Last Updated: September 3, 2025
1. Introduction
Newmensch.org (“we,” “us,” “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our online finance courses and services.
By using our website and services, you consent to the data practices described in this Privacy Policy.
2. Information We Collect
2.1 Personal Information You Provide
We collect personal information that you voluntarily provide when you:
- Create an account: Name, email address, password
- Purchase courses: Billing information processed through PayPal
- Contact us: Name, email address, message content
- Participate in courses: Course completion data, progress tracking, quiz results
2.2 Automatically Collected Information
When you visit our website, we automatically collect:
- IP address for security and analytics purposes
- Browser type and version
- Device information (operating system, screen resolution)
- Pages visited and time spent on our site
- Course access patterns and learning progress via Tutor LMS
2.3 Payment Information
We use PayPal as our payment processor. We do not store your credit card or banking information on our servers. PayPal handles all payment data according to their privacy policy and PCI DSS standards.
3. How We Use Your Information
3.1 Primary Purposes
We use your personal information to:
- Provide course access and manage your account
- Process payments through PayPal integration
- Track learning progress and course completion via Tutor LMS
- Send important updates about your courses and account
- Provide customer support and respond to inquiries
- Ensure security and prevent unauthorized access
3.2 Legal Basis for Processing (GDPR)
Our legal basis for processing your personal data:
- Contract performance: To provide courses you’ve purchased
- Legitimate interest: For security, analytics, and service improvement
- Consent: For marketing communications (where applicable)
3.3 Marketing Communications
- We may send course-related updates and educational content to your registered email
- You can opt out of marketing emails at any time using the unsubscribe link
- We will never sell or rent your email address to third parties
4. Data Sharing and Third-Party Services
4.1 Third-Party Services We Use
We share limited data with essential service providers:
PayPal (Payment Processing):
- Data shared: Name, email, transaction amount
- Purpose: Processing course payments securely
- Privacy Policy: https://www.paypal.com/privacy
Tutor LMS (Learning Management):
- Data shared: Name, email, course progress, completion status
- Purpose: Delivering course content and tracking learning progress
- Data is stored on our servers running Tutor LMS
4.2 No Sale of Personal Data
We do not sell, trade, or rent your personal information to third parties for marketing purposes.
4.3 Legal Requirements
We may disclose your information if required by law, court order, or to protect our legal rights and safety.
5. Data Security
5.1 Security Measures
We implement appropriate security measures to protect your personal information:
- SSL encryption for data transmission
- Secure hosting with regular security updates
- Access controls limiting who can view your data
- Regular backups to prevent data loss
5.2 PayPal Security
Payment data is processed securely by PayPal using industry-standard encryption and fraud prevention measures.
5.3 Data Breach Notification
In the unlikely event of a data breach affecting your personal information, we will notify you and relevant authorities as required by GDPR within 72 hours.
6. Your Privacy Rights (GDPR)
As a data subject under GDPR, you have the following rights:
6.1 Right to Access
You can request a copy of all personal data we hold about you.
6.2 Right to Rectification
You can request correction of inaccurate or incomplete personal data.
6.3 Right to Erasure (“Right to be Forgotten”)
You can request deletion of your personal data, subject to legal obligations.
6.4 Right to Restrict Processing
You can request that we limit how we process your personal data.
6.5 Right to Data Portability
You can request your data in a portable format to transfer to another service.
6.6 Right to Object
You can object to processing based on legitimate interests or for marketing purposes.
6.7 Right to Withdraw Consent
Where processing is based on consent, you can withdraw it at any time.
To exercise your rights, contact us at info@newmensch.org
7. Data Retention
7.1 Retention Period
We retain your personal data only as long as you maintain an active account with us:
- Account data: Retained while your account is active
- Course progress: Retained during your 12-month access period
- Payment records: Retained as required by German tax and accounting laws
- Support communications: Retained for 2 years for quality assurance
7.2 Account Deletion
When you delete your account or it becomes inactive:
- Personal information is permanently deleted within 30 days
- Some data may be retained longer if required by law (e.g., tax records)
- Anonymized analytics data may be retained for service improvement
8. Cookies and Tracking
8.1 Essential Cookies
We use strictly necessary cookies to:
- Maintain your login session
- Remember your course progress
- Ensure website security
- Enable basic website functionality
8.2 Analytics Cookies
We may use analytics cookies to understand how our website is used and to improve our services. These cookies do not identify you personally.
8.3 Cookie Control
You can control cookies through your browser settings, but disabling essential cookies may affect website functionality.
9. International Data Transfers
9.1 Data Location
Your personal data is primarily processed and stored within the European Union to ensure GDPR compliance.
9.2 Third-Party Transfers
When we share data with PayPal (a US company), appropriate safeguards are in place to protect your data according to GDPR requirements.
10. Children’s Privacy
10.1 Age Restrictions
Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children under 16.
10.2 Parental Discovery
If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.
11. Changes to This Privacy Policy
11.1 Policy Updates
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.
11.2 Notification of Changes
We will notify you of significant changes by:
- Email notification to registered users
- Prominent notice on our website
- Updated “Last Updated” date at the top of this policy
11.3 Continued Use
Your continued use of our services after policy changes indicates acceptance of the updated Privacy Policy.
12. Complaints and Supervisory Authority
12.1 Internal Complaints
If you have concerns about how we handle your personal data, please contact us first at info@newmensch.org.
12.2 Supervisory Authority
If you’re not satisfied with our response, you have the right to lodge a complaint with your local data protection authority or the German data protection authority (BfDI):
Federal Commissioner for Data Protection and Freedom of Information (BfDI)
- Website: https://www.bfdi.bund.de
- Address: Husarenstr. 30, 53117 Bonn, Germany
13. Contact Information
For any questions, concerns, or requests regarding this Privacy Policy or your personal data:
Data Protection Contact:
- Email: info@newmensch.org
- Subject Line: “Privacy Policy Inquiry Newmensch.org”
- Response Time: We will respond to your inquiry within 30 days
- Company Address: Davtashen 3 Block 18/16, Yerevan, Armenia
14. Definitions
- Personal Data: Any information that can identify you directly or indirectly
- Processing: Any operation performed on personal data (collection, storage, use, etc.)
- Data Controller: Newmensch.org (we determine how and why personal data is processed)
- Data Subject: You (the individual whose personal data we process)
- GDPR: General Data Protection Regulation (EU regulation 2016/679)
This Privacy Policy is effective as of the date listed above and governs our collection and use of your personal information from that date forward.
