{"id":50474,"date":"2024-10-07T19:38:38","date_gmt":"2024-10-07T19:38:38","guid":{"rendered":"https:\/\/fluency.io\/?page_id=50474"},"modified":"2024-10-07T19:38:38","modified_gmt":"2024-10-07T19:38:38","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/fluency.io\/privacy-policy\/","title":{"rendered":"Fluency Academy’s Personal Data Collection and Processing Policy (‘Privacy Policy’)"},"content":{"rendered":"

Rules for the relationship between Fluency Academy and personal data holders<\/strong><\/p>\n

This Personal Data Collection and Processing Policy (“Personal Data Policy” or “Privacy Policy”) sets forth rules and procedures that must be followed by partners, employees, and service providers who collect or process personal data on behalf of Fluency Academy Ensino de Idiomas Ltda. (\u201cFluency\u201d or \u201cOrganization\u201d). The provisions contained herein establish standards of conduct and transparency and bind all individuals or entities that collect or process personal data controlled by Fluency.<\/p>\n

This Personal Data Policy must be observed in accordance with Law No. 13.709, of August 14, 2018, the General Data Protection Law (“LGPD”). Where applicable and relevant, it will also follow the general principles and rules of Law No. 12.965, of April 23, 2014, the Brazilian Internet Civil Framework, Decree-Law No. 5.452, of May 1, 1943, the Consolidation of Labor Laws (“CLT”), applicable labor and social security regulations, Law No. 5.172, of October 25, 1966, the National Tax Code (“CTN”), applicable tax and fiscal regulations, and Law No. 8.069, of July 13, 1990, the Statute of Children and Adolescents (“ECA”). The rules contained herein must also be observed in compliance with Fluency Academy’s Articles of Association.<\/p>\n

Fluency only processes personal data to achieve legitimate, specific, and informed purposes to the data subject, in accordance with this Privacy Policy. The Organization values compatibility in processing with the purposes informed and collects only the minimum necessary to achieve its social objectives. Fluency does not process personal data for discriminatory, unlawful, or abusive purposes. The Organization will use its best efforts to maintain transparency in its relationship with personal data holders under its control, providing clear, precise, and accessible information to the holders. Fluency adopts preventive technical and administrative measures that, in the Organization’s understanding, are capable of protecting personal data from unauthorized access and from accidental or unlawful situations, in order to avoid damage resulting from the processing of personal data.<\/p>\n

This Privacy Policy consists of four sections: 1) Scope and Definitions; 2) Nature of Collected Personal Data and Processing Purposes; 3) Rights of Personal Data Holders; and 4) Information Security.<\/p>\n

First Section<\/h3>\n

1. Scope and Definitions<\/h4>\n

1.1 Personal Data: All information related to an identified or identifiable natural person and that is subject to collection or processing by Fluency or by an entity or person acting under its express instructions.
\n1.2 Personal Data Holder: A natural person to whom the personal data being processed by Fluency relates.
\n1.3 Interested Parties: Personal data holders whose data is processed by Fluency and who may belong to one of the following profiles:<\/p>\n