Privacy Policy
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Who Are We?
NeoAudio offers you practical audio language courses for quickly learning a foreign language for your next vacation or business trip.
Since 1993, the NeoAudio team has been designing and implementing learning programs, in particular for people who are blind or have low vision. Since 2016, NeoAudio's focus has been increasingly on audiobooks, thanks to a cooperation between Martin Luther University Halle-Wittenberg and Hanbat National University in Daejon, South Korea. The first audio language courses with a new didactic approach were developed in 2019. These practical courses offer an effective and flexible learning experience for beginners or those who want to resume their studies, allowing them to learn anywhere and at any time.
1. What this Policy covers
NeoAudio's main service is practical audio language courses for beginners and returning learners. The Website also offers or links to related learning materials. This Privacy Policy explains how we process personal data when you visit www.neoaudio.com, use audio-language-course information or interactive features, contact us, or obtain paid digital learning materials, including downloadable PDF files, through Paddle (each a Product).
Personal data means information relating to an identified or identifiable person. Processing includes collecting, recording, using, disclosing, storing, restricting, or deleting personal data.
2. Legal bases
Depending on the context, we process personal data on one or more of these legal bases:
- Article 6(1)(b) GDPR — steps requested before a contract and performance of a contract, including Product delivery, licence administration, and support;
- Article 6(1)(c) GDPR — compliance with legal duties, including tax, accounting, consumer-protection, and regulatory obligations;
- Article 6(1)(f) GDPR — legitimate interests, including Website security and stability, fraud and abuse prevention, service improvement, customer support, business administration, and the establishment, exercise, or defence of legal claims; and
- Article 6(1)(a) GDPR — consent, for example for non-essential cookies or direct marketing where consent is required.
Where we rely on legitimate interests, we balance those interests against your rights and reasonable expectations. You may object as described in section 4.
3. Controller and contact details
The controller responsible for NeoAudio's processing is:
Paddle is a separate controller for the processing described in section 8. The relevant Paddle controller is identified in Paddle Checkout, the transaction confirmation, or Paddle's Privacy Policy.
4. Your rights
Subject to the conditions and exceptions in applicable law, you may have the right to:
- obtain confirmation whether we process your personal data and receive access and a copy (Article 15 GDPR);
- correct inaccurate data and complete incomplete data (Article 16 GDPR);
- request erasure (Article 17 GDPR) or restriction of processing (Article 18 GDPR);
- receive data you provided in a structured, commonly used, machine-readable format and, where applicable, transmit it to another controller (Article 20 GDPR);
- object to processing based on Article 6(1)(e) or (f) GDPR, including an unconditional objection to direct marketing (Article 21 GDPR);
- withdraw consent at any time for the future without affecting processing that was lawful before withdrawal (Article 7(3) GDPR); and
- lodge a complaint with a competent data-protection supervisory authority (Article 77 GDPR).
To exercise rights concerning data controlled by NeoAudio, contact or email NeoAudio. We may request information reasonably necessary to verify identity. If we have disclosed corrected, erased, or restricted data to recipients, we will notify them where required by Article 19 GDPR.
5. Server and security logs
When you visit the Website, our hosting and security providers may process technical data sent by your browser, including IP address, date and time, requested URL, referrer URL, browser type and version, operating system, response status, and transferred data volume.
We use these logs to deliver the Website, maintain stability and performance, detect attacks and misuse, and investigate security incidents. The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are secure, reliable Website operation and legal defence.
Logs are normally deleted or anonymised when no longer needed for those purposes. If a record is needed as evidence of an incident, we may retain it until the investigation, claim, or applicable limitation period ends.
7. Contact requests
If you contact us by email or through a contact form, we process the information you provide, such as your name, email address, message, transaction reference, and any attachments, to answer the request and manage follow-up communication. Please do not send payment-card details or special-category data.
The legal basis is Article 6(1)(b) GDPR where the request concerns a contract or pre-contract steps and otherwise Article 6(1)(f) GDPR based on our legitimate interest in responding to enquiries. We retain correspondence until the request is resolved and then for any legally required or defensible period.
8. Purchases through Paddle
8.1 Roles of NeoAudio and Paddle
Paddle is NeoAudio's authorised reseller and Merchant of Record. Paddle is the seller for the transaction and independently determines how and why it processes data for checkout, payment, tax, invoicing or receipts, fraud prevention, regulatory compliance, transaction support, withdrawals, and refunds. NeoAudio independently determines how and why it processes data for Product fulfilment, access, licence administration, Product support, customer records, fraud prevention, and legal compliance.
Paddle's Data Sharing Addendum describes transfers between Paddle and the Supplier as controller-to-controller sharing. NeoAudio and Paddle are therefore not presented as one joint controller for all processing. Each party is responsible for the processing it controls and for answering requests relating to that processing.
8.2 Data collected by Paddle
When you open or use Paddle Checkout, Paddle may collect data directly from you and your device. Depending on location, payment method, and checkout type, this may include:
- name, email address, country, postal code, billing address, telephone number, and language preferences;
- business name, registration details, tax or VAT identifiers, and invoice information where relevant;
- Product, price, currency, tax, discount, transaction, delivery, refund, and purchase-history data;
- payment and financial information, including payment method, cardholder or account-holder information, payment identifiers, and payment status;
- IP address, device, browser, operating system, checkout events, timestamps, security signals, and approximate location derived for tax or fraud purposes; and
- consent records, support communications, withdrawal or refund requests, and fraud or chargeback information.
Paddle's own Privacy Policy, checkout notice, and cookie notice govern Paddle's processing. If Paddle checkout recovery is enabled, Paddle may use an email address entered into an abandoned checkout to send a recovery message under its applicable settings and notice.
Paddle Privacy Policy: https://www.paddle.com/legal/privacy
8.3 Data shared with NeoAudio
Paddle may make buyer data available to NeoAudio through the Paddle dashboard, APIs, webhooks, transaction emails, or support channels. Under the Data Sharing Addendum, shared categories include buyer names and addresses, email addresses, purchasing history, and transactional analytics available to the Supplier.
Depending on Paddle's product and our permissions, transaction analytics may include customer and transaction identifiers, Product, amount, currency, tax, status, timestamps, country, refund or chargeback status, and limited payment-method metadata. NeoAudio does not ask you to enter complete payment-card credentials into a NeoAudio form. We do not intend to receive special-category personal data through Paddle.
8.4 Why NeoAudio processes Paddle transaction data
- to provide the PDF or download link, confirm entitlement, and administer the Product licence — Article 6(1)(b) GDPR;
- to provide Product, accessibility, and technical support and communicate about fulfilment — Article 6(1)(b) GDPR and, where appropriate, Article 6(1)(f) GDPR;
- to reconcile transactions with Paddle, maintain business records, and comply with tax, accounting, consumer-protection, and regulatory duties — Article 6(1)(c) GDPR and Article 6(1)(f) GDPR;
- to prevent fraud, refund abuse, chargebacks, unauthorised distribution, and security incidents — Article 6(1)(f) GDPR and, where applicable, Article 6(1)(c) GDPR;
- to establish, exercise, or defend legal claims — Article 6(1)(f) GDPR; and
- to send marketing only where a separate valid consent or another lawful basis permits it. A purchase does not by itself constitute consent to marketing.
8.5 Recipients
NeoAudio may disclose personal data where necessary to Paddle; hosting, email, IT, security, support, fulfilment, and professional-service providers acting under appropriate obligations; competent authorities, courts, payment schemes, or advisers where required by law or needed for legal claims; and a successor in a lawful business reorganisation.
Paddle separately discloses data to its affiliates, payment providers, fraud-prevention and compliance providers, tax and professional advisers, authorities, and other recipients described in Paddle's Privacy Policy.
8.6 International transfers
Paddle operates through entities and providers in several countries. Paddle's Privacy Policy states that, where required, it uses adequacy decisions, Standard Contractual Clauses, and other appropriate safeguards for transfers from the EEA or United Kingdom. Paddle's Data Sharing Addendum incorporates controller-to-controller safeguards for restricted transfers where applicable.
Where NeoAudio itself transfers personal data to a recipient outside the EEA in a country without an adequacy decision, we use a lawful transfer mechanism and supplementary safeguards where required. You may contact us for information about applicable safeguards, subject to protection of confidential information.
8.7 Retention
NeoAudio retains Paddle transaction data for as long as necessary to deliver and support the Product, administer the licence, meet statutory recordkeeping duties, prevent fraud, and resolve claims or disputes. Different fields may have different retention periods. Data is deleted or anonymised when no purpose or legal basis remains.
Paddle determines and explains its own retention periods in its Privacy Policy. A Paddle transaction record may need to remain as a financial or compliance record even where other customer data can be deleted.
8.8 Exercising rights in relation to Paddle data
For data controlled by NeoAudio, contact or email NeoAudio. For data controlled by Paddle, use Paddle's privacy request portal or contact Paddle at [email protected]. A request sent to one controller does not necessarily reach the other, although the controllers may assist each other where legally required.
Paddle privacy requests: https://preferences.paddle.com/
9. Marketing communications
NeoAudio does not use a purchase email address for unrelated marketing merely because a purchase occurred. Where we invite you to subscribe, we record the consent and provide an unsubscribe method. You may withdraw consent or object to direct marketing at any time. Transactional messages needed for delivery, security, support, or legal notices are not marketing.
10. User posts, comments, and ratings
If we offer public posts, comments, questions, or ratings, we process the submitted content, display name or pseudonym, submission time, and any information you choose to include in order to publish and moderate the feature. The legal basis is consent under Article 6(1)(a) GDPR where we request it, or Article 6(1)(f) GDPR where processing is necessary to operate and protect the community feature.
We may also process IP address, account information, and contact details where reasonably necessary to prevent abuse, investigate unlawful content, defend rights, or comply with legal duties. Do not publish personal data about other people without a lawful basis.
12. Cloudflare
We use services from Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA to deliver content, provide TLS encryption, improve performance, and protect the Website from attacks. Cloudflare may process IP address, request, device, security, and diagnostic data as necessary to provide these services.
The legal basis for NeoAudio's use is Article 6(1)(f) GDPR. Our legitimate interests are fast, secure, and resilient Website delivery. Where data is transferred internationally, applicable adequacy mechanisms, contractual safeguards, or other lawful transfer tools are used. Through certification by the EU-US Privacy Shield Framework https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active Cloudflare guarantees that the EU data protection requirements will be observed even when data are processed in the USA. Cloudflare explains its own processing in its Privacy Policy.
Cloudflare Privacy Policy: https://www.cloudflare.com/privacypolicy/
13. Children
The Website is not intended to collect personal data directly from children under 13. A person who cannot enter into a binding purchase contract under applicable law must use Paddle Checkout only through a parent or legal guardian. If you believe a child has provided personal data without appropriate authorisation, contact us.
14. Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. No internet transmission or storage system is completely secure. Please do not send sensitive payment or identification data through ordinary email or the contact form.
15. General retention rule
Unless a more specific rule is stated above, we keep personal data only for as long as necessary for the purpose for which it was collected, plus any period required by law or reasonably needed for legal claims, security investigations, or dispute resolution. We then delete, anonymise, or securely restrict the data.
16. Changes to this Privacy Policy
We may update this Privacy Policy when our processing, Website, providers, Products, or applicable law changes. The current version is published on the Website with its revision date. Where legally required, we will provide additional notice or request consent before a material change takes effect.
17. Contact
Questions or requests concerning NeoAudio's processing, just contact or email NeoAudio.
Questions or requests concerning Paddle's processing:
Paddle Privacy Policy: https://www.paddle.com/legal/privacy
Paddle privacy request portal: https://preferences.paddle.com/