Last Updated: January 30, 2019
1. Information we collect
Personal information you provide us which we need in order to provide you with our services
If you request to receive company or product information, or request information about specific Services, or provide comments about Services, you will be asked to provide contact information so that we can complete your request.
Examples of details we collect in order to complete your request include:
- Email address
- Telephone number
We use this Site Information to fulfil your request. We may also use this Site Information to send you additional information about our Services or Programs on the Site that you may be interested in.
Some of the Services require that you become a registered user and create a user account. This will require that you provide certain personally identifiable information, that may include (but not be limited to):
- Business name
- University name
- E-mail address
- Telephone number
- City/Country of residence
Information we collect through your use of our Site and Services
When you use the NewCampus Site and Services, we collect and analyse Site Information about your general usage of the Site, Services and NewCampus Class. We collect this information to deliver the Service you request and to improve your experience with our Site and Services. We collect this information through cookies and other services.
Examples of information we might collect and track include:
- Your usage patterns to see what features of the Site, Services and NewCampus Classes you commonly use;
- Site traffic volume, frequency of visits, type and time of transactions;
- Type of browser;
- Browser language;
- IP address and operating system; and
- Statistical information about how you use the Services.
We only collect, track and analyse such Site Information in an aggregate manner that does not personally identify you.
2. How we use the personal information you directly provide us
Site and Services Registration
- Register you to use the Services, register for NewCampus Classes, and otherwise provide you with the Services;
- Verify your authority to enter the Site and access the Programs and Services;
- Notify you of updates via e-mail and other messaging systems;
- Improve the content and general administration of the Site and the Services; and
- Provide you with notices regarding the Services and other services that you have purchased or may wish to purchase in the future.
To improve class experience
You also consent to NewCampus providing this personally identifiable information for users to identify Colearners attending the same class. It is your responsibility when you attend a class to confirm what uses the Class Host will make of your personally identifiable information. NewCampus does not control these uses by Class Host.
Class Host consent to NewCampus providing this personally identifiable information to Users as part of the Services. We use your information to share your profile details with Users via our ("Class page") to promote your class, and we share these details with Users joining your particular class.
As noted above, it is your responsibility to review the Class Host's personal policy in connection with all NewCampus Class Content and decide whether or not you want to provide such content.
To improve Site performance and deliver marketing
The aggregate data we collect through your use of the Site and Services may be used to assist us in:
- Operating the Site and the Services;
- Providing you with marketing communications via a range of channels including email and push notifications via Intercom messaging
- Provided to other third parties to enable them to better understand the operation of the Services; and
- Improve their offerings directly related to the Site, Services and NewCampus Classes
Such information will be in aggregate form only and it will not contain personally identifiable data.
You may opt-out of these marketing services at any time.
3. How your information may be shared
How we work with third parties
As mentioned above, your personally identifiable information may be shared with third parties so that we may fulfil your requests, enable your use of the Site and Services, and to improve your experience with our Site and Services.
Some examples of how we share your information include:
- When you make a payment on our Site your payment will be processed by a specialist payment processor to ensure a secure transaction
- For the purposes of email marketing, your name, e-mail, business name, university name, and so forth may be used to send you email marketing content. Use of these services by NewCampus often record your open, click, and reply engagements with the e-mail
- When you participate in a NewCampus administered survey to collect information about your experience with our Site and/or Services or your interest in future NewCampus Services
- When your participation in a NewCampus Class is sponsored by a third-party, your personally identifiable information may be shared for regulatory purposes
4. DATA RETENTION
We securely store and retain Site Information and the personal data we process on behalf of Users for as long as needed to provide the Services. We will retain and use this personal Site Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with Users, and/or the period required by laws in applicable jurisdictions. Please see the sections above for how NewCampus Class Content may be used.
If you choose at any point to opt-out of NewCampus marketing materials, we will retain the basic amount of information required to still provide our primary Services to you.
5. UPDATING, CORRECTING AND DELETING YOUR INFORMATION; OPT-OUT
If you believe that NewCampus has incorrect Site Information that was provided as part of the Services, you may use the Services to correct, amend, or delete that information. You may also contact us by emailing our customer support at firstname.lastname@example.org We can only alter information that was initially provided to us; if you want to update, correct, or delete data that was provided directly to a Class Host through NewCampus Classes, you need to contact the Class Host for that purpose.
From time to time, we may send you emails about new or modified Services that we believe might interest you. If you wish to opt-out of receiving these materials, you may follow the unsubscribe procedure provided in the email.
The security of your personal information is important to us. NewCampus employs procedural and technological measures to protect your personally identifiable information. These measures are reasonably designed to help protect your personally identifiable information from loss, unauthorised access, disclosure, alteration or destruction.
We may use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorised access to your personally identifiable information.
However, NewCampus cannot guarantee that unauthorised third parties will never be able to defeat these measures or use your personally identifiable information for improper purposes. Therefore, you should be aware that when you voluntarily display or distribute personally identifiable information, that information could be collected and used by others. NewCampus is not responsible for the unauthorised use by third parties of information you post or otherwise make available publicly.
7. Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 13 (or 16 if you are in the European Economic Area (“EEA”)), and we do not knowingly collect personal information from children under the age of 13 (or 16 if you are in the EEA) without obtaining parental consent. If you are under 13 years of age (or 16 if you are in the EEA), then please do not use or access the Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age (or 16 if in the EEA) and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age (or 16 if in the EEA) has obtained an account on the Service, then you may alert us at email@example.com and request that we delete that child’s personally identifiable information from our systems.
8. LINKS TO OTHER WEBSITES
The Site, Services and in particular the NewCampus Classes, may provide links to third party web sites or resources not associated with us and over which we do not have control (“External Web Sites”). Such links do not constitute an endorsement by NewCampus of the External Web Sites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that NewCampus is only providing these links as a convenience, and cannot be responsible for the content of such External Web Sites.
9. For Residents of the European Economic Area ("EEA") – General Data Protection Regulation ("GDPR")
Lawful Bases to Process Your Personal Data
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- The lawful basis for collecting your Identity and Contact Data to register you as a new customer is the performance of a contract with you.
- The lawful bases for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data to process and deliver your purchases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
- The lawful bases for collecting your Identity, Contact, Profile, and Marketing and Communications Data to manage a relationship with you are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
- The lawful bases for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data to enable you to partake in a contest, competition or complete a survey are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
- The lawful basis to collect your Identity, Contact, and Technical Data to administer and protect our business and the Service is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
- The lawful basis to collect your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data to deliver relevant Service content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
- The lawful basis to collect Technical and Usage Data to use data analytics to improve our Service, marketing, customer relationships and experiences is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business and to inform our marketing strategy).
- The lawful basis to collect Identity, Contact, Profile, Usage, and Technical Data to make suggestions and recommendations to you about goods or services that may be of interest to you is that it is necessary for legitimate interests (to develop our products/services and grow our business).
We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may have to share your personal data with the parties set out below for the purposes described in this Policy.
External Third Parties
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Specific third parties such as Google, Stripe, PayPal, Intercom, Zapier, Heap Analytics, Algolia and Facebook
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are based in New Zealand, which is where all of your data will be processed.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS UNDER THE GDPR
Under certain circumstances, EEA residents have rights under data protection laws in relation to their personal data. If you are an EEA resident, you have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. MATERIAL CHANGES
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