SPEAK - Privacy and Cookies Policy

Privacy and Cookies Policy

Updated: September 2020

1 - Personal data collection and processing

2 - Personal data processing

3 - Personal data disclosure

4 - User Rights

5 - Personal data retention

6 - Cookies

7 - Security

8 - Claims

9 - Questions

10 - Changes to Personal Data Processing Terms

11 - List of cookies we use

We are committed to protect our users’ privacy and data security - you can learn more about how we use your information in our Privacy and cookies policy below. Please note that the provision of personal data for navigation in our website is subject to express knowledge and acceptance of this Privacy and Cookies Policy. On its own, the visit to this website does not imply an automatic registration of any form of personal data that identifies the user. However, the use of certain content or services, specifically the application process, may require the user’s personal data.

This Privacy and Cookies Policy (hereinafter “the” or “this” “Policy”) regulates the processing of personal data belonging to users (hereinafter "User" or "Users" or “You”) collected from the SPEAK website (hereinafter "Website") by SHARE YOUR WORLD, LDA (hereinafter “SYW” or “We”) and reflects the latter's institutional commitment and diligences towards the privacy and processing of Users' personal data within the context of the SPEAK project (hereinafter "SPEAK").
The provision of personal data for navigation in the Website is subject to express knowledge and acceptance of this Privacy and Cookies Policy. On its own, the visit to this website does not imply an automatic registration of any form of personal data that identifies the User. However, the use of certain content or services, specifically the application process, may require the user’s personal data.
This Policy is part of the Terms of Use of the website http://www.speak.social/en/ and regulates the possible collection and treatment of personal data submitted by the Users in any part of the website as well as the definition of their rights regarding this data, in accordance with the terms defined by the applicable Personal Data Protection laws and regulations.

1 - Personal data collection and processing

1.1. SYW as a data controller

SYW is responsible for the processing of personal data belonging to Users and may process such data directly and/or through entities subcontracted for this purpose. Personal data collected from the Website will be processed in the terms described herein for the purpose of management of language learning programs and related activities organized by SYW in the context of the SPEAK project.

From time to time, SYW may use the submitted data to supply information that it deems relevant, being always possible for the User to cancel this kind of information. Said personal data will also be used to comply with SYW’s legal and regulatory obligations (including, for example, compliance with its obligations regarding money laundering).

1.2. Use of the Website

Website access and navigation in general does not necessarily require the provision of personal data.

However, the use of certain features of the Website requires the creation of an account and the provision of personal data (for example, Users’ registration as a SPEAK Buddy). In these cases, users will only have access to the functionalities, products and services in question after providing the necessary personal data, which will be processed exclusively in accordance with and for the purposes described herein.

1.3. Personal data

SYW collects personal data processed for the purpose of creating and managing the SPEAK account. Personal data must be supplied for this purpose, otherwise it will not be possible to complete the registration process. Data collected by SYW upon registration include the user's name, e-mail, password and city. SYW will also collect additional data in order to complete the SPEAK language group application (namely, date of birth, gender, additional contact details, and nationality) and optional data to issue the application invoice (billing country, address, and VAT number).

Users who are not registered in the SPEAK account will be able to (i) navigate the Website, view and download available content (ii) subscribe SPEAK’s newsletter, (iii) inform the SPEAK team about the languages they would like to learn, (iv) contact the team through the help center, and (v) book a call with the team.

1.4. Purchase data

Through the Website and upon your explicit consent, SYW will process personal data necessary for managing purchases made from the Website (for example, completing the payment of language groups applications) and for fulfilling the legal obligations applicable in this context. This personal data refers essentially to the name, e-mail address, telephone number, address, VAT number (only if you want it on the invoice) and your city of departure (in case of SPEAK events). Information collected will also be processed by SYW in order to establish a purchase history for each User and to attribute benefits, discounts and promotions.

1.5. Profile data

Based on personal data collected and with your explicit consent, SYW may process such data for the purpose of profiling and designing cultural, promotional and institutional communications specifically suited to your interests and preferences.

Your profile will be created based on information provided through your navigating experience, information made available through the Website and other databases to which SYW has access, for the purposes of marketing, institutional communications and presentation of new products, services and initiatives.

2 - Personal data processing

2.1. SYW processes personal data for the purposes of completing registration on the Website and for managing and using the features available therein, such as processing purchases made by Users, responding to requests for contact or applications, processing applications for language groups or registration I SPEAK events, and for preparing statistics on how the SYW can improve the level of its services.

2.2. Upon your express consent, your data may also be processed for sending newsletters and institutional information, as well as information on promotions and direct marketing of events, artistic, cultural, educational and scientific activities, solidarity campaigns and other SYW initiatives through automated SMS and e-maiIs and by telephone.

2.3. You may withdraw your consent to data processing for the purposes indicated in the previous paragraph at any time. If you do so, data will no longer be processed for this purpose, although this does not affect the validity of the data processing previously carried out based on your consent.

3 - Personal data disclosure

3.1. SYW may forward your data to data processors for the purposes mentioned above, pursuant to an agreement signed with said entities.

3.2. In compliance with its legal obligations and to conclude the operations carried out through the Website, or on the basis of the consent provided for this purpose, SYW may also forward your data to third parties, namely: (i) other SYW projects or entities, (ii) partners, sponsors or other entities with whom SYW establishes similar relationships, (iii) financial/payment institutions; (iv) competent entities, in accordance with the law.

4 - User Rights

4.1. In accordance with applicable law, you may, at any time, request access to your personal data, its rectification, elimination or limited processing, portability, or opposition to its processing (in the specific case of creating profiles and, as applicable, requesting clarification of the criteria used and/or opposing the creation of the profile). You may exercise these rights directly by sending an e-mail or by writing to SYW, to the contact details provided in point 9 below.

4.2. You may also obtain confirmation that your personal data and access requests to the latter are processed. A copy of data being processed may be supplied to you at your request.

4.3. Pursuant to the law, you have the right to withdraw your consent to processing data for the purposes indicated through the contact details provided.

4.4. Pursuant to the law, you also have the right to withdraw your consent at any time, although this does not affect the validity of the data processing previously carried out based on your consent.

4.5. You also have the right, under the applicable law, to request limited processing or portability of your data, subject to the legally established conditions. You should therefore send a request using the contact details mentioned in 4.1.

5 - Personal data retention

5.1. Personal data necessary for registration purposes will be kept for as long as you wish to keep your SPEAK account.

5.2. Other personal data collected through the Website will be kept until the SYW has provided the relevant services, products and information, in order to facilitate purchase/payment processes and information requested by Users. Data collected for the purpose of sending newsletters and other institutional and marketing communications regarding SYW will be kept for as long as you consent to this. Once you have withdrawn your consent and/or checked the option to "unsubscribe" in any of our communications, your personal data will be deleted.

6 - Cookies

6.1. SYW uses its own and third-party cookies to collect and retain information, so as to provide a more personalized service that meets Users' expectations. We believe in being clear and open about how we collect and use data related to you. In the spirit of transparency, this Policy includes detailed information about how and when we use cookies.

6.2. A cookie is a small text file that is sent to your browser and stored on your computer's hard drive or on a tablet or mobile device. We use cookies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status from a previous use of our site, for when you later return to our site, to identify the web browser on the server, store information aimed at improving user experience, and analyze and review Website performance.

6.3. Cookies may be classified into two groups: session or persistent. Session cookies expire automatically when you close your web browser. Persistent cookies remain in your web browser until they expire or are eliminated. Expiry dates vary according to the nature and purpose of each cookie, as per the information available through our list of cookies.

6.4. Cookies mentioned in our list of cookies have the following categories/types and will be used by SYW strictly for the following purposes:

Category/Type	Description
a) Strictly Necessary Cookies/Essential cookies	These cookies are essential to provide you with services available through our Website and to enable you to use its features. Without these cookies the site will not perform, thus we may not be able to provide Website’s services or features. These typically include session and security cookies. These cookies do not depend on your consent, thus will be turned on by default. However, we will notify you that we are using them immediately as you enter the Website.
b) First-party Analytics and Performance Cookies	These cookies collect information about the use of the Website to improve the services provided and to evaluate its performance. Cookies may be used to test pages or features by measuring the reaction of users. The information gathered does not identify any individual visitor since it is aggregated and therefore anonymous and it is only used to improve how our Website works. These cookies do not depend on your consent, thus will be turned on by default. However, we will notify you that we are using them immediately as you enter the Website.
c) Third-Party Analytics and Performance Cookies	Analytics/Performance cookies used on the Website belonging to third parties. These cookies are used to collect information about traffic to our site and how users use our Website. This information is used by third parties. Therefore, these cookies require your consent and will be turned off by default.
d) Preference cookies	These cookies allow our Website to remember choices you make when you use our site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our site. These cookies require your consent, thus will be turned off by default.
e) Marketing, Advertising and Social Media Cookies	Marketing, Advertising and Social Media cookies are third-party cookies that allow connection to social networks and share multimedia content from our Website on those networks. Some of these cookies help us adjust advertising outside our website to the interests of users. By disabling these cookies our content will no longer be directly shared in any social network. These cookies require your consent, thus will be turned off by default.

6.5. Each User is linked to an individual cookie, which ensures data privacy and security. Statistical data is presented in aggregate form, not individually, and does not enable User identification. It is therefore possible to evaluate the performance of the Website, towards its constant improvement, to meet the User's needs and expectations.

6.6. Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of sites to set cookies, you may worsen your overall user experience and it may also stop you from saving customized settings. You can configure browser settings to accept all cookies, know when a cookie is set or never receive cookies. You can deactivate the cookies function through the web browser at any time, usually in the "Preferences" or "Tools" menu. See the "Help" menu for further details on configuration in your web browser.

6.7. Browser manufacturers provide help pages relating to cookie management in their products. Please see the following pages for more information (please select the browser you are using): Google Chrome; Internet Explorer; Mozilla Firefox; Safari (Desktop); Safari (Mobile); Android Browser; Opera Mobile; Opera.

6.8. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org, or www.aboutcookies.org.

6.9. Please note that by completely turning cookies off, some/all features of the Website may no longer be available.

6.10. For further details on cookies used on the Website, please see our list of cookies.

7- Security

7.1. SYW guarantees the privacy and security in the transmission of User data using Secure Sockets Layer (SSL) encryption of all information exchanged within the Website.

7.2. SYW will do everything in its power to protect the personal data of the Users against non-authorized access through the Internet. To that end, it uses security systems, rules and other procedures to guarantee the protection of personal data as well as preventing unauthorized access to the data and its improper use, disclosure, loss or destruction.

7.3. However, note that it is your responsibility to ensure that the computer that you are using is properly protected against malware, computer viruses and worms. Additionally, note that whenever the submission of data is done in open networks as the Internet, your data may circulate freely without proper security conditions, with the risk of being viewed and used by non-authorized third parties

8 - Claims

Without prejudice to any other administrative or judicial action, Users have the right to submit a complaint to the National Data Protection Commission or other competent control authority in accordance with the law, should they consider that the processing of their data by SYW at any time breaches the applicable legal framework.

9 - Questions

If you have any questions related to the processing of your personal data and the exercise of the rights conferred to you by the applicable law and, in particular, referred to in this Policy, please contact us through the following means:

E-mail: info@speak.social;

Address: SPEAK – SHARE YOUR WORLD, Casa do Impacto, Travessa São Pedro nº 8, 1200-432, Lisboa.

10 - Changes to Personal Data Processing Terms

SYW reserves the right to, at any given time and without prior notice and with immediate effects, alter, add or amend the present Privacy Policy, in which event said changes will be immediately disclosed in this online page. Please take a look at the last revised date at the top and bottom of this page to see when this Policy was last revised.

11 - List of cookies we use

The following table sets out details of the individual cookies we use on our site, as well as the privacy policies of cookies from third-parties:

Name	Description	Duration	Privacy Policy
__cfduid	Used by the content network, Cloud flare, to identify trusted web traffic.	1 year	https://policies.google.com/technologies/cookies?
_ga	Registers a unique ID that is used to generate statistical data on how the visitor uses the web site.	2 years	https://policies.google.com/technologies/cookies?
_gat	Used by Google Analytics to throttle request rate	1 day	https://policies.google.com/technologies/cookies?
_gid	Registers a unique ID that is used to generate statistical data on how the visitor uses the web site.	1 day	https://policies.google.com/technologies/cookies?
_hjid	Sets a unique ID for the session . Th is allow s the web site to obtain data on visitor behaviour for statistical purposes.	1year	https://policies.google.com/technologies/cookies?
uuid	This cookie is used to optimize ad relevance by collecting visitor data from multiple web sites – this exchange of visitor data is normally provided by a third -party data-center or ad -exchange.	1 year	https://policies.google.com/privacy
ZD-suid	Unique id that identifies the user's session.	persistent	https://policies.google.com/technologies/cookies?
ZD-store	Registers whether the self-service-assistant Zendesk Answer Bot has been displayed to the web site user.	persistent	https://policies.google.com/technologies/cookies?
__utm.gif	Google Analytics Tracking Code that logs details about the visitor's browser and computer.	session	https://policies.google.com/technologies/cookies?
__utma	Collects data on the number of times a user has visited the website as well as dates for the first and most recent visit. Used by Google Analytics.	2 years	https://policies.google.com/technologies/cookies?
__utmb	Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the duration of a website visit.	1 day	https://policies.google.com/technologies/cookies?
__utmc	Registers a timestamp with the exact time of when the user leaves the website. Used by Google Analytics to calculate the duration of a website visit.	session	https://policies.google.com/technologies/cookies?
__utmt	Used to throttle the speed of requests to the server.	1 day	https://policies.google.com/technologies/cookies?
__utmz	Collects data on where the user came from, what search engine was used , what link was clicked and what search term was used . Used by Google Analytics.	6 months	https://policies.google.com/technologies/cookies?
collect	Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.	session	https://policies.google.com/technologies/cookies?
ZD-buid	Unique id that identifies the user on recurring visits.	persistent	https://support.zendesk.com/hc/en-us/articles/360
ZD-currentTime	Registers the date and time for the user's latest visit to the website.	session	https://support.zendesk.com/hc/en-us/articles/360
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.	1 day	https://www.facebook.com/policy/cookies/
_hjIncludedInSample	Determines if the user's navigation should be registered in a certain statistical placeholder.	session	https://help.hotjar.com/hc/en-us/articles/1150117
Users.sid	Used in conjunction with the Session Id cookie in order to prevent session fixation vulnerabilities.	session	https://success.outsystems.com/Support/Enterprise
Users	Used by the Remember Login functionality in applications.	10 days	https://success.outsystems.com/Support/Enterprise
googtrans	Saves language preferences	session	https://policies.google.com/privacy
UULE	UULE code is an encoded geographic location	1 day	https://policies.google.com/privacy
HSID	This cookie is set by DoubleClick (which is owned by Google) to build a profile of the website visitor's interests and show relevant ads on other sites.	2 years	https://policies.google.com/technologies/cookies?
SAPISID	We embed videos from our official YouTube channel. This may set cookies on your browser for the best video experience.	2 years	https://developers.google.com/youtube/terms/requi