{"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 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. 2.1 According to this Privacy Policy and as per its Articles of Association, Fluency collects and processes personal data of Interested Parties as part of its efforts to achieve its social objectives. Sole Paragraph<\/strong>: To enable the execution of the actions described above, Fluency collects and processes personal data from the following types of information: first and last name, email, phone number, CPF (Brazilian taxpayer identification), date of birth, city, state, and country of origin, nationality, income, company or organization name, address, and credit card data linked to the individual, corporate email, motivation for learning a language, available study time, study history, study time, study location, course performance, such as completion of class schedules, units and stages, completion of additional activities, videos and audios played, social media profile, audio, image, and voice of session participants, location data, behavior of students and content producers and\/or service providers in the organization’s digital environments, such as clicks, traffic, downloads, connection type, mouse movement, survey responses, proficiency test results, course community comments, lesson evaluations, lesson comments, chat transcriptions, and more.<\/p>\n Single Paragraph:<\/strong> To enable the execution of the above activities, Fluency processes personal data based on the following information: first and last name, CPF, RG, CNH (Brazilian driver’s license), employment contract information such as PIS (Social Integration Program), CTPS (Work Card), education and professional qualifications, full address, social media profile, professional CV, professional history, phone number, job role, department, and employment start date, bank account details like bank name, branch, and account number, credit card details linked to an individual, health information necessary for employment contracts, payment information, and more.<\/p>\n Single Paragraph:<\/strong> To execute these activities, Fluency processes personal data such as social media profiles, email, first and last name, CPF, address, date of birth, city, state, and country of origin, nationality, cell phone, income, language learning history and duration, school attended, proficiency test results, cookies, pixels, and IP identification, payment method, personal data of the payer (if different from the student), motivation for taking a language course, information provided by the data subject regarding missed opportunities due to a lack of foreign language knowledge, available study time, study history, location of previous courses, personal data of corporate client representatives such as name, last name, email, and phone number.<\/p>\n 2.4.5 Sharing Personal Data:<\/strong> Fluency contracts external service providers to assist in carrying out the activities described in Item 2 of this Privacy Policy, using functionalities offered by companies such as Google (Google Workspace tools), Meta (WhatsApp, among others), Hotmart, and others. Fluency may act as either a Controller or Joint Controller of personal data in the processing chain, depending on the specific case. Fluency may also contract Personal Data Processors, who, under specific data processing rules outlined in contracts, will process personal data on behalf of Fluency.<\/p>\n 3.1 Fluency grants the personal data holder the right to access, rectify, port, and delete their data, except in cases of mandatory data retention under specific legislation and in accordance with this Personal Data Policy. Therefore, personal data holders are entitled to exercise the following rights by submitting an express request to (dpo@fluencyacademy.io<\/a>):<\/p>\n 3.2 Fluency retains personal data until it is no longer necessary to fulfill the purposes defined in this Personal Data Policy. The Organization also stores personal data as stated in item 3.1.6. In both cases, Fluency will observe the following:<\/p>\n 3.3 Fluency is not responsible for the consequences arising from incomplete, inaccurate, or outdated personal data.<\/p>\n 4.1 Fluency adopts the necessary and appropriate security measures, both technical and administrative, to protect personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication, or any form of improper or unlawful processing.<\/p>\n This Personal Data Collection and Processing Policy was adopted on September 24, 2021, and is subject to review at any time by the Organization.<\/p>\n","protected":false},"excerpt":{"rendered":" Rules for the relationship between Fluency Academy and personal data holders 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 […]<\/p>\n","protected":false},"author":2,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"template-termos.php","meta":{"inline_featured_image":false,"footnotes":""},"acf":[],"yoast_head":"\nFirst Section<\/h3>\n
1. Scope and Definitions<\/h4>\n
\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\n
Second Section<\/h3>\n
2. Nature of Collected Personal Data and Processing Purposes<\/h4>\n
\n2.2 Fluency will collect sensitive personal data through a specific consent agreement signed by the data subject, outlining, among other things, the purpose for which the data will be collected and processed, or, alternatively, in accordance with the authorizing provisions for the processing of sensitive personal data under Article 11 of the LGPD.
\n2.3 If the Interested Party is a child, Fluency will only process their personal data with the specific and highlighted consent of at least one parent or legal guardian, observing the best interest of the child, except for the provision established in paragraph 3 of Article 14 of the LGPD.
\n2.4 Fluency processes personal data to achieve the following purposes: 2.4.1 Execution of Fluency’s Social Purpose: Processing personal data of natural persons to enroll and register them to ensure access and assess the experience of students and content producers and\/or service providers in language courses on the Fluency Academy platform, undertaking the following activities:<\/p>\n\n
2.4.2 Administrative, Financial, and Human Resource Management: Carrying out the following activities:<\/h4>\n
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2.4.3 Communication and Marketing: Fluency performs the following activities with the goal of promoting and publicizing language courses:<\/h4>\n
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2.4.4 Legal Basis: The personal data processing activities mentioned in:<\/h4>\n
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Third Section<\/h3>\n
3. Rights of Personal Data Holders<\/h4>\n
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Fourth Section<\/h3>\n
4. Information Security<\/h4>\n
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