GENERAL CONDITIONS OF REGISTRATION AND ACCESS AND PRIVACY POLICY

A. The general conditions for enrolment and access (hereinafter the "Conditions") are agreed between Unlock Education, Lda., tax identification no. 516552759, with registered office at Rua Neves Ferreira, no. 13B, 2º, 1170-273 Lisboa, hereinafter referred to as "UnlockEd", and those persons wishing to enrol in any of the training courses organised by UnlockEd via the website http://www.milesinthesky.education/ (the "Platform"), hereinafter referred to as the "User".

B. UnlockEd and the User agree that any registration made through the Platform shall be governed exclusively by these Conditions, with the User declaring to acknowledge, accept and fully comply with.

1. Purpose

The purpose of the Conditions is to provide and define all the information required by Users regarding the methods of enrolment, payment and access to the courses organised by UnlockEd through the Platform.

2. Registration

2.1 Access to the training courses provided on the Platform can be obtained through registration, which is limited to the maximum number of registrations defined for each course.

2.2 Users may register through the process described below, after clicking on the respective button available on the Platform.

2.3 To make your registration, the User must:

• Register on the Platform or, if the User has a previous registration, use the login and password to access;
• Select the required training course;
• Proceed with the payment for the training course, if applicable, by choosing a payment method from those available;
• Complete the information requested and choose the options available throughout this process, if applicable.

2.4 The completion of the registration process by the User is equivalent to full and complete acceptance of the prices, content and description of the training course as it is presented on the Platform, as well as the general conditions of registration and access, which shall be the only ones applicable.

2.5 UnlockEd guarantees that all the registrations made through the Platform are secure.

2.6 If the User is a minor (under 18 years of age) the registration process must be supervised by the holder of parental responsibilities, and UnlockEd shall not be held responsible for any liability arising from any registration made in breach of the provisions of this paragraph.

3. Access

3.1 Registering for a course on the Platform gives the User access to all the materials of the respective course for the duration of the course, including a set of resources that may or may not be available for download, depending on what is defined for each particular course.

3.2 UnlockEd reserves the right to suspend access to the Platform, and consequently the training, should the User prove to have made undue or damaging use of the Platform.

4. Payment

4.1 Access to the training courses depends on the confirmation of payment, when applicable, and is only allowed from the starting date of the training course, as referred in the registration confirmation process and respective payment confirmation.

4.2 If a course requires payment, UnlockEd makes online payment methods, available to the User, namely through the use of credit cards (Visa and Mastercard) and, potentially, others that may be made available from time to time and clearly identified in the registration process.

4.3 Once the training course has been paid for, there will be no refunds, unless, for reasons attributable to UnlockEd, the training course does not take place on the scheduled date.

4.4 The withdrawal from a training course, after it has started, does not give the User the right to attend the same training in future editions, or another training that is or may become available for free.

5. Prices

5.1 Prices shall be in Euros (€), inclusive of taxes and duties, if nothing else is stated, or with taxes and duties clearly stated and communicated.

5.2 The prices shown in the registration process always correspond to the prices in force, including any discounts and special conditions that may be applicable.

6. Frequency of training

6.1 UnlockEd reserves the right to change trainers, content, dates and location of training courses, giving prior notice to the User.

6.2 The attendance of the trainings implies that the User:

• Complies with all the access criteria that may be defined, particularly in terms of age requirements or previous background, according to the information made available about the training course;
• Is proficient in the language in which the training course is given;
• Has access to a laptop computer and internet connection;
• Installed a browser on the laptop computer, preferably updated with the latest official version available.

6.3 The User is responsible for all costs associated with his/her laptop computer and internet connection, including any costs the he/she may incur in establishing and using an internet connection.

6.4 The training course sessions generally occur in asynchronous mode, but may be complemented by sessions in synchronous mode or in face-to-face mode, depending on the details that are announced in the program of each training course.

6.5 The User, during participation in synchronous sessions, can share his/her image and statements, either by sound capture, or by conversations on the platform (chat), whenever requested and through interaction during the sessions.

6.6 The face-to-face training sessions, if applicable, will take place at a date and place to be defined and previously informed by UnlockEd with the minimum advance notice indicated in the training program.

6.7 The User must respond to surveys and activities that are requested as part of the training course.

7. Evaluation and Certification

7.1 In case there is a final evaluation, UnlockEd will inform the User of the evaluation criteria underlying each training course and the respective weighting for the final evaluation.

7.2 The self-learning courses are autonomous, without mentoring, and the evaluation is done according to the principles of the Platform methodology, often using automatic evaluation formats. The User acknowledges and accepts that elements such as his/her participation in the Platform, results of any material submitted and interaction with other Users, will be used for his/her evaluation. 

7.3 Users who obtain a positive classification, in accordance with the criteria defined for each training course, are entitled to a certificate of participation, available for consultation or printing in their respective user area on the Platform.

8. Complaints

8.1 Users may submit their complaints to UnlockEd by post to the address above or electronically via email to info@milesinthesky.education.

8.2 In case of dispute, the User may resort to a consumer Alternative Dispute Resolution Entity (ADRE): Centro de Arbitragem de Conflitos de Consumo de Lisboa (CACCL), with headquarters at Rua dos Douradores, 116, 2.º, 1100-207 Lisboa or the Arbitration Centre of the Universidade Autónoma de Lisboa (CAUAL), with headquarters at Rua de Santa Marta, 43-E, 1.º C, 1150-293 Lisboa. For more information the User may consult the Consumer Portal available at www.consumidor.gov.pt.

8.3. The User may also use https://www.livroreclamacoes.pt.

9. Responsibility

The temporary transfer or definitive transfer to third parties, leasing, lending or any other similar activity or practice of the email address and password defined by the User to access the Platform is prohibited. The User is entirely responsible for the confidentiality of his/her data.

10. Maintenance and updates to the Platform

10.1 UnlockEd reserves the right to periodically carry out maintenance and updating tasks on the Platform to improve it, which may occasionally degrade or affect access to the Platform and cause it to be temporarily unavailable.

10.2 If the training is interrupted for reasons attributable to UnlockEd, UnlockEd undertakes to guarantee the conditions necessary to resume it as soon as possible.

10.3 If the User has been unable to complete the training for reasons attributable to UnlockEd then UnlockEd shall guarantee said User the right to priority access to training starting immediately after the end of the interruption.

11. Newsletters and other communications

11.1 UnlockEd may send newsletters with promotions, offers and information related to the training courses and to the Platform to the email address provided by the User when registering on the Platform.

11.2 It is UnlockEd understanding that there may be a legitimate interest in sending the aforementioned newsletters, given the relevant relationship formed with the registration and subscription to the training courses by the User, which may create an expectation on the part of the User to receive communications from UnlockEd related to the training courses and to the Platform.

11.3 The User can exercise his/her right to object through the option "If you no longer wish to receive this newsletter, you can edit your communication preferences here" available in every newsletter.

11.4 Within the scope of the training sessions, UnlockEd will send the User communications related to the training sessions in which they are enrolled, namely for the purposes of management and information on how the training sessions will operate, access to the training materials made available, instructions for the issue of certificates and the conclusion of the training course.

12. Applicable law and jurisdiction

The Conditions shall be governed and interpreted in accordance with Portuguese law. Should the User have his/her residence outside Portugal, he/she accepts the jurisdiction of the Portuguese Courts to settle any disputes arising from the interpretation or execution of the Conditions.

Document updated on 10/03/2022

PRIVACY POLICY

1. Identification of the data controller and scope of application

1.1 Unlock Education, Lda., tax identification no. 516552759 and registered office at Rua Neves Ferreira, no. 13B, 2.º, 1170-273 Lisboa (hereinafter referred to as UnlockEd) is the entity responsible for collecting and processing the personal data of the data subjects (hereinafter referred to as the User or Users) for the purposes indicated in point no. 2 of this Privacy Policy.

1.2 This Privacy Policy applies to all personal data collected by UnlockEd through the Platform 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 to provide their personal data to UnlockEd, prior to sending it. Users guarantee that they are of legal age and that the information provided is true, accurate, complete and up to date, and are 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:

• Identification data: Full name; nationality; personal identification document number; tax identification number;
• Contact details: Email and telephone/mobile phone number; address; 
• Image.

2.2 The personal data collected by UnlockEd is to be processed for the following purposes:

• Handling of applications to register for training courses organised by UnlockEd and advertised on the Platform (contractual obligation);
• Organization and promotion of events that will be held and that are related to the training courses (legitimate interest); and 
• Communication of news and relevant information about UnlockEd and about new training courses that it might organise (legitimate interest).

2.3 UnlockEd may also use personal data related to the Users’ performance in a course to obtain statistical reports and information regarding the Platform in order to improve the Platform’s content and Users’ experience. The personal data used for the referred purpose shall, at all times, be anonymized.

2.4 Under contractual obligations applicable to UnlockEd, UnlockEd may have to communicate data related to the Users’ performance to entities with whom the User has a direct relationship and which have an intervention on the course, namely, but not limited to, Universities or User’s employer, if applicable.

2.5 UnlockEd may also use data from the Users’ performance to grant Users discounts in additional UnlockEd’s programs in which the User chooses to enrol. 

3. Retention Period

3.1 UnlockEd shall store Users' personal data for the period of time necessary to fulfil the purposes for which it was collected.

3.2 Given the purposes identified above, UnlockEd will store personal data for as long as the User remains in any way related to UnlockEd (namely, but not limited to, while the User is enrolled in any of the courses organized by UnlockEd or has an active user area in the Platform).

3.3 At the end of the indicated period and unless UnlockEd is obliged to retain the Users' personal data for a specific period in order to comply with a legal or contractual obligation, UnlockEd shall delete or anonymise the personal data in accordance with the GDPR.

4. Users' Rights

4.1 Users have the right of access to personal data concerning them; right to rectification of the personal data; right to erasure of the personal data; right to restriction of processing; to object to the processing; and the right to data portability, under the terms of the GDPR, as applicable, and through the following email address: info@milesinthesky.education. 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 contacting UnlockEd, the User must send a copy of a document proving his/her identity (avoiding, if possible, sending a copy of his/her Portuguese citizen card, if applicable), specifying the right or rights he/she wishes to exercise.

5. Security

5.1 UnlockEd declares that it has implemented and will continue to implement the technical and organizational security measures required to guarantee the security of the personal data processed in order to prevent their alteration, loss, processing and/or unauthorized 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 are downloaded and stored on the User's device, via their browser, when they visit a website.

6.2 Cookies can be categorised according to its purposes. There are cookies that are strictly necessary for the website to function, while others collect statistical information in order to analyse the use of the website and its performance or are used to ensure that additional functionalities are made available to the website or to store the visitor's preferences regarding navigation on the website, whenever they use the same device. Other cookies may also be used to measure the success of applications and the effectiveness of third-party advertising.

6.3 UnlockEd does not collect personal data under the terms of the applicable law, namely the GDPR, through the cookies used on the Platform, as they do not directly or indirectly allow UnlockEd or any other entity to identify the User.

6.4 Users can always configure the devices and browsers they use to accept all or some cookies, to notify them whenever a cookie is issued, or to stop receiving cookies.

7. Changes to the Privacy Policy

UnlockEd reserves the right, at any time, to make adjustments or changes to the Privacy Policy, which will be duly published on the Platform.

Last updated on 10/03/2022