Privacy Policy

This Privacy Policy covers our data collection practices and sets forth your rights to access, correct or restrict the use of your personal data, which applies when you visit or use Fluency Academy's website, mobile applications, APIs or other platforms (“Platforms”).

Accordingly, by using the Platforms, you agree to the terms of this Privacy Policy.

1. TYPES OF DATA COLLECTED

ACCOUNT DATA: when the user's account is created, we collect and store the data provided, such as email address, password, phone number, address, gender, date of birth, CPF/MF, Instagram profile, and assign the user a unique ID number.

STUDENT PAYMENT DATA: When a user purchases any of the Courses, the user is required to provide certain payment and billing information directly to our payment processing partners, including the user's name, credit card information, billing address and zip code. For security reasons, Fluency Academy does not collect or store sensitive cardholder data, such as the full credit card number or card authentication data.

DATA ABOUT USER ACCOUNTS ON OTHER SERVICES: We may obtain certain information through your social media accounts or other online accounts if they are connected to your account. These platforms and services make information available through their respective APIs. The information we receive depends on what information the user (through privacy settings) or the platform or service chooses to provide to us.

DRAWS, PROMOTIONS, AND SURVEYS: If the user participates in a Fluency Academy drawing, promotion, or survey, the data that is provided, such as name, e-mail address, date of birth, or phone number, will be stored. The data collected will be used to manage the promotion or survey, including notifying winners and distributing prizes.

COMMUNICATIONS AND SUPPORT: In the event that you contact us for support or to report a problem or concern, we collect and store your contact information, as well as messages and other data about you such as your name, e-mail address, location, and any other data that you provide or that we collect through automated means.

SYSTEM DATA: Technical data about the user's computer or device, such as IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other system and platform type data.

USAGE DATA: We collect usage data about user interactions on the Platforms, such as courses accessed, date and time of access, time spent on pages, pages visited, click-through data, and other data related to user use of the Platforms.

APPROXIMATE GEOGRAPHIC DATA: We collect ****data about the ****approximate geographic location of the user when using the Platform calculated based on the user's IP address.

2. HOW USER DATA IS COLLECTED

The Fluency Academy Platforms, when running, collect data from the user, and some of them give the user the ability to opt-out of data collection.

Users' personal data is collected when they voluntarily provide such information to access and/or use the Platforms, such as: name, date of birth, CPF number, e-mail address, mailing address, password, telephone number.

In addition to personal data, non-personal data and information about user activities on the Platforms may be collected to understand the user's usage model.

The Fluency Academy Platforms and third party systems that are connected to them use server log files and tools for automated data collection, such as cookies, tags, scripts, custom links, device or browser traces, and web beacons, when a user accesses and uses the Platforms.

We use cookies to analyze the use of the Platforms, personalize the user experience, facilitate connection and recognize the user when using them. We use web beacons to identify whether a page has been visited, identify whether an email has been opened and to advertise more effectively by excluding current users from certain promotional messages or identifying the source of a new mobile application download.

Some categories of cookies used:

PREFERENCES: Cookies in this category allow Fluency Academy to remember information about user behavior and preferences, such as preferred language for navigation.

SECURITY: Necessary for the operation of the site. They allow you to navigate our sites and use the services and features (for example, security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized third parties).

PERFORMANCE: cookies that track user interactions with the Platform and help improve the user experience by collecting information about user behavior.

ADVERTISING: Cookies for advertising purposes are used to deliver advertisements and run advertising campaigns according to a certain audience, and it is possible to deliver advertisements according to your consumption profile on the Platforms.

Technology service providers may use their own cookies, with our permission, to provide services to Fluency Academy. Such cookies will collect user data on our Platforms for the purposes set out in this policy.

Most browsers are set to automatically accept cookies. You can change your settings to block cookies. Blocking all cookies will affect how your experience works, as it will not be possible to identify your preferences and recommend relevant content.

3. USE OF USER DATA

User data is used for the purpose of providing, developing and improving the services provided or products offered, including those to be created, as well as for user communication, troubleshooting problems, fraud and abuse protection, serving personalized advertising and for Fluency Academy to analyze how people use the Platforms.

Fluency Academy will use personal data in the following ways:

a) to enable the purchase and delivery of our courses, through e-commerce;

b) deliver printed and/or digital content of the courses;

c) process payment;

d) confirm and complete user data;

e) fulfill the requirements of promotions, commercial actions or contests promoted by Fluency Academy;

f) send confirmations and fulfill user requests;

g) respond to the user when in contact with Fluency Academy;

h) polls and surveys for the purpose of testing, troubleshooting, improving or evaluating the courses and Platforms;

i) communicate about events, promotions, announcements, new products and services in your email account, by text message, messaging apps, phone call (including telemarketing) and push notification;

j) inform about changes in the Platforms' terms of use and policies;

k) perform technical and operational support and ensure the security and functionality of the Platforms;

l) monitoring and preventing illegal, fraudulent or suspicious activities;

m) protect the rights and properties of Fluency Academy, including against invasion and hacking;

n) customize the content and advertising disclosed on the Platform and make inferences about content and topics that may be of interest to the user, in order to recommend content and products;

o) analyze trends and traffic, track purchases and usage data;

p) monitor activity and usage trends;

q) measure Course interactions and audience;

r) develop machine learning;

s) to recognize and follow user navigation;

t) comply with legal, judicial and administrative determinations and offices of competent authorities; and

u) take or provoke legal, judicial and administrative measures to defend our rights and the rights of third parties, including in any judicial or administrative proceedings.

4. SHARING OF USER DATA

We may share user data with third parties, subject to the following:

(a) SERVICE PROVIDERS, CONTRACTORS AND REPRESENTATIVES: sharing of user data with third party companies that provide services to Fluency Academy, such as payment processing, fraud and abuse prevention, data analytics, marketing and advertising services (including retargeted advertising), email and hosting services, and customer service and support;

b) BUSINESS PARTNERS: To (i) improve our products and Platforms; (ii) expand our business; and (iii) develop new business, including for purposes of facilitating user registration and enhancing user experience with partner products and services;

c) DATA ANALYSIS AND DATA ENRICHMENT SERVICES: third-party data analysis tools and data enrichment services;

d) PARTNERS AND PURCHASERS OF NEW COMPANIES AND/OR ASSETS: For the sale of Fluency Academy businesses, assets, or equity interests, the establishment of new companies or the making of investments, data may be shared, disclosed, or transferred to the successor organization during the transition or in contemplation of a transition (including during an audit).

5. DATA STORAGE

Your user data may be transferred, stored and processed in Brazil or abroad by Fluency Academy or by a service provider contracted by it, subject to the security measures applicable by the company.

6. SECURITY

Fluency Academy has adopted security controls to protect user data from unauthorized access, use, alteration, disclosure or destruction, including physical and logical protection of assets, encrypted communications, access management, adherence to secure software development, and internal compliance policies.

Still, it is not possible to guarantee the platforms are completely tamper-proof.

The user password is a sensitive part of the security system. Do not share your password with others. If you suspect a password or account violation, change it immediately and contact the Support Team.

7. USERS UNDER 18 YEARS OF AGE.

Users under the age of sixteen (16) must be duly represented by their legal representative when registering on the Platforms and creating a user profile, so that their parents, guardians or legal representatives expressly consent to use the Platforms and their functionalities. Users under eighteen (18) and over sixteen (16) years of age must be duly assisted by their legal representative when registering on the Platforms and creating a user profile.

Parents, guardians or legal representatives are fully responsible in case of access to the Platforms by children and adolescents, without due authorization or representation, as they are fully responsible for the supervision of the activities and conduct of the respective minors under their guardianship.

Parents, guardians and legal representatives who believe that we have accidentally collected personal data about their minor children should contact us for help in deleting this information.

8. USER RIGHTS

The user can opt out of receiving promotional emails, cookies and data collection. The user may update or terminate their account within the Platforms, as well as clarify doubts about their personal data, either through specific functionality for this purpose on the Platform, or through settings in their browser or device, safeguarding the user's right to express your request directly to the Fluency Academy Support Team.