following instances:

• When you visit our website https://www.newbook.cloud
• When we process your personal data for sales and marketing purposes

Newbook is a processor of all personal data processed on the application, on behalf of our clients. We only process the personal data under their direction. Please contact your employer or the organization that granted you access to the application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

• Consent: We will ask for your express and informed consent every time we collect your personal data on this legal basis.
• Contractual basis: We process the personal data as necessary to fulfil our contractual terms with you or our clients.
• Legitimate interest: We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation. 

You have the following rights under the GDPR:

• Be informed about the collection and use of your personal data
• Access your personal data
• Correct errors in your personal data
• Erase your personal data
• Object to the processing of your personal data.
  • This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request. 
• Export your personal data
• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above). 

We process personal data in United States and share it with our affiliates and our service providers in the United States and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of transferring EU data to countries subject to data transfer requirements.

Under Article 27 of GDPR, we are required to provide a contact in the EU and UK that will act as our representative should you wish to contact us. You can contact our Representative to exercise your rights under the GDPR or to discuss any sort of data protection issue relating to our company.

​Our EU Representative is:
Adam Brogden
Instant EU GDPR Representative Ltd, 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
Email: co*****@*******al.com
Support Website: https://newbook.gdprlocal.com/eu

Our UK Representative is:
Adam Brogden
GDPR Local Ltd, 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Email: co*****@*******al.com
Support Website: https://newbook.gdprlocal.com/uk

You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC). See their contact details here National Data Protection Authorities.

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

A.2 For Individuals Based in California

A.2.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
• Internet/network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
• Geolocation data, such as information about your location (at country and city level) collected from your IP address
• Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
• Profession/employment information that you send to us when applying for a position included in your CV and cover letter
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

A.2.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks. 

Please see the “How We Share Information” section of the Privacy Policy above for more information.

A.2.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):
  • The specific pieces of personal information we have collected about you
  • The categories of personal information we have collected about you
  • The categories of sources of the personal information
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
  • The business or commercial purposes for collecting or selling the personal information.
• The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights. 

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

A.2.4 How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at pr*****@*****ok.cloud.

We will need to verify your identity before processing your request. 

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you. 

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority. 

If you are an employee/former employee of a Newbook client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Newbook application by a Newbook client, please direct your requests and/or questions directly to the Newbook client that gave you access.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.