This Privacy Policy explains what information New Charter Technologies, Inc. and its subsidiary and affiliated managed service providers (“New Charter”) may collect from you, how we may use it, the choices you have regarding our use of it, and whether we disclose it to anyone when you access our website at newchartertech.com, and the websites of our New Charter brands (the “Site”), including all content, information, and functionality available through the Site, and when you receive or interact with our managed services, professional services, or technology offerings (collectively referred to as the “Services”). Services provided to business customers and their personnel may be referred to herein as “B2B Services”.  When we process Personal Data on behalf of our business customers (“Clients”), we act as a service provider/processor. We process such data solely on behalf of and under the instructions of the Client. Individuals should direct requests regarding such data to the relevant Client.

A list of New Charter Technologies’ subsidiary and affiliate companies (each an “OpCo”), their websites, and their privacy policies can be found here. If you are a New Charter client, you may receive services from one or more OpCos, as described in your services agreement. Please refer to the applicable OpCo’s privacy policy for additional information regarding the handling of your data.

This Privacy Policy applies to both (i) consumer interactions with our Site and (ii) business-related data processed in connection with the delivery of our Services, including data contained within client systems, networks, and environments (“Client Systems”).

By using our Services, including the Site, you acknowledge the terms of this Privacy Policy as they may be amended from time to time.

Personal Data We Collect

We treat any data that identifies, or reasonably can be linked to, an individual consumer as “Personal Data.”  Data that has been de-identified or aggregated so that it cannot reasonably be linked to an individual consumer is not Personal Data, and we may use that data for any purpose.  Personal Data also does not include publicly available information, such as information that is lawfully made available through federal, state, or local government records. We may use de-identified, aggregated, or publicly available data, for any purpose.  We do not attempt to re-identify de-identified data unless we have been given consent to maintain and use the data in identifiable form. We process sensitive personal data only as necessary to provide the Services and do not use such data for purposes requiring consumer opt-out or limitation rights under applicable law.

We may provide the following information when you visit our Site, purchase our Services, or otherwise interact with us. The Personal Data we collect may include:

• Identifying Information – such as name, mailing address, phone numbers, and email addresses.
• Internet or Similar Network Activity – such as your activity related to your interaction on our Site, as well as your interaction with our advertising and other communications, which may include your IP address and browsing activity.
• Commercial Information – such as information relating to your purchases and services, including your purchasing or consuming histories or tendencies.
• Professional or employment-related information
• Financial Information – such as your bank account number, credit card number or other financial information when you purchase Services from us.
• Demographic Information – such as age and gender.
• Client Systems Data – including data stored in, transmitted through, or accessible via Client Systems that we monitor, manage, or support as part of the Services (which may include business contact data, end-user data, system logs, and operational data).
• Support and Communications Data – including helpdesk tickets, chat transcripts, call recordings, and AI-assisted support interactions.
• Device and Environmental Data – including device identifiers, configuration data, performance metrics, and security-related telemetry collected from managed systems.
• AI Interaction Data – including prompts, inputs, outputs, and related metadata where AI-enabled tools (e.g. note-taking, assistants, automation tools) are used in delivering Services.

How We Obtain Your Personal Data

• From You: We obtain the Personal Data that we collect about you from you when you interact with our Site and Services, including when you: (1) contact and communicate with us, including our sales, support or field service teams; or (2) purchase and use our Services or Site.
• In addition to data collected directly from you, we may obtain Personal Data:
  • From our business customers (Clients), including data made available to us in connection with providing Services;
  • Automatically from Client Systems through monitoring, management, or security tools; and
  • From third-party service providers integrated into our Services.

Our Use of Personal Data:

We may use your Personal Data as follows:

• Provide Our Services, and to Personalize Your Experience: We use Personal Data to furnish our Services, including to: (1) process and fulfill your purchases; or (2) provide information about the status of your Services.
• Communicate with You: We use Personal Data to respond to communications, contact you about your transactions, promote Services, provide other relevant information, and request information or feedback.
• Personalize Your Experience: We utilize Personal Data regarding your use of our Services to personalize and enhance your experiences.
• Internal Research: We use Personal Data to conduct internal research to develop, improve or repair our products, services, or technology.
• Security or Fraud Prevention: We use Personal Data to: (1) prevent, detect, protect against, or respond to security incidents, fraud or malicious or deceptive practices, or other illegal activity, (2) preserve the integrity or security of systems, and (3) investigate, prepare for, establish or defend legal claims.
• Legal Compliance: We may use Personal Data to comply with applicable law or to comply with a lawful governmental request.
• Provide Managed Services: including monitoring, maintaining, securing, troubleshooting, and improving Client Systems and related infrastructure.
• Remote Support and Administration: including accessing systems, devices, and data within Client Systems to diagnose and resolve issues.
• Security and Threat Detection: including detecting, preventing, and responding to cybersecurity incidents.
• AI-Enabled Service Delivery: including processing inputs and outputs for automation, support, analytics, and operational efficiency.

Monitoring and Remote Access

As part of delivering our Services, we may remotely access, monitor, and interact with Client Systems and associated data. This may include:

• Monitoring system performance, availability, and security;
• Accessing devices, networks, and applications;
• Reviewing logs, alerts, and operational data;
• Remotely troubleshooting and resolving technical issues; and
• Deploying updates, patches, or configuration changes.

Such access may occur on a continuous or periodic basis and may involve automated tools and third-party platforms.

We perform these activities solely to provide the Services and in accordance with our contractual obligations with our Clients.

AI-Enabled Services

Some Services may include AI-enabled tools. These tools may process Personal Data such as communications, prompts, system data, and outputs to:

• Provide automation and support;
• Improve service delivery;
• Generate summaries or recommendations.

We do not use Client Personal Data to train generalized AI models except as permitted by contract.

Employee and Workforce Personal Data

This Privacy Policy also applies to certain Personal Data collected and processed by New Charter relating to its employees, contractors, and other workforce members (“Workforce Personnel”) when they access New Charter systems, websites, or applications, or use third-party software, platforms, or services licensed, provided, or managed by New Charter or its affiliates.

Such Personal Data may include identifiers, professional or employment-related information, device and usage data, system access logs, communications, and other information generated through the use of New Charter systems or authorized third-party tools. New Charter processes this information for legitimate business purposes, including workforce management, system administration, security monitoring, compliance, support, and operational efficiency.

Where required by applicable law, New Charter will provide Workforce Personnel with additional notices regarding the collection and use of their Personal Data.

Data Retention

We will retain your Personal Data only for as long as necessary to fulfill the business and commercial purpose(s) for which we obtained the information as described in this Privacy Policy, to resolve disputes, to enforce agreements, or as otherwise required by law. Also, please see below regarding consumer rights that may be applicable in your jurisdiction. For Client System Data, retention is governed primarily by our agreements with our Clients.

Our Sharing of Personal Data

We may share Personal Data with service providers who act on our behalf, our partners, or others operating at your direction or where legally necessary or appropriate.

• Service Providers: We disclose Personal Data to “service providers” and “contractors” (as defined under applicable privacy laws) that process Personal Data on our behalf pursuant to written agreements that restrict their use of Personal Data to specified business purposes and require appropriate data protection measures. We engage third parties to act as our service providers and perform certain tasks on our behalf in connection with delivering you our Services.  The tasks performed by service providers include: (1) processing and storing Personal Data; (2) assisting with marketing communications, advertising, and strategic initiatives to enhance the Services; (3) processing credit card or other financial charges; and (4) providing technology services.  We may provide service providers with all categories of Personal Data described above so they may act on our behalf.  We take reasonable steps to ensure that our service providers are contractually obligated to keep Personal Data confidential and only utilize the Personal Data as permitted.
• Affiliates: We may share all the above categories of information with our affiliated companies.
• Other Legal Purposes: We also may share Personal Data: (1) with your consent; (2) to respond to subpoenas, court orders, or other legal process or otherwise as required or allowed by law or the competent governmental or judicial authorities; (3) to cooperate with law enforcement, government or regulatory entities, and safety or investigation authorities; (4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or other illegal activities or to establish or preserve a legal claim or defense; (5) to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or other illegal activity, or preserve the integrity or security of systems; (6) to investigate, establish, exercise, prepare for, or defend legal claims; or (7) as part of a corporate restructuring, sale of assets, merger or divestiture.

We do not otherwise sell or share Personal Data to non-affiliated third parties without your consent. However, we may “share” Personal Data (as defined under the California Consumer Privacy Act, as amended by the CPRA) for purposes such as analytics or advertising. We also have no actual knowledge of selling or sharing the Personal Data of minors under 16 years of age to non-affiliated third parties without affirmative consent.

Use of Cookies

Like most commercial websites, we analyze how visitors use our website and portals with “cookie” technology. A cookie is a small text file that is placed on your computer when you access our website and allows us to recognize you each time you visit the website. We and our third-party partners may use cookies and similar technologies such as pixels to: (1) enhance or personalize your website usage and experience; (2) monitor website usage; (3) improve the functionality of our website and our services; and (4) for targeted or cross-context behavioral advertising (where applicable).  We may work with service providers or third parties that help us track, collect and analyze this information.  We may combine the information we collect through cookies with other information we have collected from you or information from other sources. These technologies may result in the “sharing” of Personal Data under applicable law.

We honor legally recognized universal opt-out signals (such as Global Privacy Control) where required. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features on our website. Please note that browser-management tools for cookies are outside of our control, and we cannot guarantee their effectiveness.

Security of Your Personal Data

We use commercially reasonable administrative, technical and physical safeguards, including measures appropriate to the nature of the Services, such as access controls, monitoring systems, endpoint management tools, and security event detection technologies, to protect Personal Data, considering the nature of the Personal Data and the threats posed.  However, there is security risk inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Data.

Third Party Websites and Applications

Our Site may contain links to websites or applications hosted by third parties.  This Privacy Policy only applies to websites and applications within our control and does not apply to any third-party sources.  Any data collected through third party websites or applications is subject to the privacy practices of the third party, and you should review the privacy policies of these third parties prior to sharing any data.

Rights and Choices of Customers

Depending on your state of residence, you may have the following rights:

• Access, correct, or delete Personal Data;
• Obtain a copy (portability);
• Opt out of:
  • targeted advertising
  • sale of Personal Data
  • profiling in furtherance of decisions producing legal or similarly significant effects;
• Appeal our decision regarding your request.

We will not discriminate against you for exercising your rights.

Right to Opt-Out of Sale or Sharing of Personal Data

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), California residents have the right to direct a business to not sell or share their Personal Data. Sale means disclosing Personal Data to a third party for monetary or other valuable consideration. Sharing means disclosing Personal Data to a third party for cross-context behavioral advertising. We do not sell Personal Data for monetary consideration. However, we may share Personal Data with third parties (such as analytics or advertising partners) in a manner that may be considered “sharing” under the CCPA/CPRA.

You have the right to opt out of the sale or sharing of your Personal Data at any time. Your opt-out request will apply only to:

• Personal Data collected in connection with your use of our website and online services; and
• Personal Data processed for marketing, analytics, or advertising purposes.

This right does not apply to Personal Data we process solely as a service provider or processor on behalf of our business customers. In those cases:

• We process Personal Data under the direction of our Client;
• We do not control or own such data; and
• Requests regarding such data should be directed to the applicable Client.

Right to Know About Personal Data Collected, Used, or Disclosed

You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data. Once we receive your request and verify your identity, we will disclose to you:  (1) the categories of Personal Data we collected about you; (2) the categories of sources for the Personal Data; (3) our business or commercial purpose for collecting or disclosing that Personal Data; (4) the categories of third parties with whom we shared that Personal Data; and (5) the specific pieces of Personal Data we collected about you in the preceding 12 months.  We do not use or disclose Sensitive Personal Information for purposes that require a right to limit under CCPA/CPRA, except as permitted by law or necessary to provide the Services.

Right to Delete Personal Data Collected or Maintained

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your Personal Data from our records, unless a legal exception to deletion applies.

Right to Correction of Personal Data

You have the right to request that we correct inaccurate Personal Data that we maintain about you.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-345-9605 and select Option “4”
• Emailing us at [email protected]

Authorizing an Agent

You may designate an authorized agent to submit your consumer request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.

Verifying Your Request

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Data provided in a verifiable consumer request to verify your identity or authority to make the request.

To verify your identity, we ask that you provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email.  We will use the above information to verify your identity.  Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request.

Response Timeframes

We will confirm receipt of your verifiable consumer request within ten (10) business days of receiving it. We will respond to your request within forty-five (45) calendar days of receipt. If we reasonably require additional time, we will notify you in writing of the reason and may extend the response period by an additional forty-five (45) calendar days, for a maximum total response period of ninety (90) calendar days from the date we receive your request.

If we decline to take action regarding your request, you may have the right to appeal.  Please contact us at [email protected] if you would like to submit such an appeal.

Rights and Choices of EU and UK Data Subjects

The EU’s General Data Protection Regulation and the UK Data Protection Act and UK General Data Protection Regulation provide EU and UK data subjects with additional rights described below.  We generally act as a data controller of EU and UK data subject’s Personal Data submitted to us. We rely on that Personal Data for the legitimate commercial purposes of providing our Services. Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Data when requested, we may not be able to provide you with our Services. We consider and balance any potential impact on you and your rights before we process your Personal Data. We do not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.  In certain circumstances, we act as a data processor, and, in those circumstances, we process your Personal Data for the purposes set out in this Policy consistent with the data processing terms of those partners.  If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time by contacting us at the information below.  We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If you are located in the EU or UK and would like to: (1) access your Personal Data; (2) transfer your Personal Data; (3) request the erasure of your Personal Data; (4) object to the processing of your Personal Data; or (5) change your privacy preferences, please use our privacy forms by sending an email to: [email protected].  Please note that there are certain exceptions and restrictions of these rights under the European data privacy laws that enable Personal Data to be retained, process or withheld from access, and we will inform you of these exemptions and restrictions, if applicable.  If you are located in the EU or UK and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority.  However, we would appreciate the chance to address your concerns before you approach your Supervisory Authority, so please contact us first at the information below.

Cross-Border Data Transfers

We process Personal Data both inside and outside the United States.  When appropriate, we execute EU and UK Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the EU and the UK and make transfers of personal data from those jurisdictions to the United States and other countries that lack adequacy determinations.  Please contact us as detailed in the “Contact Us” section below for more information. In addition, we may transfer your Personal Data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us.

Personal Data Concerning Children

We do not knowingly collect Personal Data from individuals under the age of 16, unless the Personal Data is submitted with verifiable parental consent.  Our website, portals, and applications are not intended for anyone under the age of 16, and no one under the age of 16 may provide information on the website, portals, or applications.

Updates to the Privacy Policy

We may update this Privacy Policy periodically as we offer new products and services, and as our business, technology, and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” reference below. Any changes will become effective upon posting of the revised Privacy Policy.  If we make material changes to the policy, we will provide notice to you of the changes as required by applicable law.

Contact Us

New Charter Technologies, Inc.

Email: [email protected]

Accessibility

Consumers with disabilities who wish to access this Privacy Policy in an alternative format may contact us at [email protected] or by calling 1-800-345-9605.

Policy Last Updated:  June 9, 2026