About this Policy

1. 1. This policy explains when and why we collect personal information about our members and instructors, how we use it and keep it secure, and your rights in relation to it.
   2. We may collect, use and store your personal data as described in this Data Privacy Policy and as described when we collect data from you.
   3. We reserve the right to change this Data Privacy Policy from time to time without prior notice. we may be required to change this Data Privacy Policy due to regulations. For any significant changes, you will be notified, but you are advised to check our website for the latest Privacy Policy.
   4. We will always comply with the General Data Protection Regulation (GDPR) when we handle your personal data. For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
   5. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website allows us to use cookies each time you visit our website.

Who are we?

We are WPexperts. We can be reached at Saukonkuja 5, 10620, Tammisaari – Finland, contacto@wpexperts.pt and +358 45 78337530].

Collection of personal information.

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

1. information about your computer including your IP address, geographical location, browser type and version, and operating system;
2. information about your visits to and use of this web site, including the referral source, duration of visit, page views, and navigation paths of the web site;
3. information, such as your e-mail address, that you enter when you register on our site;
4. information that you enter when you create a profile on our website – for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
5. information, such as your name and e-mail address, that you enter in order to establish subscriptions to our e-mails and/or newsletters;
6. information that you enter while using our web site services;
7. information that is generated during the use of our web site, including when, how often and under what circumstances you use it;
8. information related to anything you buy, services you use, or transactions you make through our website, which includes your name, address, telephone number, e-mail address, and credit card details;
9. information that you post on our web site with the intention of publishing it on the Internet, which includes your username, profile pictures, and the content of your messages;
10. information contained in any communications you send to us by electronic mail or through our website, including your communication content and metadata;
11. any other personal information you send us.

Before disclosing another person’s personal information to us, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

Use of your personal information

Personal information submitted to us through our web site will be used for the purposes specified in this policy or on the relevant web site pages. We may use your personal information for the following purposes:

1. managing our website and our business;
2. customizing our website for you;
3. allowing you to use the services available on our website;
4. sending you goods purchased through our website;
5. providing services purchased through our website;
6. send you statements, invoices and payment reminders, and collect payments from you;
7. send you non-marketing commercial communications;
8. sending you e-mail notifications that you have specifically requested;
9. send you our electronic newsletter, if you have requested it (you can inform us at any time if you no longer need the newsletter);
10. send you marketing communications relating to our business or the businesses of carefully selected third parties that we think may be of interest to you, by mail or, where you have specifically agreed to this, by electronic mail or similar technology (you can inform us at any time if you no longer require marketing communications);
11. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
12. handle questions and complaints made by or about you in connection with our web site;
13. keep our website secure and prevent fraud;
14. verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent via our website private messaging service);

If you submit personal information for publication on our website, we will publish and use that information in accordance with the license you grant us.

Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website.

We will not, without your express consent, provide your personal information to third parties for their direct marketing or that of any other third party.

Disclosure of personal information

We may disclose your personal information to any of our employees, agents, insurers, professional advisors, agents, suppliers or subcontractors as reasonably necessary for the purposes set forth in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all of its affiliates) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

1. to the extent that we are required to do so by law;
2. in connection with any ongoing or prospective legal proceedings;
3. in order to establish, exercise or defend our legal rights (including providing information to third parties for the purpose of fraud prevention and credit risk reduction);
4. to the buyer (or potential buyer) of any business or asset that we are (or are considering) selling; and
5. to any person who, in our reasonable opinion, could request a court or other competent authority to disclose such personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order the disclosure of such personal information.

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

International Data Transfers

• The information we collect may be stored, processed and transferred between any of the countries in which we operate in order to allow us to use the information in accordance with this policy.
• The information we collect may be transferred to the following countries that do not have data protection laws equivalent to those in force in the European Economic Area: United States of America, Russia, Japan, China, and India.
• Personal information that you post on our Web site or submit for posting on our Web site may be available via the Internet worldwide. We cannot prevent the use or misuse of such information by third parties.
• You expressly agree to the transfers of personal information described in this section 6.

Retention of personal information

• This Section 7 sets forth our data retention policies and procedures, which are designed to help ensure compliance with our legal obligations regarding the retention and disposal of personal information.
• Personal information that we process for any purpose or purposes should not be kept longer than is necessary for that purpose or purposes.
• Subject to Article 7.2, we will normally delete personal data falling into the categories set out below on the date/time set out below:
  • type of personal data will be deleted on December 31 at 1pm; and
  • January 15 at 1 pm.
• Notwithstanding the other provisions of this section 7, we will retain documents (including electronic documents) that contain personal data:
  • to the extent that we are required to do so by law;
  • if we consider that the documents may be relevant to any ongoing or prospective legal proceedings; and
  • in order to establish, exercise or defend our legal rights (including providing information to third parties for the purpose of fraud prevention and credit risk reduction).

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 the personal information you provide us on our secure (password- and firewall-protected) servers.
• All electronic financial transactions conducted through our website will be protected by encryption technology.
• It recognizes that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.
• You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password (except when you log on to our website).

Changes

We may update this policy from time to time by posting a new version on our website. You should check this page occasionally to ensure that you understand any changes to this policy. We may notify you of changes to this policy by e-mail or through the private messaging system on our website.

Third-Party Sites

Our website includes links to, and details of, third-party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

We use Google reCAPTCHA for spam protection. Their privacy policy can be found here : https://policies.google.com/privacy?hl=en

Information update

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

Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until the established expiration date unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.

Cookies do not normally contain any information that personally identifies a user, but the personal information we store about you can be linked to the information stored in and obtained from cookies. We use both session and persistent cookies on our website.

1. The names of the cookies we use on our website, and the purposes for which they are used, are set out below:
   1. we use Google Analytics and Adwords on our website to recognize a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the usability of the website / analyze the use of the website / administer the website / prevent fraud and improve the security of the website / customize the website for each user / target ads that may be of particular interest to specific users;
2. Most browsers allow you to refuse to accept cookies – for example:
   1. in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy”, and then “Advanced”;
   2. in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unchecking “Accept cookies from sites”; and
   3. in Chrome (version 29), you can block all cookies by going to the “Customize and control” menu, and clicking on “Settings”, “Show advanced settings”, and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, you will not be able to use all the features of our website.

• You can delete cookies already stored on your computer – for example:
  • in Internet Explorer (version 10), you must manually delete the cookie files (you can find instructions for doing this at http://support.microsoft.com/kb/278835 );
  • in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, and “Privacy”, then selecting “Use custom settings for history”, clicking “Show cookies”, and then clicking “Remove all cookies”; and
  • in Chrome (version 29), you can delete all cookies by going to the “Customize and control” menu, and clicking “Settings”, “Show advanced settings”, and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
• Deleting cookies will have a negative impact on the usability of many web sites.

Your rights

You may instruct us to provide you with any personal information we have about you; the provision of such information will be subject to the following:

1. the provision of adequate proof of your identity for this purpose, we will generally accept a photocopy of your passport certified by a notary public, plus an original copy of a utility bill showing your current address.
2. to access your personal data
3. be informed about how your personal data is processed
4. to have your personal data corrected
5. to have your personal data deleted under certain circumstances
6. to object to or restrict how your personal data are processed
7. to have your personal data transferred to yourself or to another company under certain circumstances.

We may retain personal information you request to the extent permitted by law.

You can instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will give you the opportunity to opt-out of the use of your personal information for marketing purposes.

Data Protection Ombudsman’s Office.
O. Box 315
FIN-00181 Helsinki
Tel. +358 10 3666 700
Fax +358 10 3666 735
e-mail: tietosuoja@om.fi
Website: http://www.tietosuoja.fi/en/

Article 29 WP Member: Sr. Reijo AARNIO, Finnish Data Protection Authority Ombudsman

Art 29 WP Alternate Member: Sra. Elisa KUMPULAHead of Department

For further details, please direct any questions, comments, and requests regarding our data processing practices to our André Luiz Ribeiro Naback Lopes at andre@wpexperts.pt.