12 February 2020
Capitalised Terms have the same meaning as set out in Neutopia’s Terms of Service and End User License Agreement.
Neutopia is the data controller for the processing of personal data in relation to Content Managers and End Users Neutopia accounts.
Each individual Channel Manager is the data controller for their End Users personal data and for any processing conducted in relation to the online courses provided by the Content Manager.
If you have any questions regarding processing for which the Content Manager is data controller, please contact the relevant Content Manager or the related school or business.
The Information Neutopia May Collect
Our primary purpose in collecting information from or about you is to provide you with the Neutopia experience. Neutopia collects information about you that Neutopia deems necessary to provide and improve its services.
Personal Information or Personal Data (“PII”): Neutopia may collect and process information that could be directly or indirectly associated with you; information such as your full name, company name where applicable, phone number, email address, billing or mailing address, credit/debit card information and other information that you share with Neutopia. You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Services because such information may be required in order for you to register with us; pay for Services; participate in our or Content Manager’s services; ask a question; or initiate other communications or transactions on our website.
Payment Information: For the purposes of billing Neutopia fees we will request your credit card and certain contact information, such as a billing address. We retain credit card information internally for the purpose of all payment processing related to our Services. The payment information is necessary in order for you to use our Services and failure to provide such information may result in you not being able to use our Services.
Information from Third Party Platforms: You may allow our Services to interact with one or more third party social networks or platforms, which will provide data about you to us (“Platform(s)”). The information you allow Neutopia to access varies by Platform, and it is affected by the privacy settings you and those that you are connected with establish while using such Platforms.
How We Use the Information We Collect
Purpose of the processing
Legal basis for the processing
To provide you access to our Services and communicate with you regarding Neutopia services.
To perform and improve our Neutopia Services as promised in our agreement with you.
To market and advertise our products and Services, including making recommendations about courses and other Services you may be interested in, conducting market research, surveys or competitions.
Balancing of interests where Neutopia has pursued the legitimate interest of performing and improving our service, interacting with our third party service providers and conducting marketing activities.
To prevent, detect, investigate and take measures against criminal activity, fraud and misuse of or damage to our Services or network and to take measures against other threats against Neutopia or a third party’s rights.
Legal basis for the processing: Balancing of interests where Neutopia has pursued the following legitimate interests: (a) Neutopia’s interest of investigating suspicion of and taking measures against misuse of or damage to our Services or network; (b) Neutopia and/or third party’s interest of investigating and producing evidence regarding criminal activity, fraud and other threats against its interest; and (c) Competent authority’s interest of conducting law enforcement activities and collecting evidence for such purposes.
To comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests.
Compliance with a legal obligation to which Neutopia is subject.
Disclosure of your PII
Neutopia provides to Content Managers information about the End Users enrolled in their respective Courses to allow them to understand who is using their content and to improve their services. Information we provide includes PII such as : (1) name, (2) email address, (3) IP address, and (4) other Neutopia activity about the End User. .
Neutopia may also disclose any of your information, which in some cases includes PII, in the following situations:
Please keep in mind that all of the information that you disclose or content that you post in your user profile, forum posts, comments, or other public portions of our website becomes public information.
We will save your PII until the later of,
(1) you elect to erase or delete your account, (2) period we require to retain your records to provide our service or enforce our rights (debt collection or other service related issue), (3) as required by law or legal processes.
Access to Your Information and other rights
You are, at any time you may request a copy of the PII that Neutopia holds about you and information about the processing thereof. Please note that Neutopia may charge a fee to recover its expenses to provide this data and we need to be able to confirm your identity in order to be able to respond to your request.
If you believe that any PII Neutopia is holding is incorrect or incomplete please send an email with your specific request to support@Neutopia.com. We will work with you to make any corrections deemed necessary. We may not accommodate a request to change information if Neutopia believes the change would violate any law or legal requirement or cause the information to be incorrect.
If you provide your email address to Neutopia, you will always have the opportunity to opt out of receiving email newsletters and promotions through the unsubscribe link in the email communications or by logging into and changing the preferences for your user account. We may send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If Neutopia has already provided your information to a third party (such as a credit card processing partner) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party.
You have the right to object, on grounds relating to your particular situation, at any time to Neutopia’s processing of your PII if the processing is based on, for example, legitimate interests. If you object to such processing, Neutopia will no longer be entitled to process your PII based on such legal basis, unless Neutopia can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights, and freedom or if it is conducted for the establishment, exercise, or defense of a legal claim.
You have, under certain conditions, the right to receive the PII concerning you and which you have provided to Neutopia, in a structured, commonly used and machine-readable format and have the right to transmit such PII to another data controller without Neutopia trying to prevent this, where Neutopia’s processing of your PII is based on a contract or consent and the processing is carried out by automated means. In such a case you have the right to request that the PII shall be transmitted from Neutopia directly to another data controller, where technically feasible.
You also have the right to withdraw your consent, if applicable. If you withdraw your consent, please note that this does not affect the lawfulness of the processing based on your consent before its withdrawal and that Neutopia may, under certain circumstances, have another legal ground for the processing and therefore may be entitled to continue the processing.
If you are unhappy with our processing of your PII or of an alleged infringement of the General Data Protection Regulation or other applicable data privacy laws, you may lodge a complaint with a competent supervisory authority, for example in the country of your habitual residence or place of work.
Our Policy Concerning Minors (Children under 18)
Securing Your Information
Neutopia takes a range of security measures designed to protect your PII and keep it confidential (unless it is non-confidential by nature) and free from any unauthorized alteration. For example, only authorized staff are permitted to access personal information, and they may do so only for permitted business functions.
Third Parties and Other Information Collectors
Note that any Do-Not-Track instructions from your browser or similar mechanism will not affect our collection of the data that you voluntarily provide to Neutopia through such means as browsing our website, signing up for any of the Services or any Courses, entering PII into information fields on our website, or posting on any of our forums or blogs. Be advised that third parties are free to collect any information that you volunteer to Neutopia that is visible to the public. Therefore, please do not provide Neutopia with any information that you do not want collected.
California Civil Code Section 1798.83 Compliance
Under California law, upon request Neutopia is required to disclose to its California customers the identity of any third parties to whom Neutopia has disclosed PII within the previous calendar year, along with the type of PII disclosed, for the third parties’ direct marketing purposes. Please note that under California law, Neutopia is required to respond to a customer request once during any calendar year.
If you are a California resident and would like to make such a request, email us at support@Neutopia.com.
Transfer of personal information to countries outside the EU/EES
Neutopia is incorporated and based in Australia. Your PII is therefore transferred outside the European Union (“EU”) and European Economic Area (“EEA”). Such transfer is necessary for the performance of the contract between you and Neutopia (article 49.1 (b) of the GDPR).
The Content Managers and Schools may also be established in countries outside the EU/EEA. Such transfers are necessary for the performance of the contract between you and Neutopia (article 49.1 (b) of the GDPR).
Your PII is also transferred to and processed by third party payment providers (such as Stripe and Paypal) and your bank. Such transfers are necessary for performance of the contract between you and Neutopia (article 49.1 (b) of the GDPR).
No Rights of Third Parties