Privacy Policy

Accountability and Compliance

NeoSkills Academy is responsible for the personal data under our control. We have established policies and procedures to safeguard confidential personal data we collect and to handle complaints and inquiries. We are committed to maintaining the accuracy, confidentiality, and security of your personal data, and we will ensure you have access to information about the policies and procedures we use to manage it.

NeoSkills Academy has designated a Privacy Officer / Data Protection Officer (the "Privacy Officer") who is accountable for our compliance with this Policy. All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing by email or postal mail using the contact details at the end of this page.

Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found, we will take appropriate measures to address it. This may include amending our policies and procedures. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.

Consent

By using the Services, you signify your agreement to the terms of this Policy and to our collection, use and disclosure of your personal data as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal data at any time by contacting the Privacy Officer. In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.

Collection and Retention of Information

We collect personal data only to the extent necessary for the purposes set out below. Subject to any legal or accounting requirements, we will retain personal data only as long as necessary to fulfill those purposes. Personal data that is no longer required will be destroyed, erased, or made anonymous, although copies of deleted information may continue to exist on backup media.

User Submitted Information

We collect personal data when users register to create an account or update their account details, including name, email address, and other contact information. We also collect personal data users submit through their use of the Services, including contact and other information collected from email subscribers and when they create and send email campaigns.

Usage Data

We collect non-identifying information about the usage of the Services, including how users use the Services and the characteristics of those users. This information is anonymized and is not used by us to identify you as an individual.

Account Deletion Requests

You may request at any time to have your account data deleted by contacting us. Upon receiving the request, we will send you a confirmation email. After successful confirmation, your account will be marked for deletion in 30 days. During this 30-day period, you may request reactivation by contacting us. After 30 days the account is permanently deleted and cannot be reactivated.

Account Inactivity

To protect your privacy and your data, if your account is not active for a period of one year, it will automatically be permanently deleted. Thirty days prior to deletion, we will send a notification to the account email address with information and instructions on how to keep the account active if desired.

Data Retention Policy

An account can be permanently deleted either by a deletion request or through account inactivity. We retain personal data only for as long as necessary to provide the Services you requested and thereafter for legitimate legal or business purposes. These may include retention periods:

• needed to maintain adequate and accurate business and financial records;
• for resolving, preserving, enforcing or defending our contractual or legal rights;
• mandated by law, contract or similar obligations applicable to our business;
• to protect recipients from spam or malicious emails.

Technical and Device Information

We collect non-identifying information related to your access to the Services, including your IP address, the date and time you accessed the Services, and the operating system you use. We make no attempt to link this information with the identity of individuals visiting our site without express permission. We may review server logs and anonymous traffic for system administration and security purposes.

Cookies and Web Beacons

A "cookie" is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. A cookie cannot run any programs, deliver viruses, or send back information about your system.

We use cookies to determine your access privileges on our site, to complete and support a current activity, and to track site usage. Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or alert you when cookies are being sent. If you decline cookies, you will still be able to use the Services, but your ability to access certain features and functions may be affected. See our dedicated Cookies page for more detail.

A "web beacon" is an invisible electronic image used to track certain information. We use web beacons on our sites and in emails we send or that you send through the Services. The information gathered allows us to measure the success of email campaigns and to improve the Services.

Why We Collect, Use and Disclose Information

We will identify the purposes for which we collect personal data before or when we request the information. We will not collect personal data that is not necessary and, except as specified below, will not use or disclose personal data for any purpose other than the purposes for which it was collected without first obtaining your consent. The information we collect is used and disclosed only for business purposes, including:

• to enable you to access and use the Services;
• to process, track and communicate with you about the usage of the Services;
• to establish, maintain and manage business relations with you so we may provide you with the information, products, or services you request;
• internal business purposes, such as administering or improving the Services;
• to perform internal market research and conduct polls and surveys;
• to obtain feedback regarding the Services and our ability to address a user's needs;
• to provide users with information and promotional materials regarding NeoSkills Academy products and services;
• to protect against error, fraud, theft, or damage to our goods, business, or property;
• to comply with any legal, accounting, and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas, or court orders; and any other reasonable purpose for which you provide consent.

We may collect, use, or disclose your personal data without your knowledge or consent where we are permitted or required to do so by applicable law, government request, or court order, or based on our good faith belief that it is necessary to comply with such law, request, or court order, or to protect our assets, users, or the public.

Disclosure to Third Parties

We may disclose your personal data in response to requests from government agencies, law enforcement authorities, and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal data when we buy a business or sell all or part of our business.

In the course of providing the Services, we may delegate our authority to collect, access, use, and disseminate your information to third-party subcontractors. Third-party subcontractors may include web hosts, payment processors, delivery and logistics providers, social network integrators, and membership vendors. If we transfer any personal data to a third-party subcontractor, we will provide only the information needed to perform the subcontracted service and will use appropriate contractual or other means to provide a comparable level of protection.

How Information is Protected

We maintain reasonable security safeguards to protect personal data in our possession or under our control from loss, theft, and unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the information is held. The safeguards applied depend on the sensitivity of the personal data, with the highest level of protection given to the most sensitive. We use user IDs, passwords, and encryption technology, and restrict the employees and contractors who have access to personal data to those with a "need to know" and who are bound by confidentiality obligations.

When destroying personal data, we delete electronically stored personal data and shred any tangible materials. Deleted information may continue to exist on backup media but will not be used unless permitted by law.

We continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet to collect and process personal data may involve the transmission of data across networks not owned or operated by us; by using the Services you acknowledge and agree to our processing of personal data in this way.

Accuracy and Access

NeoSkills Academy has a responsibility to ensure that all personal data contained in our records or disclosed to third parties is accurate, complete, and up to date. You may make a written request for access to your personal data. We will inform you of the personal data we hold about you, provide an account of the use made of the information, and identify any third parties to whom it has been disclosed. You may have reasonable access to your personal data, and if you demonstrate inaccuracy or incompleteness, the information will be amended as appropriate. Please advise us immediately if you discover inaccuracies, if your personal data changes, or if you wish to have your information removed from our files.

International Transfer and Storage of Information

You acknowledge and agree that your personal data may be transmitted, transferred, processed, and stored outside of Morocco, including in the United States and the EU, and therefore may be available to governmental authorities under lawful orders and laws applicable in such jurisdictions. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as those of Morocco.

Third-Party Content and Links

The Services may contain optional links to third-party internet sites and services. You acknowledge that these third parties may collect data from users or their computers. Accessing and using third-party sites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies, or actions of third parties. This Policy applies only to the NeoSkills Academy Services, and we encourage you to review the privacy policies of any third parties when using their sites or services.

Minors

Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal data to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of an adult. NeoSkills Academy does not knowingly collect personal data from minors.

Notice of Breach

In the event of a security breach causing unauthorized intrusion into our Services that materially affects you or your contacts, NeoSkills Academy will notify you as soon as possible and later provide a report of the actions we took in response.

Your Data Rights

NeoSkills Academy takes reasonable steps to ensure the data we collect is accurate, complete, and up to date. You can manage most of your data through the Services; you can also contact us directly at contact@neoskillsacademy.com about deleting, updating, or accessing your personal data. We will honor your request in accordance with applicable laws.

If you are using our Services to process personal data from certain territories such as the European Union, you may have broader data protection rights:

• The right to be informed.
• The right of access and rectification, contact us to request updates or corrections.
• The right to erasure, you can cancel your NeoSkills Academy account at any time, subject to our Terms of Use.
• The right to restrict processing in certain circumstances.
• The right to data portability, request your personal data in a structured, commonly used, machine-readable form.
• The right to object to further processing of your personal data in certain circumstances.

Data Protection, Purpose and Scope

NeoSkills Academy needs to gather and use certain information about individuals, including customers, suppliers, business contacts, employees, and others the organization has a relationship with. This section describes how personal data must be collected, handled, and stored to meet our data protection standards and to comply with the law.

Why this policy exists

This data protection policy ensures NeoSkills Academy:

• complies with data protection law and follows good practice;
• protects the rights of staff, customers, and partners;
• is open about how it stores and processes individuals' data;
• protects itself from the risks of a data breach.

Data protection principles

Personal data must:

• be processed fairly and lawfully;
• be obtained only for specific, lawful purposes;
• be adequate, relevant and not excessive;
• be accurate and kept up to date;
• not be held for any longer than necessary;
• be processed in accordance with the rights of data subjects;
• be protected in appropriate ways;
• not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

Policy scope

This policy applies to the head office and all branches of NeoSkills Academy, all staff and volunteers, and all contractors, suppliers and others working on our behalf. It applies to all data the company holds relating to identifiable individuals, including names, postal addresses, email addresses, telephone numbers, and any other information relating to individuals.

Data Protection, Responsibilities

Everyone who works for or with NeoSkills Academy has some responsibility for ensuring data is collected, stored and handled appropriately. The following people hold key areas of responsibility:

Board of directors

Ultimately responsible for ensuring NeoSkills Academy meets its legal obligations.

Data Protection Officer

The Data Protection Officer is responsible for:

• keeping the board updated about data protection responsibilities, risks, and issues;
• reviewing all data protection procedures and related policies, in line with an agreed schedule;
• arranging data protection training and advice for the people covered by this policy;
• handling data protection questions from staff and anyone else covered by this policy;
• dealing with subject access requests from individuals;
• checking and approving any contracts or agreements with third parties that may handle sensitive data.

Web developer

Responsible for:

• ensuring all systems, services, and equipment used for storing data meet acceptable security standards;
• performing regular checks and scans to ensure security hardware and software is functioning properly;
• evaluating any third-party services the company is considering using to store or process data.

Marketing manager

Responsible for:

• approving any data protection statements attached to communications such as emails and letters;
• addressing any data protection queries from journalists or media outlets;
• ensuring marketing initiatives abide by data protection principles.

Data Storage and Handling

Only those who need data covered by this policy for their work should have access to it. Data should not be shared informally; when access to confidential information is required, employees can request it from their line managers. Strong passwords must be used and they should never be shared. Personal data should not be disclosed to unauthorized people, either within the company or externally. Data should be regularly reviewed and updated if found to be out of date, and deleted if no longer required.

Paper storage

When data is stored on paper it should be kept in a secure place where unauthorized people cannot see it. When not required, paper or files should be kept in a locked drawer or filing cabinet. Printouts should be shredded and disposed of securely when no longer required.

Electronic storage

• Data should be protected by strong passwords that are changed regularly and never shared.
• Removable media (CDs, DVDs, USB drives) must be kept locked away securely when not in use.
• Data should only be stored on designated drives and servers, and only uploaded to approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently and backups should be tested regularly.
• Data should never be saved directly to laptops or other mobile devices.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use

• Employees should ensure screens are locked when left unattended.
• Personal data should not be shared informally, especially not by unencrypted email.
• Data must be encrypted before being transferred electronically.
• Personal data should not be transferred outside of the European Economic Area without appropriate safeguards.
• Employees should not save copies of personal data to their own computers; always access and update the central copy.

Subject Access Requests

All individuals who are the subject of personal data held by NeoSkills Academy are entitled to ask what information the company holds about them and why, ask how to gain access to it, be informed how to keep it up to date, and be informed how the company is meeting its data protection obligations.

Subject access requests should be made by email, addressed to the data controller at contact@neoskillsacademy.com. The data controller can supply a standard request form, although individuals do not have to use it. The data controller will aim to provide the relevant data within 14 days and will always verify the identity of anyone making a subject access request before handing over any information.

Comments Policy

Comments are welcomed and encouraged on neoskillsacademy.com, but there are some instances where comments will be edited or deleted. Comments are subject to our Terms of Use and this Privacy Policy. Violations may result in comments being deleted and commenters being blocked from access to commenting or to the site entirely. Commenting is a privilege, not a right.

NeoSkills Academy reserves the right to edit, delete, move, or mark as spam any and all comments, and to block access to any person or group from commenting or from the entire site.

• Comment form guidelines, the form must be filled in with a legitimate name and URL. Comments with spam or suspicious information will be deleted.
• Links, links must be relevant and add value; comments with more than one link are automatically held for moderation.
• Thank-you comments, superficial comments that appear to seek a backlink will be deleted.
• Copyright and plagiarism, comments containing proprietary, copyrighted, or plagiarized information will be deleted and the commenter may be blocked.
• Email privacy, email addresses are required for commenting, are not published, and are not shared; they may be used by administrators to contact the commenter privately.
• Commenter privacy, comments containing email addresses, physical addresses, phone numbers, or other private information will be deleted to protect the affected party.
• Attachments, to post an image or file, upload it to a file-sharing service and link to it in your comment. Do not post screenshots of code.
• Language and manners, comments including offensive or inappropriate language will be deleted; personal attacks are not permitted.
• Approval timing, please be patient; comments cannot always be approved right away.
• Multiple comments, multiple related comments on the same post may be combined into one.
• Irrelevant comments, may be moved to another post or deleted if no suitable post exists.
• Comment spam, will be deleted and reported to services such as Project Honeypot, Botscout, and Stop Forum Spam.
• Liability, all comments are the responsibility of the individual commenter.
• Trackbacks, are treated inline with this Comments Policy.