Effective date: April 19, 2018
Instead of overwhelming you with a bunch of vague, legal jargon, we’ve tried to make this page as easy-to-read as possible (by actual humans!) Our goal with this page is to provide more transparency about how your data is used when you entrust us with it.
While this policy was written to conform with the new European GDPR laws, we’re extending it to everyone who uses our site. We’re glad these laws exist, because they’re all about providing consumers with more transparency about how personal data is collected, stored and used online.
Introduction
Remember: If the service doesn’t offer paid services or products, it likely means you are the product. (Eg. You don’t pay for Facebook, so they charge advertisers to show you ads).
Our business model is simple: Members pay a small fee to access podcast transcriptions, the Learning Studio, and other content that supports European Portuguese learners around the world. The little bit of personal data we need to collect is for the sole purpose of providing these services, and making them better over time.
We don’t sell ads, and especially don’t sell or share your data with advertisers or other marketing companies… no shenanigans!
Many users often don’t realize that even with a simple business models like ours, we do need to rely on third-party services (that we administrate), to securely process payments, store and organize your data, send out our email newsletters etc.
If you have any concerns, or are simply curious to have us elaborate on any of the points below, please get in touch. We believe strongly in the importance of these GDPR principles and want to do a good job following them – so your feedback is always appreciated.
Privacy Policy
Practice Portuguese LDA (“us”, “we”, or “our”) operates the http://www.practiceportuguese.com website (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http://www.practiceportuguese.com/terms-conditions/
Definitions
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on a User’s device.
Data Controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your data.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee or founder of the Data Controller) who processes the data on behalf of the Data Controller.
We use the services of various Service Providers in order to process your data more effectively.
Data Subject
Data Subject is any living individual who is the subject of Personal Data.
User
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.
Usage Data
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- When a user signs up to our mailing list or subscribes as a paying member, we use a cookie to ensure they aren’t asked again multiple times as they continue exploring our site.
- Some plugins on our website may use cookies to remember your preferences for your own convenience, such as keeping your place when filtering through posts on our site, or keeping you logged in if you have an account.
Use of Data
Practice Portuguese LDA uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Retention of Data
Since we frequently have members who resubscribe years after canceling a subscription, or sign-up as a member for the first time years after their first interaction with our site, we intend to keep personal user data for up to 10 years after their last interaction with us.
That way, if a member resubscribes, they can continue where they left off. If a user contacts us again, we’ll be able to refer to previous conversations with them or see their progress throughout their site (if they were a member) to add context to the conversation.
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Portugal and choose to provide information to us, please note that we transfer the data, including Personal Data, to Portugal and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Practice Portuguese LDA will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
Disclosure Of Data
Legal Requirements
Practice Portuguese LDA may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Practice Portuguese LDA
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that while we do everything possible to keep your Personal Data safe at all times, no method of transmission over the Internet, or method of electronic storage can be 100% secure.
“Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Rights
Practice Portuguese LDA aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
You have the right:
- To access and receive a copy of the Personal Data we hold about you
- To rectify any Personal Data held about you that is inaccurate
- To request the deletion of Personal Data held about you
You have the right to data portability for the information you provide to Practice Portuguese LDA. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Our understanding of the EU’s GDPR law is that we would have up to 40 days to gather this information and send it in response to your request; however, we’ll likely get back to you much sooner.
Please note that we may ask you to verify your identity before responding to such requests.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Communication
- HelpScout – This is the CRM / help ticket software that integrates with the forms on our site, allowing us to manage customer communication and provide support. Privacy policy: https://www.helpscout.net/company/privacy/
- MailChimp – used for communicating updates about our site and services to all of users who have chosen to opt-into our list. Privacy policy: https://mailchimp.com/legal/privacy/
- Gmail – when a user subscribes or fills out a form on our site, a copy of those details are sent to a Gmail account for the purposes of notifying the owners (Rui Coimbra & Joel Rendall) of activity on the site. Privacy policy: https://policies.google.com/privacy
Backups & Storage
- Dropbox – We use a Dropbox Business account to securely store backups of our website’s database (which includes user data as well). Privacy policy: https://www.dropbox.com/privacy
Analytics
We use the following third-party Service Provider to monitor and analyze the use of our Service.
- Google Analytics – a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Payments
We provide paid products and/or services within the Service. We use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
For internal accounting and customer support, we use the following payment-relate services:
- ChargeDesk – this service aggregates PayPal and Stripe payment history into one place, which allows us to assist customers with their billing-related customer inquires from inside HelpScout. Their Privacy Policy can be viewed here: https://chargedesk.com/privacy-policy
- Stunning.co – this service connects to Stripe and sends automatic email reminders when a payment method is failing or about to expire. From those emails, a member can update their credit card, with the information being sent directly to Stripe via Stripe’s API. Their Privacy Policy can be viewed here: https://stunning.co/privacy-policy
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Testimonials / Reviews
When users reach out to us with positive feedback, we’ll occasionally share a snippet of that message on our “Reviews” page.
The testimonial may also include your general location (City, State, or Country), and/or through which channel the message was sent (Facebook, Email, YouTube etc).
Only the first name and/or initials are included, and additional identifying details in the message are removed.
Changes To This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: help@practiceportuguese.com
- By visiting this page on our website: http://www.practiceportuguese.com/contact/
