This Privacy Policy (“Privacy Policy”) explains how the New Economic Academy LLC (“New Economic Academy”) will ensure an appropriate level of protection for the personal data of the user (“User”) (and personal data refers to information related to individuals who can be identified, directly or indirectly, especially by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific factors related to that individual, hereinafter referred to as “Personal Data”).

This Privacy Policy will clarify several matters including, but not limited to, (1) why the New Economic Academy collects and processes the User’s personal data and how it uses it, (2) the legal basis on which the New Economic Academy processes personal data, (3) who can access personal data, (4) where personal data may be stored or transferred, (5) how the security of personal data is protected, (6) how long personal data is retained, (7) how the User can access, modify, or delete their personal data, (8) what rights the User can exercise with respect to their personal data under current laws and regulations, (9) cookies, and (10) how to contact the New Economic Academy, etc.

This Privacy Policy applies to all services offered and provided by New Economic Academy LLC, including all of its subsidiaries and affiliates (“New Economic Academy”) on its websites, digital applications, contests, and other digital features (“New Economic Academy Services”).

Additionally, specific notifications may be sent that highlight particular uses we wish to make of the User’s personal data, with the option to opt-in or opt-out of specific uses on a case-by-case basis, including new services or other services that may have their own privacy policies.

Please note that in some countries, the user must be at least 18 years old to subscribe to the New Economic Academy’s services, while in others, the legal age may be higher than 18. In such cases, the user must reach the appropriate legal age to subscribe. Individuals under 18 may benefit from the New Economic Academy’s services, but only with the intervention, supervision, and consent of a parent or legal guardian.

Why Does New Economic Academy Collect and Process User Personal Data?

New Economic Academy collects and processes the User’s personal data for the following purposes:

1. To provide the User with the requested services; allow the User to use online forms and surveys, including New Economic Academy services that do not require any form of registration; allow the User to register for certain services such as newsletters, information feeds, or SMS updates, or to create an account. In such cases, the User will be required to provide personal data such as their name, email address, or phone number.

2. Depending on the situation, to allow the User to share information; enable the User to fully enjoy sharing features provided by New Economic Academy, such as participation in viewer forums and discussion groups, or interaction with second-screen applications for shared viewing. It also allows the creation of a public profile that may include, if the User chooses, their name and picture. The User’s personal data collected via one service may be combined with data collected from other New Economic Academy services to facilitate sharing certain items with known people.

3. To maintain and improve New Economic Academy services; to understand how the User utilizes the services and to carry out other functions; and to develop new services and offerings.

4. To provide the User with personalized services tailored to their needs and interests; to provide personalized content such as relevant ads and services; and to allow New Economic Academy to better understand the User for offering more services they may request, including exclusive offers, information, competitions, and improving their overall experience with our digital services.

5. If those services and features are activated at any time: to process transactions, store transaction records, ensure subscription fees are paid, and comply with legal or regulatory obligations related to this.

6. To communicate with the User; to allow the User to contact New Economic Academy; to maintain a record of our communications; to assist the User in resolving any issues they may face; to send promotional offers and direct marketing; to inform the User about upcoming services or changes to our digital offerings; and to contact the User for competitions or participation in various offers, if any.

7. To create and maintain a reliable and safe environment; to investigate, detect, prevent, or report fraud, misrepresentation, violations, security breaches, or other prohibited or illegal activities; to protect New Economic Academy’s vendors, the User’s rights, and the security of New Economic Academy’s services; to enforce New Economic Academy’s Terms of Service or other agreements or policies; and to verify the User’s identity.

8. To comply with any applicable laws or regulations or respond to legal requests for information from government authorities or through legal procedures; to achieve any other purpose disclosed to the User regarding New Economic Academy services; and to contact the User to resolve disputes or assist with New Economic Academy services.

On What Legal Basis Will New Economic Academy Process Personal Data?

Processing will be based on the type of data being processed, which will be done on one of the following legal bases:

1. User’s Prior Consent: For example, when the User is offered registration for New Economic Academy services, creating an account, subscribing to newsletters, or email marketing. The User will be clearly asked to accept or refuse the processing of personal data. If the User consents, they have the right to withdraw consent at any time. However, in some cases, choosing not to disclose personal data or withdrawing consent may limit the User’s ability to use certain services or features. For example, the User may not be able to access certain parts of New Economic Academy websites or respond to inquiries without providing the relevant information.

2. Contractual Relationship: In this case, processing of the User’s personal data is generally necessary to fulfill or perform that contract. This means that if the User does not agree to New Economic Academy processing their personal data in this context, New Economic Academy may refuse to enter into the contract with the User.

3. Legitimate Interests: For example, under data protection law, when monitoring or tracking devices are used to detect and prevent online fraud and intrusion. For instance, when a User accesses and visits New Economic Academy websites even without creating an account, and utilizes the services provided by New Economic Academy, the User acknowledges that New Economic Academy may perform legitimate data processing as described in this Privacy Policy. If the User does not agree with this policy, they are free to stop browsing/using New Economic Academy websites.

4. Legal Obligations: To carry out activities required by New Economic Academy.

Who Can Access the Personal Data?

For the purposes outlined above, New Economic Academy will allow access to the User’s personal data by authorized New Economic Academy employees who need to know this information in order to process it on behalf of New Economic Academy, and who are bound by strict contractual confidentiality obligations and may be disciplined or terminated if they fail to comply.

Additionally, New Economic Academy may need to transfer or allow third parties to access the personal data, including:

• Suppliers and service providers New Economic Academy works with to process personal data or execute services on behalf of New Economic Academy, following their instructions and in accordance with their privacy policies and other appropriate security and confidentiality measures.

• Successors in ownership or business of New Economic Academy (or those in serious negotiations with potential new owners of the business or company). Therefore, if the ownership of the company or a substantial part of New Economic Academy’s business changes or undergoes reorganization, the User acknowledges and accepts that New Economic Academy may need to transfer their personal data to the relevant third party (or its advisors) as part of any sale analysis or restructuring process. New Economic Academy may also need to transfer the User’s personal data to the reorganized entity or third party after the sale or restructuring, to use it for the same purposes described in this Privacy Policy.

• Media representatives or agents of New Economic Academy.

• Legal advisors, witnesses, experts, and judicial or quasi-judicial authorities to protect New Economic Academy from harm to its rights, property, or safety, and to protect its users, the public, and any third party as required or permitted by law, and to enforce New Economic Academy’s service terms or other agreements or policies.

• Administrative or judicial authorities to meet the requirements of any applicable law, regulation, legal procedure, or government request.

New Economic Academy may also aggregate data for public use or third-party partners, such as advertising companies or related sites. For example, data may be shared publicly to show usage trends for New Economic Academy services.

Where Can Personal Data Be Stored or Transferred?

New Economic Academy may be affiliated with an international group of companies and partners located in many countries around the world. As such, New Economic Academy may need to transfer the User’s personal data to other countries, including those outside the European Economic Area (EEA), and to countries where data protection laws may be less stringent than those in the User’s country. For example, New Economic Academy may process the User’s personal data on servers located outside the country where the User resides, and may transfer it outside of their home country for processing.

To ensure an adequate and consistent level of protection for the User’s personal data, New Economic Academy will continue to implement appropriate safeguards for its protection.

How is the Security of Personal Data Protected?

New Economic Academy follows physical, electronic, technical, and organizational security measures, including governance models, to protect the User’s personal data in accordance with data protection law, to prevent unauthorized access, use, alteration, disclosure, or destruction of personal data.

Please note that no data transmission over the internet or via websites can be guaranteed as 100% secure. Additionally, the User is also responsible for taking appropriate measures to protect their personal data, especially by keeping their password confidential. If the User learns or suspects that their account credentials have been lost, stolen, misused, or compromised, or there has been unauthorized use of their account, the User is advised to contact New Economic Academy following the instructions in the “How to Contact” section below.

If New Economic Academy becomes aware of a data breach involving the User’s personal data, it will promptly notify the affected Users according to applicable laws.

How Long is Personal Data Retained?

New Economic Academy will retain the User’s personal data as long as their account is active or as long as necessary for the fulfillment of the purposes for which it was collected. Personal data may also be retained for a period of time to comply with applicable laws, resolve disputes, and enforce agreements.