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PRIVACY POLICY

This Privacy Policy was last updated on 02/05/ 2023.

Thank you for participating in our online learning platform. Freitas Educacional respects user privacy and wants everyone to understand how user data is collected, used and shared. This Privacy Policy covers our data collection practices and describes the user’s rights to access, correct or restrict Freitas Educacional’s use of their personal data.

By using the Services, you agree to the terms of this Privacy Policy. Do not use the Services if you do not agree to this Privacy Policy or any other agreement governing your use of the Services.

Table of contents

  1. Types of data collected
  2. How user data is collected
  3. Purposes of user data
  4. With whom user data is shared
  5. Security
  6. Users’ rights
  7. Specific rules for each jurisdiction
  8. Updates and contact information.
  9. Types of data collected

We collect certain data directly from users, such as information entered by you, data on your consumption of content. We also collect some data automatically, such as information about your device and which parts of our Services you interact with or use.

1.1 Data provided by the user

We may collect different data about or provided by you depending on how you use the Services. Here are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect all the data you provide directly, including:

Account details

To use certain features (such as accessing content), you need to create a user account. When creating or updating the account, we collect and store the data provided, such as e-mail address, password, telephone number, occupation, interests, gender, race, ethnicity, official identification document information, verification photo, age, date of birth and account settings, and assign the user a unique identification number (“Account Data”).

Profile data

The user can also choose to provide profile information, such as a photo, title, biography, language, website link, social media profiles, country or other data. User profile data can be seen publicly by other people.

Shared content

Certain parts of the Services allow you to interact with other users or share content publicly, including by posting reviews of the content, questions or answers, sending messages to students or instructors, or posting photos or other work submitted by the user. This shared content can be seen publicly by other people, depending on where it is published.

Educational Content Data

When the user accesses the content, we collect certain data, including which courses, assignments, labs, workspaces and tests have been started and completed by the user; purchased content and credits; subscriptions; certificates of completion; exchanges of information with instructors, teaching assistants and other students; and essays, answers to questions and other items submitted to satisfy the requirements of the courses and related content. If you are an instructor, we store your educational content, which may contain data about you.

Student payment data

When the user makes purchases, we collect some data about the purchase in question (such as the user’s name and zip code) when necessary to process the order. It is up to the user to provide certain payment and invoice data directly to our payment processing partners, including the user’s name, credit card information, billing address and zip code. We may also receive limited information, such as the fact that you have a new card and the last four digits of that card, from partners to facilitate payments. For security reasons, Freitas Educacional does not collect or store confidential cardholder data, such as the full credit card number or card authentication data.

Sweepstakes, promotions and surveys

We may invite you to take a survey or participate in a promotion (such as a contest, sweepstakes or challenge), either through the Services or a third-party platform. If the user participates, we will collect and store the data provided by the user as part of the participation, such as name, e-mail address, postal address, date of birth or telephone number. Such data is subject to this Privacy Policy, unless otherwise specified in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including to notify winners and distribute prizes. In order to receive a prize, it may be necessary to obtain the user’s permission for us to disclose some of their information publicly (such as on the winners’ page). When we use a third party platform to administer a survey or promotion, the privacy policy of that third party will apply.

Communications and support

If the user contacts us for support or to report a problem or question (regardless of whether they have created an account), we collect and store the user’s contact information, as well as messages and other data about the user, such as name, e-mail address, messages, location, user ID at Freitas Educacional, refund transaction IDs and any other data that the user provides or that we collect by automated means (discussed below). This data will be used to respond to the user and research the question raised, in accordance with this Privacy Policy.

The data listed above is stored by Freitas Educacional and associated with the user’s account.

1.2 Data collected by automated means

When the user accesses the Services (including when browsing content), we collect certain data by automated means, including:

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 data and platform types (“System Data”).

Usage data

Usage statistics on user interactions with the Services, such as content accessed, time spent on pages or the Service, pages visited, resources used, search queries, click data, date and time, referrer and other data related to the use of the Services (“Usage data”) by the user.

Approximate geographical data

Approximate geographical location, which includes information such as country, city and geographical coordinates, calculated on the basis of the user’s IP address.

The data listed above is collected through server log files and tracking technologies, as detailed in the “Cookies and data collection tools” section below. The data is stored by Freitas Educacional and associated with the user’s account.

1.3 Third-party data

If you are a business or potential customer of Freitas Educacional , we may collect some contact information from third-party commercial sources.

  1. How user data is collected

We use tools such as cookies, web beacons and similar tracking technologies to gather the data listed above. Some of these tools offer the user the possibility of opting out of data collection.

2.1 Cookies and data collection tools

We use cookies, which are small text files stored by your browser to collect, store and share data about your activities on different websites, including Freitas Educacional. Cookies allow us to remember details about the user’s visits to Freitas Educacional, such as the preferred language, and to facilitate the use of the site. To find out more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

2 Why we use Data Collection Tools

Freitas Educacional uses the following types of Data Collection Tools for the purposes described:

  • Strictly Necessary: these Data Collection Tools allow you to access the site, provide basic functionality (such as logging in or accessing content), secure the site, protect against fraudulent logins and detect and prevent abuse or unauthorized use of your account. This is necessary for the Services to function properly, so if you disable them, some parts of the site will be corrupted or unavailable.
  • Functional: these Data Collection Tools remember data about your browser and your preferences, offer additional functionalities on the site, personalize the content so that it is more relevant to the user and remember settings that affect the appearance and behavior of the Services (such as your preferred language or volume for playing videos).
  • Performance: these Data Collection Tools help evaluate and improve the Services by providing usage and performance data, visit counts, traffic origins or the location where an application was downloaded. These tools help us to test different versions of Freitas Educacional to see which features or content users prefer, as well as to determine which e-mail messages are opened.
  • Advertising: these Data Collection Tools are used to display relevant advertisements (on the website and/or on other websites) based on information known about the user, such as System and Usage Data (as detailed in Section 1), and information that the advertising service providers know about the user based on tracking data. Ads can be based on your recent or historical activity and on other sites and services. To help display personalized advertising, we may provide service providers with an anonymized and hashed version of the user’s email address (in human-readable format) and the content that the user shares publicly on the Services.
  • Social Media: these Data Collection Tools enable social media functionality, such as sharing content with friends and acquaintances. These cookies can track a user or device on other websites, and create a profile of the user’s interests for use in targeted advertising.

You can configure your web browser to alert you to attempts to insert cookies on your computer, limit the types of cookies allowed or simply refuse cookies altogether. In this case, it may not be possible to use some or all of the features of the Services, and the user experience may be different or less functional. To find out more about managing Data Collection Tools, see Section 6.1 (User options regarding the use of their data) below.

  1. Purpose of user data

We use user data for purposes such as providing our Services, communicating with you, troubleshooting problems, protecting against fraud and abuse, improving and updating our Services, analyzing how people use our Services, serving personalized advertising, as required by law or necessary for safety and soundness.

The data collected when the user uses the Services is used to:

  • To provide and administer the Services, including to facilitate participation in educational content, issue certificates of completion, display personalized content and facilitate communication with other users;
  • Processing payments to instructors and other third parties;
  • Process user requests and orders for educational content, products, specific services, information or resources;
  • Communicate with the user about their account:
    • Answering user questions and doubts;
    • Send administrative messages and information, including messages received from instructors, students and teaching assistants; notifications about changes to our Service; and updates to our agreements;
    • Send information to the user, by email or text messages, about their progress in courses and related content, rewards programs, new services, new features, promotions, newsletters and other available content created by the instructor (which, at any time, the user can opt out of receiving);
    • Sending push notifications to the user’s wireless device to provide updates and other relevant messages (which can be managed from the mobile app’s “options” or “settings” page);
  • Manage the user’s account and account preferences;
  • Facilitate the technical operation of the Services, including troubleshooting, protection of the Services and prevention of fraud and abuse;
  • Request feedback from users;
  • Products, services, research and market promotions;
  • Market subscription plans for potential customers;
  • Learn more about the user by linking their data to other data through third-party data providers and/or analyzing the data with the help of analytics service providers;
  • Identify unique users between devices;
  • Customize ads between devices;
  • Improve our Services and develop new products, services and resources;
  • Analyze trends and traffic, track purchases and usage data;
  • Advertise the Services on third party websites and applications;
  • As required or permitted by law; or
  • As Freitas Educacional, in our sole discretion, determines necessary to ensure the safety or integrity of our users, employees, third parties, the public or our Services.
  1. With whom user data is shared

We share some data about you with instructors, other students, companies that provide services to Freitas Educacional, Freitas Educacional affiliates, our business partners, data analysis and enrichment providers, user social media providers, companies that help us run promotions and surveys, and advertising companies that help us promote our Services. We may also share your data as necessary for security purposes, legal compliance or as part of a corporate restructuring. Finally, we may share data in other ways if it is aggregated or de-identified, or if we obtain consent from the user.

We may share your data with third parties in the following circumstances or as otherwise described in this Privacy Policy:

  • With Teachers: We share data about the user (except the e-mail address) with instructors or teaching assistants of the educational content that the user accesses or requests information about, so that they can improve the content for the user and other students. This data may include the user’s city, country, browser language, operating system, device settings, the website that led the user to Freitas Educacional and the user’s activities on Freitas Educacional. If we collect other data about the user (such as age or gender), we may share it as well. We will not share your e-mail address with instructors or teaching assistants.
  • With other students and teachers: Depending on the user’s settings, shared content and profile data can be viewed publicly, including by other students and instructors. If you ask an instructor or teaching assistant a question, the user’s information (including name) can also be seen publicly.
  • With service providers, contractors and representatives: We share user data with third-party companies that provide services to our Company, such as payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer service and support. These service providers can access the user’s personal data and are obliged to use it only as directed by Freitas Educacional to provide the requested service.
  • With Freitas Educacional Affiliates: Your data may be shared with our corporate group of companies, related by common ownership or control to enable or support the provision of the Services.
  • With business partners: We maintain contracts with other sites and platforms that aim to distribute our Services and increase traffic to Freitas Educacional. For example, we work with Benesse in Japan.
  • With data analysis and enrichment services: As part of our use of third-party analytics tools, such as Google Analytics, and data enrichment services, such as ZoomInfo, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1) or de-identified data as necessary. De-identified data means data from which information has been removed, such as the user’s name and e-mail address, which is replaced by a token ID. In this way, providers can provide analysis services or combine user data with information from publicly available databases (including contact and social information from other sources). The aim is to communicate with the user in a more effective and personalized way.
  • To enable social media features: Social media features included in the Services (such as the Facebook Like button) may allow the social media provider to collect information such as the user’s IP address and which page of the Services the user is visiting, and set a cookie to enable the feature. User interactions with these resources are governed by the privacy policy of the third-party company.
  • To manage promotions and surveys: We may share your data as necessary to administer, market or sponsor promotions and surveys in which you choose to participate, as required by applicable law (such as providing a list of winners or making required registrations) or in accordance with the rules of the promotion or survey.
  • For advertising: If we decide to use an advertising-driven revenue model in the future, we may use and share certain System Data and Usage Data with advertisers and third-party networks to display general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1) and use this data to offer targeted advertisements in order to personalize the user experience (through behavioral advertising) and perform web analytics. Advertisers may also share the data they collect about you with us. To find out more or to opt out of receiving behavioral advertising from participating ad networks, see Section 6.1 (User Choices Regarding the Use of Your Data) below. It is worth noting that by opting out, users will continue to receive generic ads.
  • For security and compliance with the law: We may disclose your data to third parties if (in our sole discretion) we believe, based on good faith, that the disclosure is:
    • Permitted or required by law;
    • Requested as part of a judicial, governmental or legal investigation, order or proceeding;
    • Justifiably necessary as part of a valid subpoena, warrant or other legally valid request;
    • Reasonably necessary to enforce our Terms of Use, Privacy Policy and other legal agreements;
    • Necessary to detect, prevent or resolve cases of fraud, abuse, misuse, possible violations of law (or rules or regulations) or technical or security issues; or
    • Justifiably necessary, in our opinion, to protect against imminent harm to the rights, property or safety of Freitas Educacional, our users, employees, members of the public or our Services.
    • We may also disclose data about you to our auditors and legal advisors in order to evaluate our disclosure obligations and rights under this Privacy Policy.
  • In cases of transfer of control: If Freitas Educacional undergoes a business transaction, such as a merger, acquisition, corporate divestiture or dissolution (including bankruptcy), or a partial or total sale of assets, we may share, disclose or transfer all User Data to the successor organization during such transition, or in contemplation of a transition (including during an audit).
  • After aggregation/ de-identification: We may disclose or use aggregated or de-identified data for any purpose.
  • With your permission: With your consent, we may share data with third parties outside the scope of this Privacy Policy.
  1. Security

We use appropriate security based on the type and confidentiality of the data being stored. As with any system with Internet access, there is always the risk of unauthorized access. It is therefore important that you protect your password or contact us if you suspect unauthorized access to your account.

Freitas Educacional adopts appropriate security measures to protect itself against unauthorized access, alteration, disclosure or destruction of the user’s personal data collected and stored by us. These measures vary based on the type and confidentiality of the data. Unfortunately, however, no system can be 100% protected. Therefore, we cannot guarantee that communications between you and Freitas Educacional, the Services or any information provided to Freitas Educacional in relation to the data we collect through the Services are free from unauthorized access by third parties. The user’s password is an important part of our security system, and it is the user’s responsibility to protect it. Do not share your password with third parties. If you suspect that your password or account has been breached, change it immediately and contact Freitas Educacional’s management to remedy the situation.

  1. Users’ rights

Users have certain rights regarding the use of their data, including the possibility of opting out of receiving promotional emails, cookies and the collection of data by certain third parties. You may update or terminate your account within our Services and contact us with any questions regarding your individual rights over your personal data. Parents who believe that we have accidentally collected personal data about their underage children should contact us for help on how to delete this information.

6.1 User Choices Regarding the Use of Your Data

You may choose not to provide certain data to Freitas Educacional, but you may not be able to use certain features of the Services.

  • Users can opt out of receiving promotional communications. To do this, you can use the unsubscribe mechanism in the promotional communication you receive, or change the e-mail preferences of your user account. It should be noted that, regardless of the user’s e-mail preference settings, Freitas Educacional will send transactional and relationship messages related to the Services, including administrative confirmations, order confirmations, important updates about the Services and notices about our policies.

6.2 Accessing, updating and deleting personal user data

To access and update the personal data collected and kept by Freitas Educacional, the user can:

  • To update data provided directly, the user must log in to their account and update it at any time.
  • To close the account:
    • If you are a student, you must access the profile settings page and follow the detailed steps.
    • If you are an instructor, you must follow the detailed steps.
    • If you are having problems closing your account, please contact support. Note: Even after the account has been closed, some or all of the user’s data will still be visible to other people, including, but not limited to, data that has been (a) copied, stored or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including in your shared content); or (c) published on a third-party platform. Even after the account has been closed, we will retain your data for as long as we have a legitimate purpose for doing so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes and enforce our contracts. We may retain and disclose such data in accordance with this Privacy Policy after the user’s account has been closed.
  • You can also send an e-mail to direcao@freitaseducacional.com or write to Freitas Educacional. It is worth noting that we retain certain data when we are entitled to do so, including in the case of mandatory record-keeping and to carry out transactions.

6.3 Our policy towards children

We recognize the privacy interests of children and recommend that parents and guardians take an active role in their children’s online interests and activities. If you are not yet 18 years old, but already have the minimum age for consent to use online services in the country where you live (for example, 13 in Brazil or 17 in the UK), you will not be able to create an account, but we suggest asking your father, mother or other guardian to open an account and help you sign up for the appropriate content. Individuals who have not yet reached the minimum age for consent to use online services will not be able to use the Services. If we become aware that we have collected personal data from a child under these ages, we will take the necessary steps to delete it.

Parents who believe that Freitas Educacional may have collected personal data from a child under these ages can send a request to remove the data to direcao@freitaseducacional.com.

  1. Updates and contact information

In the event of significant changes to this policy, we will notify users by e-mail, notices on the product itself or other mechanism required by law. The changes will come into force on the day they are published. Please contact us by e-mail or post if you have any questions, clarifications or conflicts.

7.1 Changes to this privacy policy

From time to time, we may update this Privacy Policy. In the event of significant changes, we will notify you by email, notice posted on the Services, or as otherwise required by applicable law. We will also include a summary of the main changes. Unless otherwise stated, the amendments shall enter into force on the day they are published.

As permitted by applicable law, by continuing to use the Services after the effective date of any change, your access and/or use will be deemed to constitute acceptance of the revised Privacy Policy (and agreement to follow and be bound by it). The revised Privacy Policy replaces all previous Privacy Policies.

7.2 Interpretation

All terms with initial capital letters not defined in this policy are defined as specified in the Freitas Educacional Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. In the event of a conflict with a non-English version, the user agrees that the English version shall prevail.

7.3 Questions

If you have any questions, clarifications or conflicts regarding our Privacy Policy, please contact our privacy team (including our designated personal information protection manager) at direcao@freitaseducacional.com.