Data Privacy and Protection Policy

1. Introduction

This Data Privacy and Protection Policy ("Policy") establishes the Company's approach to protecting the privacy and personal data of all individuals including customers and students (hereinafter referred to as "you" or "your") whose information is collected and processed by the Company in connection with the services and products we offer. For more information in relation to NEL, please see our about us page at https://www.jointherealworld.com/about

1.2 In delivering educational services, consulting services, and related operational activities, we collect your personal data. We want you to understand what personal data we have about you and how we use it. We also want you to know that you can exercise certain rights over this data.

1.3 We respect your privacy and take the protection of your personal data seriously. When you use our products and services, we acquire certain information about you. This information, including your name and email address, is called personal data. Personal data means anything that identifies you directly (like your name) or indirectly (like an identity number), or as personal data has been defined by applicable privacy laws.

1.4 We value your trust and are committed to safeguarding your data and giving you control over it. Any personal data provided to or collected by us is controlled by the Company, who acts as the data controller.

1.5 This Policy also applies to our marketing content, including offers and advertisements for our products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own privacy notices and terms and conditions. We encourage you to read them before using those websites.

1.6 This Policy is binding on all NEL Personnel, including employees, contractors, consultants, and interns. Every individual acting on our behalf is responsible for adhering to these privacy standards.

2. Sources of Personal Data and What Is Being Collected?

2.1 We may collect personal data from a variety of sources. This includes:

2.1.1 Personal data you give us directly: We collect data regarding your interactions with our products and services, including the content you view and the frequency of your activity. Additionally, we collect personal information, such as your name, contact details, birth date, and payment information, when you register for an account, subscribe to a service, or sign up for newsletters and surveys. In certain instances, and only with your explicit consent, we may collect "special categories" of sensitive data.

2.1.2 Your online and digital interactions with us, including through our website:

Personal contact information: Including name, physical address, email, and phone number;
Demographic information: Including date of birth, age, gender, location, and personal interests related information;
Payment information: When you buy / subscribe to a course or any other product or service, we collect your billing address and payment details. We also maintain a record of your purchase history and any refunds issued. Given the sensitivity of financial data, we use enhanced security measures to keep this information protected;
Account login information: Including any information that is required for you to establish a user account with us (such as, login ID, email address, username, password and personal security question/answer);
Consumer feedback: Including information that you share with NEL about your experience in using our products and services (such as, comments and suggestions, testimonials and other feedback related to various courses);
Consumer-generated content: Including any content (such as, photos and videos) that you create and then share with us by uploading it to our website;
Educational data: Including course enrolments showing which courses you have accessed, progress and completion status tracking learning advancement, assessment scores and grades earned on quizzes and assignments, certificates earned upon successful course completion, learning preferences such as preferred language or accessibility settings, and course feedback and reviews submitted by you. Educational data enables us to deliver personalized learning experiences and track your achievement;
Marketing data: Including marketing preferences including your preferred channels, frequency, and the types of content you wish to receive. We also track your engagement with our campaigns and identify how you first discovered our services. This includes information gathered from account registrations, surveys, loyalty programs, or direct requests. By analysing your expressed interests and inferred behaviours, we can ensure our communications remain relevant to your needs; and
Communication data: Including support tickets and inquiries submitted through our help systems, email correspondence with customer support or other departments, chat transcripts from live chat interactions, and feedback and surveys providing opinions about our services. Communication data enables us to provide responsive customer service and improve our offerings based on customer input.

2.1.3 Automatically: We and some third-party providers we work with automatically also receive and store certain types of personal data whenever you interact with us online. These include:

Device Data: Information from devices you use to access our websites or apps.
Online or offline purchases through our stores: Details provided when you purchase our products and/or services.
Technical data: This includes IP address, browser type and version, device information including operating system, cookies and tracking identifiers used for analytics and personalization, login history showing when and from where accounts were accessed, and usage analytics capturing how individuals interact with our platforms. Technical data supports security monitoring, platform optimization, and understanding user behaviour.
Cookies: We use cookies—small data files placed on your device—to uniquely identify your browser to our server. These allow us to store information that improves your browsing experience and helps us analyse site performance. While most browsers accept cookies by default, you can adjust your settings to refuse them or alert you when they are sent. Please note that disabling cookies may affect the functionality of certain parts of our website.
Web Beacons: We may use "web beacons" (also called action tags or clear GIFs) on our website and in emails to analyse site effectiveness. These tools help us measure metrics like visitor counts and engagement with specific site elements. Importantly, web beacons and similar tracking technologies do not automatically collect personally identifiable information. We only link this tracking data to you if you voluntarily provide personal information, such as by registering for an account or emailing us, to help us improve the relevance of our services.
Services: Our website features third-party applications and content tools. These providers may automatically receive certain data when you interact with them on our site. Additionally, we use software to monitor your browsing sessions, capturing technical details such as page load times, download errors, the duration of your visit, and how you navigate or exit our pages. This information helps us optimize site performance and user experience.

Other Sources: We may collect information about you from other legitimate sources, for the purpose of providing you with our products and services, as follows:

Your personal data is also collected when you search, buy, post, participate in a contest or questionnaire or communicate with our customer service teams.
Your interaction with online targeted content (such as advertisements) that we, or service providers on our behalf, provide to you via third party websites or applications.
We also collect personal data through our relations with third parties and via our accounts on external platforms. For instance, if you interact with our content using social media features (such as "liking" a post on Facebook), we may receive information from your profile. This includes any data you have authorized the social network to share, such as your name, email, gender, birthday, location, and friend list. For more details on what information is shared, please review the privacy settings of the specific social network;
We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

2.2 This Policy does not cover websites or online services run by other organizations. Check their privacy notices to understand how they handle your information.

2.3 Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as "special categories of data" and benefit from additional protection under the European data protection legislation. We limit the circumstances where we collect and process these special categories of data.

2.4 We collect and process personal data only where we have an appropriate legal basis to do so, including your consent, the performance of a contract, compliance with legal obligations, protection of vital interests, or our legitimate interests where permitted by applicable law.

3. How Do We Protect Children's Privacy?

3.1 We understand the importance of taking extra precautions to protect the privacy and safety of children using our products and services.

3.2 We will obtain consent from the person with parental responsibility before we collect a child's personal data where it is required by applicable laws and regulations (the age at which consent is necessary varies from Country to Country).

3.3 If you are under the legal age requiring parental consent in your country, please review this Policy with a parent or guardian to ensure you understand and accept its terms. We do not knowingly collect personal data from children without required parental consent; if we discover such data has been collected, it will be deleted promptly. Please note that access to certain website features, rewards, or services may be restricted based on age.

3.4 We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions.

4. What Purpose Do We Use Your Data For?

4.1 We collect, process and disclose your personal data only for specific and limited purposes.

4.2 We may create user profiles by analysing your online browsing, search history, purchasing behaviour, and interactions with our brand. This process involves "segmenting", grouping individuals based on shared characteristics, and assigning your data to one or more of these segments. This helps us better understand our audience and refine our services.

4.3 Additionally, we process your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.

4.4 We collect, process and disclose your personal data for the following purposes:

To provide you with our products and services including our education services. For example, we use contact and account information to set up accounts, verify identity and eligibility for participation in classes, or any other service we may offer, and to improve and personalize your experience on our services.
To process your payments, if you purchase or subscribe to any of our services, to provide you with your service status, deal with your enquiries and requests, and assess and handle any complaints;
To develop and improve our products, services, communication methods and the functionality of our websites;
To communicate information to you including through marketing emails and to manage your registration and / or subscription to our newsletter or other communications;
To manage our everyday business needs regarding your participation in our contests or promotional activities or request;
To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
For internal training and quality assurance purposes;
To understand and assess your interests, wants, and changing needs, to improve our website, our current products and services, and/or developing new products and services;
To provide personalised products, communications and targeted advertising as well as product recommendations to you;
To learn more about you. We gather details like your interests, course selection, and shopping habits to better understand what you like. By combining info from our site with data from outside sources, we can improve our services and predict what products or features you might enjoy next;
To administer promotion, or loyalty program. For example, we use demographic information to check eligibility and to facilitate your participation in a promotion, or loyalty program or to share your personal information with third-party partners when you choose to;
To enforce our terms, agreements, and policies. For example, we review account information or consumer media uploads and moderate content, such as audio, pictures, and videos that you upload to participate in an experience as well as consumer-generated content to maintain a safe, secure, and trusted environment;
To comply with laws and policies. For example, we may use your contact and account information or other communications to protect against fraud or to detect security incidents or to monitor and enforce compliance with consumer agreements;
To fulfil our legal obligations or address legal claims or disputes. We are sometimes legally required to use or share your data. This includes keeping records for tax purposes, following anti-money laundering laws, or responding to official government requests like subpoenas and court orders. We also process this information to handle legal disputes or fulfil our own administrative requirements.

4.5 When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection. Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

4.6 NEL may use your personal data to build profiles and also content personalisation. By looking at how you browse, search, and shop, and even which classes you take, we build a profile of your interests. We use this to show you content and offers we think you'll actually like, both on our website and in our newsletters. This also helps us show you relevant ads on other websites. We only do this if you've given us your consent, like when you accept cookies or sign up for our emails or newsletter.

4.7 You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice (found on our website) or unsubscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.

4.8 We may also use personal data you have provided to selected third parties and if you have consented to be share, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.

4.9 We may share a common account identifier (such as an email address, phone number or user ID) with our third-party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5. Legal Basis for Processing

5.1 In some locations, we have an obligation to inform you that we process your personal information pursuant to certain legal bases. We rely on the following legal bases:

To Conclude or Perform a Contract with you: For example, when you enrol into a class, to register and verify your account, to administer prizes and promotions, and facilitate the functionality of our websites and mobile applications, including payment-related functionality.
For our Legitimate Interests: We process certain personal information in our legitimate business interests if it is not overridden by your privacy or other fundamental rights and freedoms, for example to communicate with you in relation to your accounts, our services, our marketing, and your requests or to enforce our terms, agreements, and policies.
To Comply with Applicable Laws: We are required to process certain personal information under certain laws and regulations, for example tax laws, as well as to maintain appropriate records for internal administrative purposes and to respond to lawful governmental requests, as needed.
With Your Consent: We process personal data to deliver tailored promotions and brand updates via email, SMS, and push notifications, provided we have your explicit consent. You maintain the right to withdraw this consent at any time by contacting us on the NEL website. Withdrawal of consent is effective moving forward and does not retroactively invalidate processing that occurred while consent was active.

6. Personal Information Sharing

We share personal information with the following categories of recipients:

Professional advisors, such as lawyers, accountants, insurers, and information security and forensics experts.
Third party Service providers and Consultants to enable them to perform services on our behalf, including teachers / educators, marketing vendors, advertisement agencies, cloud storage solutions, payment processors, and other such parties who help us carry out our business.
Third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time so that they may play or display ads on other devices, applications, and platforms that you may use.
Business partners (with consent, where required) to provide you with complementary offerings, access to information from our partners, and for marketing purposes.
Potential or actual acquirers or investors and their professional advisers in connection with any actual or proposed merger, acquisition, or investment in or of all or any part of our business.
Competent law enforcement, government regulators, and courts when we believe disclosure is necessary (i) to comply with the law, (ii) to exercise, establish or defend legal rights, or (iii) to protect the rights, property and safety of NEL, our consumers, employees, contractors, business partners, service providers, or another third party.
Other third parties with your permission or at your request.

7. International Data Transfers

7.1 NEL shares personal data within the Company or with third parties working on our behalf for purposes described in this Policy, and in compliance with applicable local laws. We will only send personal data collected within a restricted legal framework, such as e.g. the European Economic Area (EEA) or Asian Pacific Economic Cooperation (APEC), to countries which do not have data protection laws that are considered to provide appropriate levels of protection in the restricted legal framework in circumstances such as:

To follow your instructions
To comply with a legal obligation; or
To work with our contractors, agents and advisers who we use to help run our business and services.

7.2 If we do transfer personal data to outside of the restricted legal framework, we will make sure that it is protected in the same way as if it was being used in that restricted legal framework. We'll use one of the following safeguards:

Transfer to another Country whose privacy legislation contains a similar level of protection of personal data equivalent to the country it was collected in; or
Put in place a contract with the third-party that means they must protect personal data to the same standards as in the country the data was collected in.

7.3 We might send your information to other countries where we or our partners do business. These countries may not have the same level of privacy protection as the country where your data was collected. By using our services, you agree that your data can be moved and stored internationally. Such international transfers shall be carried out only where appropriate safeguards are implemented in accordance with applicable data protection laws.

7.4 To request information about our standard contractual clauses or other safeguards for cross-border personal information transfers, please Contact Us.

8. Protection of Personal Information

8.1 NEL undertakes to secure and safeguard the personal information entrusted to us. We work hard to protect your information from being lost, stolen, or changed without your permission. We use a mix of digital security (like encryption), physical security (like locked servers), and strict office rules to keep your data as safe as possible.

8.2 We use modern tools like encryption and anonymization to hide your identity whenever possible. Only the employees or contractors or other third parties working on our behalf, who absolutely need to see your info for their job can access it, and they must follow strict privacy rules and remain in compliance with this Policy. While we constantly test and update our defences, the nature of the internet means we can't guarantee security against every possible risk.

8.3 You are responsible for protecting your passwords and maintaining the security of your devices. Company treats access to our services through your account as being authorized by you.

8.4 We may suspend your use of all or part of our services without notice if we suspect or detect any breach of security. If you believe that information you provided to us or your account is no longer secure, please Contact Us.

8.5 If we become aware of a breach that affects the security of your personal information, we will provide you and any relevant data protection regulator with notice, as required by applicable law. When permitted by applicable law, we will provide this notice to you as well, using the email address associated with your account or another permitted method associated with your account.

9. How Long Do We Keep Personal Information

9.1 Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to provide our services, comply with our data retention policy and applicable legal requirements, resolve disputes, and enforce our agreements. We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.

9.2 When determining the applicable retention period, we consider various criteria, such as:

How long the record is needed to provide you with the services you have purchased;
How long the record is needed to support and enhance our operational processes;
How long the record is needed to protect our rights and legal interests; and
How long the record must be retained to comply with applicable laws.

9.3 We only keep your information for as long as we have a good reason to use it. For example, if you buy something, we'll keep your order details to manage the sale and handle any returns or questions you might have later. We also keep some data to make sure you get your loyalty rewards and to keep improving our website for you.

9.4 We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

9.5 We also reserve the right to delete your personal information if you are no longer an active account user or if we detect fraudulent activity.

10. Your Rights

10.1 You can make choices about our handling of your personal information. You can manage your privacy settings by using various tools available through your browser or that we make available to you depending on your jurisdiction, and you can Contact Us at [email protected]. In some cases, your ability to access or control your personal information will be limited due to applicable law.

10.2 Depending on your place of residence, the type of personal information collected, and subject to certain exemptions, you may have choices with respect to your personal information and some of these choices are subject to exemptions and qualifications. We may also choose to extend the following choices to you even if we are not required to under applicable law:

You can request information about how your personal information is processed. In some locations you may request information on the identities of third parties that your data has been shared with.
You can request access to your personal information.
You can request the correction of inaccurate or incomplete personal information.
You can request deletion of your personal information.
You can request that we limit the processing of your personal information in specific cases such as for profiling, automatic decision-making, etc.
You can request to receive your personal information in a machine-readable format or ask us to send it to another controller.
You can object to the processing of your personal information or withdraw your consent at any time.

10.3 If you exercise these privacy choices, you have the right not to be treated in a discriminatory or retaliatory way. We will respond to your requests at our own cost, unless otherwise specified.

10.4 To exercise your privacy choices and submit a privacy request form, please Contact Us at [email protected]. When you submit your request, you may need to provide some personal information for us to fulfil your request. We aim to complete requests as soon as reasonably practicable and consistent with any applicable laws. If you have an account with us, you may also make certain changes directly through your account profile page.

When submitting your request, please note:

We may need to verify your identity before we can act on your privacy request.
We may deny a part or all of your request. Sometimes, we can't delete or change your information even if you ask us to. For example, we have to keep records of your purchases until they are finished, and we can't delete data that is required by law or already public. If we can't fulfil your request, we will always write back and explain exactly why.
If you object the processing of your personal information or withdraw your consent, once we've verified your identity, we will immediately cease collecting and processing your personal information.
Before we delete anything, we will ask you to prove who you are to keep your account safe. Once we start the deletion, it might take a bit longer for your info to disappear from our backup systems due to technical or legal reasons. During that time, we'll keep your data locked away and won't use it for anything until it's fully erased.
In some locations, we are only obligated to respond to a limited number of your requests each year and may be limited in what personal information we can disclose.
We will maintain all your privacy requests in accordance with our retention policy and this information will not be used for any other purpose except to review compliance processes or in compliance with a legal obligation.
Providing your personal information is voluntary; however, it is necessary for fulfilling the purposes described in this Policy. Refusal to provide such personal information may partially or fully prevent the provision of Services, as well as limit your participation in certain features or benefits.

10.6 Depending on where you live, you can have someone else (like a lawyer or a privacy app) handle your data requests for you. If you do this, we'll check with you first to make sure they really have your permission. Just keep in mind that these requests might take a little longer for us to complete.

10.7 Please visit our Contact Us page on our website to obtain jurisdiction specific information contact information. For example, depending on your residency, you may have the right to appeal a decision regarding a request, lodge a complaint with another authority, or to find other applicable contact information for your local data controller, data protection officer, supervisory authority, data protection authority, or other regulator contact information.

10.8 Any data that cannot be reliably linked to a specific, verified individual will be excluded from request responses. Should we deny a request, either fully or partially, we will provide a written explanation of the refusal along with instructions on how to appeal the decision or submit a formal complaint where applicable by law.

11. Manage Your Privacy Settings

11.1 Mobile operating systems and app platforms (such as the Google Play store) have permission settings for specific types of mobile device data and notifications, such as for access to contacts, geo-location services, and push notifications.

11.2 Users may opt out of promotional emails via the "Unsubscribe" link or cancel SMS marketing by replying "STOP." You may also manage push notifications through your account settings or contact us directly at [email protected]. Please note that opting out of marketing does not affect essential service communications, such as transaction receipts or administrative updates.

11.3 Refer to the cookie notice on our website to review the choices that you have about the use of cookies.

11.4 You may delete your registered account at any time after logging in. After receiving your request to delete your account, we cannot guarantee that the corresponding information will be deleted from the backup system immediately. However, such information will be deleted when the backup system is updated unless otherwise provided by laws and regulations.

12. Changes to This Policy

12.1 As business and technology evolve, this Policy may be updated to reflect changes. The most recent version will be posted on our website. Certain laws may require additional steps, such as informing you or obtaining your consent for significant changes before they are implemented. Reviewing this Policy periodically will provide information about any updates related to the use of your personal information.

13. Contact Information

13.1 The Company welcomes your questions or comments regarding this Policy. If you believe that the Company has not adhered to this Policy, please contact us at [email protected].