Privacy Policy

Effective Date: May 23, 2018

Welcome to, (the “Website”), a service of New Levant Initiative, LLC (“NLI”, “our”, “us”, or “we”).  The NLI respects the privacy of visitors to the Website.  Please read this Privacy Statement carefully so that you understand what information we collect through the Website and what we do with that information.  This Privacy Statement applies only to information collected online through the Website and does not apply to any information you may provide to us, or that we may collect, offline or through other means (for example, via telephone, through the mail, or at live events).  If you have any questions about this Privacy Statement, we can be reached via email at NLIPRIVACY@NEW-LEVANT.ORG

Protecting the privacy of children

The Website is not directed at children under the age of 13 and we do not knowingly collect personal information from children under the age of 13.  If you’re under 13, please don’t provide any information about yourself on the Website.

Types of information we collect

The information that we and/or our service providers collect falls into two categories: (1) information voluntarily supplied by visitors when they use the Website, such as when they register for an account or subscribe to our offerings, sign up to receive our email newsletters, make a purchase of other content, products, or services that we may offer, respond to user surveys, and the like; and (2) certain technical information that is automatically collected as visitors navigate through the Website and review our email newsletters and other email messages.

Third parties featured on or linked to by the Website, such as advertisers and others that display promotional messages on the Website or offer products and services through the Website (“Advertisers”), may be gathering information as well, through processes we don’t control.

Information You Voluntarily Supply to Us

We may collect and store information that you voluntarily supply to us while on the Website.  In accessing and using the Website, you may have the opportunity to voluntarily submit some or all of the following types of personal information:

  • Contact information, such as your name and email address;
  • Communications preferences, such as which email messages you would like to receive from us;
  • Questions or correspondence you send to us through the Website.

You are not required to provide personal information about yourself to visit the Website.  However, you must provide certain information to use or access certain features of the Website.  For example, if you wish to receive our newsletters, you will be required to provide us the email address to which you want us to send the newslettersWe may collect other types of information for other functions.

Information That Is Collected Automatically

We also may collect and store, and permit our service providers to collect and store, certain technical information that is generated automatically as you navigate through the Website.  For example, we and our service providers may collect limited information about the configuration of your computer or other device through which you access the Website, including the type of browser software you use, the operating system you’re running, the resolution of your computer monitor, the website that referred you, the type of mobile device you’re using to access the Website (for example, iPhone, BlackBerry, Android device, tablet, etc.), and your IP address.  (Your IP address is a numerical address that is used by computers connected to the Internet to identify your computer so that data – such as the web pages you want to view – can be transmitted to you.)  We use this information to make the Website as useful as we can for as many users as possible. For example, we use IP address information for systems administration and troubleshooting purposes.

Cookies and Pixel Tags

We may use “cookies,” a standard feature found in browser software, to enhance your experience on the Website.  Cookies are small files that your web browser places on your hard drive for record-keeping purposes.  We also may use pixel tags (sometimes referred to as “clear GIFs” or “web beacons”) to collect non-personally identifiable information about how our visitors use the Website.  By showing how and when visitors and registered users use the Website, cookies and pixel tags help us deliver more relevant content to users, identify how many unique users visit the Website and various pages within the Website, and anonymously track user interests, trends and patterns.  For example, we may use these technologies to collect aggregate information about the time visitors spend on each page of the Website, the number of visits made to each page or section of the Website, and the content that visitors select and copy using the standard copy and paste tool provided in standard web browsers.  Providers of web analytics services may use cookies and pixel tags to gather this sort of information on our behalf.  And Advertisers that display ads or other promotional messages (“Ads”) on the Website (and their providers of ad serving and other advertising services) may use cookies and pixel tags of their own in connection with Ads displayed on the Website, as described below under the heading “Data Collected in Connection with Ads or Your Use of the Website.”

We also may use cookies to record certain preferences that you enter or set while using the Website.  For example, if you are a registered user and you opt to have the Website “remember you,” we’ll use cookies to automatically store your log-in information so that you won’t have to re-enter it the next time you visit.

The help function on most web browsers contains information on how to set your browser to notify you before accepting a cookie or to disable cookies entirely.  However, if you don’t accept cookies, you won’t be able to take advantage of various features on the Website that are available to other visitors.  Click here to decline.

Where required by law, we will only place cookies or pixel tags and other tracking technologies on your device if you have agreed to these being placed except where such cookies, pixel tags or tracking technologies are strictly necessary to provide a service that you request. If you had declined tracking you can opt back in by clicking here.

How we use collected information and the legal basis on which we use it


We use the information we collect from you while you are using the Website to provide you with services and communications that you have requested; to send you email updates, newsletters, and other communications; to deliver the Website content to you; to measure Website traffic; to measure user interests and traffic patterns; to improve the Website and the services and features offered via the Website; and to detect, prevent, and respond to fraud, intellectual property infringement, violations of our Visitor Agreement, violations of law, or other misuse of the Website. In certain cases, we use your personal information in these ways as it is necessary for the performance of our obligations to you as set out in the Visitor Agreement, for example to provide your email newsletters. Where this is not the case, we use your personal information to meet our legitimate interests in managing our business efficiently, in understanding how users use the Website, in exercising our legal rights, and in keeping our records accurate and up to date.

Your Email Address

In addition, we may use your email address to contact you for customer service purposes, to inform you of important changes or additions to the Website or the services offered over the Website, to send you administrative notices and other information about the Website, and to tell you about other products or services offered by NLI, or other companies, that we think may be of interest to you.  We will use your personal information to send these messages to meet our legitimate interests in sending information to our customers. Where required by law, we will only send you these messages and any newsletters when you have chosen to subscribe to receive them.   Although we hope you’ll find these communications informative and useful, if you don’t, you can always unsubscribe to either type of message by following the simple instructions included in each email.

Except as stated above, the Website currently does not respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Statement. For more information about do not track, visit

Disclosure to Third Parties

We may also share the information, your personal information or otherwise, that is collected through the Website with our third-party service providers, including, but not limited to, service providers that provide services related to Website administration and operation.  In some cases, we may permit our third-party service providers to collect such information directly, on our behalf.  For example, the Website may use third-party web analytics services to help analyze how users use the Website.  These services may use cookies and pixel tags to collect information directly from the Website on our behalf, and then use that information to provide us with statistical reports on website activity.  We also may share your email address and name with third-party email service providers that send newsletters and other communications on our behalf. These service providers will act only on our instructions and on our behalf, and we remain directly responsible to you for the actions of these service providers.

We also may disclose information about our visitors and registered users if required to do so by law, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations, or if, in our judgment, such disclosure is reasonably necessary (a) to protect our rights, the integrity of the Website, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Visitor Agreement, violations of law, or other misuse of the Website. Finally, we may disclose information about visitors and registered users to third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets, and/or as part of the assets transferred in the event of a merger, acquisition, or asset sale. We may share this information to meet our legitimate interests in running our business and complying with legal obligations to which we are subject.

Interacting with the Website

You may interact with content on the Website through social media plugins provided by third party social media services.  We do not control the information that these companies collect when you use these tools, nor do we control how they use any information they collect.  We encourage you to review their privacy policies before interacting with the Website through these tools.

Please keep in mind that whenever you make your personal information or other information available for viewing by other users online – whether in comments posted to the Website, or in other public posting areas of the Website – that information can be seen, collected, and used by anyone with access to the Internet; we are not able to control how they may use this information.  We cannot be responsible for any use of such information by third parties.

Your rights over your personal information

Under the laws of some countries, you may have certain rights regarding the personal information about you. These may include the rights to:

  • access your personal information;
  • rectify the personal information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate.

Please note that we will likely require additional information from you in order to honor your requests.

If you would like to discuss or exercise such rights if applicable to you, please contact us  at NLIPRIVACY@NEW-LEVANT.ORG.

Storage of Information

The information that we collect through the Website is stored within databases that we control (or databases hosted on our behalf) on servers maintained within the United States, France, or Switzerland.  If you are not located there, the United States may not provide the same level of legal protection for your personal information as your home country, and such information may be available to the United States government or its agencies under a lawful order made in the United States.  In addition, we may transfer your information to our affiliates, business partners, and service providers located in other countries.  By using the Website, you acknowledge and agree to such transfer to, and processing in, the United States and these other countries. Those transfers are necessary to carry out the terms of our Visitor Agreement and this Privacy Statement. Where necessary and where consent to transfers is not sufficient, we have put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us using the email address above.

We will retain personal information about you for at least as long as you are a subscriber and for additional periods of time for our legitimate interests in operating our business. When determining how long to retain this information after you stop being a subscriber, or if you are not a subscriber, we will take into account our legal obligations and regulators’ expectations.  We may also retain records to investigate or defend potential legal claims.

Security of Information

We maintain administrative, technical, and physical safeguards designed to safeguard the information collected through the Website.  For example, any credit card information you provide on the Website is secured for transmission over the Internet using industry-standard secure sockets layer (SSL) encryption.  However, no physical or electronic security system is impenetrable.  We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us or our third-party service providers over networks that we do not control, including the Internet and wireless networks.

Changes to this privacy statement

The web is an evolving medium.  If we need to change this Privacy Statement in the future, we will post the revised Privacy Statement on the Website and update the “Effective Date,” above, to reflect the date of the changes.  By continuing to use the Website after we post such changes, you agree to the terms of this Privacy Statement, as modified.

We are using cookies on our website

The web site uses cookies to track your browsing behavior in order to deliver our services to you. Detailed information, including the right to withdraw consent can be found in our Privacy Policy. By using our site, you agree to these terms.