PRIVACY POLICY
1. IDENTIFICATION OF THE ENTITY RESPONSIBLE FOR PROCESSING PERSONAL DATA (DATA CONTROLLER) AND SCOPE OF APPLICATION
1.1. Unlock Education, Lda, with tax identification no. 516552759 and registered office at Rua Neves Ferreira, No. 13B, 2, 1170-273 Lisbon (hereinafter referred to as UnlockEd) is the entity in charge of collecting and processing the personal data of the data subjects (hereinafter referred to as the User or Users) for the purposes indicated in Section 2 of this Privacy Policy.
1.2. This Privacy Policy is applicable to the processing of personal data collected by UnlockEd through the website https://www.milesinthesky.education (the "Website") and is intended to inform Users in accordance with Article 13 of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the "GDPR").
1.3. Users must read this Privacy Policy carefully and freely decide whether they wish to provide their personal data to UnlockEd, prior to sending it. Each User guarantees that he/she is of legal age and that the data provided is true, accurate, complete and up to date, being responsible for any non-compliance that may occur.
2. PERSONAL DATA COLLECTED, PURPOSES AND GROUNDS FOR PROCESSING
2.1. UnlockEd may collect the following personal data:
(a) Identification data: Name;
(b) Contact data: Email and telephone/mobile phone; and
(c) Cookies
2.2. Personal data collected by UnlockEd through the Website is processed exclusively for the following purpose: response and processing of contact or information requests (legitimate interest).
3. RETENTION PERIOD
3.1. UnlockEd shall retain Users' personal data for a period of 13 (thirteen) months from the data of collection or, in relation to the Cookies, for each period identified in Section 6.3. of this Privacy Policy.
3.2. Once the indicated period is reached and, unless UnlockEd has to retain the personal data under a legal or contractual obligation, UnlockEd will delete or anonymize the personal data.
4. USER’S RIGHTS
4.1. Users have the right to request, through the email info@milesinthesky.education, as applicable, access to their personal data; its rectification; its erasure; limitation of processing; opposition to processing; and the right to data portability. Users also have the right to lodge a complaint with the Supervisory Authority, which in Portugal is the Comissão Nacional de Proteção de Dados (https://www.cnpd.pt/).
4.2. When exercising any of the rights identified in the previous paragraph, the User must send a copy of a document proving his/her identity (avoiding, if possible, sending a copy of his/her citizen card), specifying the right or rights he/she wishes to exercise.
5. SECURITY
UnlockEd declares that it has implemented and will continue to implement technical and organisational security measures deemed as necessary to guarantee the security of the personal data that it processes in order to prevent its alteration, loss, processing and/or unauthorised access, taking into account the current state of technology, the nature of the data stored and the risks to which it is exposed.
6. COOKIES
6.1. Cookies are files or text files containing small amounts of information that may be downloaded to and stored on the website visitor’s device through the browser when visiting a website.
6.2. Cookies can be categorised according to its purposes. Some cookies are strictly necessary for the website to be operational, while others collect statistical information for the purpose of analysing the use of the website and its performance or are used to ensure the provision of additional functionalities to the website or to store the visitor's preferences regarding navigation on the website, whenever the visitor uses the same device. Other cookies may also be used to measure the success of applications and the effectiveness of third-party’s advertising.
6.3. Cookies that may be used when browsing our website:
www.milesinthesky.education
6.4. Information about each third-party identified above commitments on data protection can be found in the following links:
· Stripe
· Hotjar
6.5. Unlocked entered into relevant data processing agreements with Hotjar and Stripe in accordance with the applicable law and to ensure an adequate processing of User’s personal data if and when applicable.
6.6. User may revoke consent or modify preferences in terms of cookie management on the cookies page at any time. Alternatively, most browsers allow control over the cookies stored on the browsing devices, as well as their immediate deletion if the User wishes to stop allowing the local storage of cookies. Further information regarding cookies can be found on the following websites: www.aboutcookies.org or www.allaboutcookies.org.
6.7. Users can configure the devices and browsers used in order to accept/reject all or some cookies.
7. ADJUSTMENTS TO THE PRIVACY POLICY
UnlockEd reserves the right, at any time, to make adjustments or changes to this Privacy Policy, which shall be duly published on the Website.
Last Updated on: 06/07/2022
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