Privacy Policy

1. Introduction

Fluent Chat ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Conversational Portuguese language learning services and website.

This policy complies with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Information We Collect

2.1 Personal Information You Provide

When you register for an account or book lessons, we collect:

• Contact Information: Name, email address, phone number
• Account Information: Password (encrypted), time zone
• Payment Information: Transaction references
• Profile Information: Learning goals, Portuguese proficiency level, preferences
• Communication Data: Messages sent through our contact forms or email

2.2 Information Collected Automatically

When you use our website, we may automatically collect:

• Technical Data: IP address, browser type, operating system, device information
• Usage Data: Pages visited, time spent on site, links clicked, access times
• Cookies: Small data files stored on your device (see Section 7)

2.3 Lesson Information

During lessons, we may collect:

• Lesson attendance and scheduling information
• Progress notes and assessments
• Homework and feedback
• Learning materials accessed or downloaded

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery

• Provide and manage your Conversational Portuguese lessons
• Process bookings and payments
• Schedule lessons and send reminders
• Customize lessons to your learning needs
• Track progress and provide feedback

3.2 Communication

• Respond to inquiries and support requests
• Send lesson confirmations and updates
• Provide important service announcements
• Send educational content and learning tips (with your consent)

3.3 Business Operations

• Improve our services and develop new features
• Analyze usage patterns and service performance
• Prevent fraud and maintain platform security
• Comply with legal obligations

3.4 Legal Basis for Processing (GDPR)

We process your personal data under the following legal bases:

• Contract Performance: To provide the services you request
• Consent: For marketing communications and optional features
• Legitimate Interests: For service improvement and fraud prevention
• Legal Obligation: To comply with applicable laws and regulations

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information only in the following circumstances:

4.1 Service Providers

We may share information with trusted third-party service providers who help us operate and improve Fluent Chat, such as:

• Email delivery
• Website hosting and data storage
• Payment processing
• Analytics and performance monitoring

These providers are authorised to process personal data only on our instructions and are contractually required to protect it, keep it confidential, and use it only to provide services to us.

4.2 Video Conferencing Platforms

Lessons are conducted using third-party video conferencing platforms (e.g., Zoom, Google Meet, Skype). Your use of these platforms is subject to their respective privacy policies.

4.3 Legal Requirements

We may disclose your information if required by law or in response to:

• Comply with applicable laws, regulations, or legal processes (eg. court orders)
• Respond to lawfull requests or regulatory authorities
• Protect our rights, property, or safety
• Prevent fraud or illegal activities

4.4 Business Transfers

If Fluent Chat is involved in a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: Passwords are stored using industry-standard encryption and hashing practices
• Secure Transmission: We use HTTPS to help protect data in transit
• Access Controls: Access to personal data is restricted to authorised personal on a need-to-know basis
• Security Reviews: Ongoing assessment of security practices

Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide you with our services
• Comply with legal obligations (e.g., tax and accounting records)
• Resolve disputes and enforce our agreements
• Active accounts: Data retained while your account is active
• Inactive accounts: Data retained for 3 years after last activity
• Financial records: Retained for 7 years where required by law
• Marketing data: Retained until you withdraw consent

After the retention period, personal data will be securely deleted or anonymized.

7. Cookies and Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us provide a better user experience.

7.2 Types of Cookies We Use

• Essential Cookies: Required for website functionality (e.g., login, shopping cart)
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Authentication Cookies: Keeps you logged in between sessions

7.3 Managing Cookies

You can control cookies through your browser settings. However, disabling essential cookies may affect how the website works. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block cookies from specific sites
• Clear all cookies when you close your browser

8. Your Privacy Rights

Under the GDPR and applicable data protection laws, you have the following rights (subject to certain conditions and exceptions):

8.1 Right to Access

You can request a copy of the personal information we hold about you.

8.2 Right to Rectification

You can request correction of inaccurate or incomplete personal information.

8.3 Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal information, where applicable, subject to legal retention requirements.

8.4 Right to Restrict Processing

You can request that we limit how we use your information in certain circumstances.

8.5 Right to Data Portability

You can request your data in a structured, machine-readable format for transfer to another service.

8.6 Right to Object

You can object to processing of your personal information for certain purposes (eg. direct marketing).

8.7 Right to Withdraw Consent

Where we rely on your consent, you can withdraw it at any time.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint to us and we will reply within 30 days.

9. Children's Privacy

Our services are intended for adults and students over the age of 16. We do not knowingly collect personal information from children under 16 without parental consent.

If we discover that we have collected information from a child under 16 without parental consent, we will delete that information promptly. If you believe we have collected information from a child, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the European Commission
• Transfers to countries with adequate data protection levels
• Your explicit consent for the transfer

11. Third-Party Links

Our website may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.

12. Marketing Communications

With your consent, we may send you marketing emails about:

• New lesson packages and special offers
• Portuguese language learning tips and resources
• Updates about our services

You can opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your preferences in your account settings
• Contacting us here

Note: You will still receive essential service-related emails (e.g., booking confirmations, password resets) even if you opt out of marketing.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will:

• Update the "Last Updated" date at the top of this page
• Notify you via email for significant changes

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us here.

15. Complaints

If you believe we have not handled your personal information properly, you have the right to lodge a complaint with a supervisory authority in Portugal.