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Privacy policy

1.  Introduction

The privacy of our website visitors is very important to us, and we are committed to protecting it. This policy details what we do with your personal information.

Consenting to our use of cookies in accordance with this policy when you first visit our website allows us to use cookies each time you visit our site.

2.  Source

This document was created using a template from SEQ Legal (seqlegal.com), modified by Website Planet (websiteplanet.com) and adapted specifically for use by users of the https://newtrain.com/ website.

3.  Collection of Personal Information

The following types of personal information may be collected, stored and used:

Information about your computer, including your IP address, geographic location, browser type and version, and operating system;

Information about your visits to and use of this website including the referring source, length of visit, pages viewed, and website navigation paths;

  1. Information such as your e-mail address, which you provide to us when you register for the site;
  2. Information you enter when you create a profile on our website such as your first and last name and email address;
  3. Information such as your name and email address, which you enter to contact us via the contact form https://newtrain.com/contact/;
  4. Information that you enter when you use the services on our website;
  5. Information generated when you use our site, including when, how often and under what circumstances you use it;
  6. Information that you post on our website with the intention of publishing it on the Internet, including your user ID, and the content of your comments;
  7. Information contained in any communications you send to us by e-mail or on our website, including their content and metadata;
  8. Any other personal information you provide to us.

Before you disclose personal information about another person to us, you must obtain that person’s consent to the disclosure and processing of that personal information under the terms of this policy.

4.  Use of Your Personal Information

Personal information provided to us through our website will be used for the purposes described in this policy or on the relevant pages of the website.

We may use your personal information to:

  • Administer our website and our business ;
  • Customize our website for you;
  • Enable your use of the services offered on our website;
  • Send you non-marketing communications; Send you e-mail notifications that you have specifically requested;
  • Send you marketing communications about our company or carefully selected third party companies that we believe may be of interest to you, in the form of a publication, or if you have expressly agreed, by e-mail or similar technology (you may notify us at any time that you no longer wish to receive marketing communications);
  • To provide statistical information about our users to third parties (without such third parties being able to identify individual users with this information);
  • To process requests and complaints about your website made by or about you;
  • To maintain the security of our website and prevent fraud; and
  • Other uses.
  • If you submit personal information to our website for the purpose of publication, we will publish it and may use that information in accordance with the permissions you grant us. Without your explicit consent, we will not provide your personal information to third parties for their direct marketing or to other third parties.

5.  Disclosure of Your Personal Information

We may disclose your personal information to any of our employees, officers, or contractors to the extent reasonably necessary for the purposes set forth in this policy.

We may disclose your personal information:

  • To the extent we are required to do so by law;
  • In connection with any pending or future legal proceedings;
  • To establish, exercise or defend our legal rights (including providing information to others for fraud prevention and credit risk reduction purposes);
  • To the purchaser (or potential purchaser) of any business or assets in our possession that we wish to (or are considering) selling; and
  • To any person whom we reasonably believe to be a party to a court or other competent authority for the disclosure of such personal information if, in our opinion, such a court or authority would be likely to require disclosure of such personal information.

Except as otherwise provided in this Policy, we will not provide your personal information to third parties.

6.  International Data Transfers

Personal information that you post on our website or submit for posting may be available, via the Internet, throughout the world. We cannot prevent the use, good or bad, of this information by third parties.

7.  Retention of Your Personal Information

This Section 7 details our data retention policies and procedures, designed to help us comply with our legal obligations regarding the retention and disposal of personal information.

Personal information that we process for any purpose is retained no longer than is necessary for that purpose or those purposes.

Without prejudice to Section 7, we will generally delete personal data in these categories:

1. 2 years after the completion of a service, if any,

2. or upon termination of your personal guest account which essentially allows you to post content (comments) on the website.

Notwithstanding the other provisions of this Section 7, we will retain records (including electronic records) containing Personal Data:

– To the extent we are required to do so by law;

– If we believe the records may be relevant to any current or potential legal proceedings; and

To establish, exercise or defend our legal rights (including providing information to others for fraud prevention and credit risk reduction purposes).

8.  Security of Your Personal Information

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. We will store all personal information you provide to us on secure servers (password and firewall protected). You acknowledge that the transmission of information over the Internet is inherently insecure, and that we cannot guarantee the security of your data sent over the Internet. You are responsible for maintaining the confidentiality of the password you use to access our website; we will not ask you for your password.

9.  Amendments

We may occasionally update this policy by posting a new version on our website. You should check this page periodically to ensure that you are aware of any changes to this policy. We may notify you of changes to this policy by email or through our website’s private messaging service.

10.     Your Rights

You may ask us to provide you with any personal information we hold about you; the transfer of such information will be subject to the following condition: the presentation of sufficient proof of your identity (for these purposes, we will generally accept a photocopy of your identity card or passport plus an original copy of a utility bill showing your current address).

We may retain the personal information you request to the extent permitted by law. You may ask us at any time not to process your personal information for marketing purposes. In practice, you will expressly agree in advance to our use of your personal information for marketing purposes or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

11.     Third Party Websites

 Our website contains hyperlinks to third party websites and information about them. We have no control over these sites, and are not responsible for their privacy policies or practices.

12.     Updating Information

Please let us know if the personal information we hold about you needs to be corrected or updated.

13.     Cookies

See the cookie policy at https://newtrain.com/privacy-policy/.

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