We at NEWPRENEURS, VICTOR GREEN PRODUCTIONS INC, (“Newpreneurs,” “we,” “us,” or “our,”) created this privacy policy (“Policy”) because we know that you care about how information you provide to us is used and shared. This Policy relates to the information collection and use practices of NEWPRENEURS in connection with our investment channel platform (“Platform”), which are made available to you through our website located at newpreneurs.com (“Site”).

Children’s Online Privacy Protection Act of 1998 Compliance

We strive to educate parents and young adults about how to appropriately safeguard their privacy when using our Platform. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow anyone under the age of 18 to access and/or use our Platform. We urge young adults to check with their parents before entering information through our Platform and/or Site, and we recommend that parents discuss with their children restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.

By visiting our Site and/or using our Platform, or by permitting your child to use our Platform, you are agreeing to the terms of this Policy and the accompanying Terms of Use. Capitalized terms not defined in this Policy shall have the meaning set forth in our Terms of Use.

Information We Collect

Personal Information

We do not collect any personal information from you unless you voluntarily provide it to us.

When you sign up to become an Applicant of the Site (“Applicant”), you will be asked to provide us with certain personal information. In this Policy, we refer to this information as “Personal Information.”

Other than the online contact information required to obtain parental consent, we do not collect any Personal Information from Applicants under the age of 18 unless the Applicant’s parent or legal guardian has first provided us with consent for that Applicant to use the Platform and disclose Personal Information to us.

If you are an Applicant under the age of 18, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from an Applicant under the age of 18 without parental consent, or if we learn an Applicant under the age of 18 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that an Applicant under the age of 18 may have provided us Personal Information in violation of this Privacy Policy, please contact us at contact@nuprnrs.com

For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal Information comprises the categories of Personal Information defined by the CCPA, which includes:

Category	Examples
Identifiers	Name, address, email, phone, SSN, driver’s license
Other Data	Financial information, medical information, health insurance information
Protected Classes	Race, gender, sexual orientation, religion
Commercial Information	Records of personal property, purchasing or consuming histories or tendencies
Biometric Information	Fingerprints, retina scans, face prints
Internet Activity	Browsing history, search history, IP address, website interactions
Geolocation Data	GPS coordinates, location history
Sensory Data	Audio, electronic, visual, thermal, olfactory
Professional Data	CV, resume, employment history
Education Data	Educational background, grades, scores
Inferences	Drawn the above categories, such as preferences, characteristics, attitudes, predispositions, abilities, aptitudes,  intelligence, psychological traits

The examples given above are not meant to provide an exhaustive list but are examples of the kinds of data included in each category. We do not collect Personal Information in every one of these categories. Personal Information under the CCPA also includes any other category of personal information not included within the CCPA’s definition that are defined in California Civil Code § 1798.80(e).

We refer to this category as “Other Data,” and it includes information such as financial information (bank account number, credit card number, debit card number), medical information, health insurance information, and insurance policy number.

Our Company collects only that Personal Information that is relevant for the purposes for which the data is requested. The Company does not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented.

Usage Information

Like most websites, we use automatic data collection technology when you visit the Site to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Platform (“Usage Information”).

We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website Applicants. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Site, but may not be able to use some areas of the Site and/or the Platform.

We do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.

How We Use Your Information

We may use your Personal Information and Usage Information in a manner that is consistent with this Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:

• To identify you when you sign in to your account;
• To respond to your requests and to provide you with the Platform;
• To respond to your inquiries and contact you about changes to the Site and/or the Platform;
• To send you notices (e.g., in the form of e-mails, mailings, and the like) regarding products or services you are receiving;
• To send you information we think you may find useful or that you have requested from us;
• To enhance and improve the Site or the Platform;
• To analyze the use of the Site and the Platform and the people visiting to improve our content and Site and the Platform;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
• For any other purposes disclosed at the time the information is collected or to which you consent; and
• As otherwise specifically described in this Policy.

Disclosure of Personal Information to Third Parties

We do not disclose your Personal Information to third parties for their direct marketing purposes.

We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. These companies may include, but are not limited to:

• Other producers or financers of our Platform;
• Administrative authorities;
• HR Services providers;
• Recruiting or talent agencies;
• Financial institutions;
• Insurance organizations;
• Governmental organizations or agencies, including law enforcement;
• External advisors (such as attorneys, accountants); and
• Employee benefit providers.

If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.

We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other Applicants of this Site, or anyone else that could be harmed by such activities.

How We Protect Your Information

We take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Accessing and Modifying Account Information

You may update the information that is stored in your Applicant account by visiting profile or by emailing us at contact@newpreneurs.com.

We strive to help parents ensure that their kids have a safe experience using our Platform. Parents or legal guardians can review any Personal Information collected about their child under 18 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

Your Choices

If you wish to stop receiving promotional e-mails, you may do so by visiting settings or by emailing contact@newpreneurs.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.

Links

The Site may contain content, services, advertising and other materials that link to websites operated by third parties. We have no control over those other sites, and this Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your Personal Information.

Shine the Light Law

Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to contact@newpreneurs.com.

Do Not Track

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals. Important Notice to Applicants Outside the U.S.

The Site and the Platform are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the Platform, you consent to this transfer.

Changes to This Privacy Policy

This Policy is effective as of the date stated at the top of this Policy. We may change this Policy from time to time and will post any changes on the Site as soon as they go into effect. By accessing the Site or using the Platform after we make any such changes to this Policy, you are deemed to have accepted such changes. Please refer back to this Policy on a regular basis.

How to Contact Us

If you have questions about this Policy, please email us at contact@newpreneurs.com. “PRIVACY POLICY” in the subject line.