- Types of Data Collected
- Form of Collection of User Data
- Purpose of User Data
- With whom User Data is Shared
- User Rights
- Specific Rules of Each Jurisdiction
- Updates and Contact Information
1. Types of Data Collected
we collect data directly from users, such as information entered by the user himself, data on the user's participation in courses and data from third-party platforms with which the user connects through Werkey. We also collect certain 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 the user, or provided by the user, according to how the user uses the Services. Below 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 data you provide directly, including:
1.1.1. Account details
To use certain features, such as making purchases or enrolling in a course through our online store, or accessing courses directly within our learning environment, it is necessary to create a user account using an online form in one of these environments. When the user creates or updates their account, we collect and store the provided data, such as full name, identification document number, email address, phone number, and mailing address.
1.1.2. Profile data
The user may also choose to provide information regarding the profile, such as a photo, a title, a link to websites, profiles on social media or other data. User profile data may be publicly viewable by others.
1.1.3. Shared content
Certain portions of the Services allow you to interact with other users or share content publicly, including by posting reviews on a course page, asking questions or answers, sending messages to students or content providers, or posting user-submitted photos or other work. . This shared content may be publicly viewable by others, depending on where it is posted.
1.1.4. Course data
When the user enrolls in a course, we collect certain data, including which courses, assignments and tests the user started and/or completed, exchanges of information with content providers (including instructors and teaching assistants) , other students, answers to questions, and other items submitted to satisfy course requirements.
1.1.5. Student payment data
When the user makes purchases, we collect some data about the purchase in question (such as name, email, address, CPF or CNPJ of the user) when necessary to process the order. It is up to you to provide certain payment and billing information directly to our payment processing partners, including your username, credit card information, billing address and zip code. For security reasons, Werkey does not collect or store confidential data from the cardholder, such as the full credit card number or authentication data.
1.1.6. Content Provider or Affiliate Payout Data
1.1.7. Data about user accounts on other services
We may obtain certain information through user accounts on social networks or other online accounts, if they are connected to the user's Werkey account. If the user connects to Werkey through Facebook or another third-party platform or service, we ask for the user's permission so that we can access certain information about that other account. For example, depending on the platform or service, we may collect the user's name, profile picture, account ID number, access email address, location, physical location of the user's access devices, user, gender, birthday, and the user's friends or contacts list.
These platforms and services make information available to Werkey 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.
If you access or use our Services through a third-party platform or service or click on third-party links, the collection, use and sharing of data will also be subject to the privacy policies and other agreements of the respective third parties.
1.1.8. Sweepstakes, promotions and surveys
1.1.9. Communications and Support
The data listed above is stored by Werkey and associated with the user account.
1.2. User data is collected by automated means
1.2.1. system data
Technical data about your 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 ("Data of the system").
1.2.2. Usage data
Usage statistics about user interactions with the Services, such as courses accessed, time spent on pages or on the Service, pages visited, resources used, search queries, data on clicks, date and time and other data related to use of the Services (“Usage Data”) by the user.
1.2.3. Approximate geographic data
Approximate geographic location, which includes information such as country, city and geographic coordinates, calculated based on 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 Werkey and associated with the user account.
2. User Data Collection Form
We use tools such as cookies, web beacons, analytics services and advertising providers to gather the data listed above. Some of these tools offer the user the possibility to opt out of data collection.
2.1. Cookies and data collection tools
2.2. Werkey uses the following types of cookies
- Necessary: These cookies are essential for the website to function. They allow you to browse the site and use its features, such as accessing secure areas and shopping online.
- Performance: These cookies collect information about how users interact with the website, such as the most visited pages and the time spent on each page. This helps website owners better understand user behavior and improve the user experience.
- Functional: These cookies allow the website to remember choices you have made in the past, such as your language preferences or account settings. They can also be used to provide you with personalized features, such as product recommendations based on your purchase history.
- Marketing: These cookies are used to track your online activity and provide you with personalized advertisements based on your interests. They may be used by third-party advertising companies to build a profile of your interests and show you relevant advertisements on other websites you visit.
Some third-party partners that provide certain features on our website may also use local storage objects (also known as flash cookies or LSOs) to collect and store data.
We use third party browser and mobile analytics services such as Google Analytics, Active Campaign, Post Affiliate Pro and Zendesk on the Services. These services use data collection tools to help us analyze your use of the Services, including information such as the third-party site the user came from, the frequency of visits the user visits, events within the Services, usage data and performance and where the app was downloaded from. We use this data to improve the Services, better understand how the Services work on different devices and provide you with information that may be of interest to you.
2.4. Online advertising
We use third-party advertising services such as Facebook, Google's ad services, and other ad networks and servers to provide advertising about our Services on other websites and applications that you use. Ads may be based on information known about the user, such as the user's usage data and system data (detailed in Types of data collected ) and information these ad service providers know about the user based on the data tracking them. Ads may be based on recent activity or activity over time and across other sites and services and may be tailored to the user's interests.
Some types of advertising services we use may place cookies or other tracking technologies on your computer, phone or other device to collect data about your use of our Services and access those tracking technologies to serve you personalized advertisements. To help deliver personalized advertising, we may provide service providers with an anonymized and hashed version of your email address (in a human-unreadable format) and the content that you share publicly on the Services.
When using mobile applications, the user may also receive personalized advertisements in the application. Apple iOS and Android OS provide their own instructions on how to control in-app personalized ads. For other devices and operating systems, please review privacy settings or contact user platform operator.
3. Purpose of User Data
We use user data for purposes such as providing our Services, communicating with you, troubleshooting issues, protecting against fraud and abuse, improving and updating our Services, analyzing how people use our Services, serving you personalized advertising as required by law. or necessary for security and integrity.
The data collected when the user uses the Services is used to:
- Provide and administer the Services, including to display personalized content and facilitate communication with other users;
- Process requests and requests for user-made courses, products, specific services, information or resources:
- Communicate with the user about their account:
- Send administrative messages and information, including messages received from instructors and teaching assistants, notifications about changes to our Service and updates to our agreements;
- Sending push notifications to the user's wireless device to provide updates and other relevant messages (which can be managed in the mobile app's "options" or "settings" page).
- Facilitate the technical operation of the Services, including troubleshooting, securing the Services, and preventing fraud and abuse;
- Disseminate and administer surveys and promotions administered or sponsored by Werkey;
- Identify unique users across devices;
- Improve our Services and develop new products, services and features;
- Advertise the Services on third-party websites and applications;
- How Werkey, in our sole discretion, determines what is necessary to ensure the safety or integrity of our users, employees, third parties, the public or our Services.
4. With whom User Data is Shared
We share some data about the user with content providers, other students, companies that provide services to Werkey, our business partners, analytics and data enrichment providers, users' social media providers, companies that help us run promotions and surveys and advertising companies that help us promote our Services. We may also share user 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 user consent.
- With content providers: We share data about you with instructors or teaching assistants of courses you enroll in or request information about, so that they can improve courses for you and other learners. This data may include full name, email address, user's city, country, browser language, operating system, device settings, the website that led the user to Werkey and the user's activities on our course store and/or on our learning environment, including details about your interaction with the courses. If we collect other data about you (such as age or gender), we may share that as well. We also allow our instructors to implement Google Analytics on the course pages they offer to track traffic sources in the courses and optimize the course pages.
- With sponsors and promoters of the courses: We may share data about the user and his performance in the courses in which he is enrolled with companies that sponsor these courses; either by fully or partially paying the price of enrolling in courses, including in the case of discount coupons offered to a specific public. This sharing applies especially to dealerships that sponsor courses for the brands they represent. The data to be shared may include the student's full name, email address, telephone number and their status in courses that have been sponsored.
- With other students and content providers: Depending on user settings, shared content and profile data may be publicly viewable, including by other students and content providers. If you ask a content provider (instructor, administrator or teaching assistant) a question, the user's information (including name) may also be publicly viewable by other users, depending on the user's settings.
- With service providers, contractors and agents: We share user data with third-party companies that provide services to our Company, such as payment processing, data analysis, marketing and advertising services (including retargeted advertising), email services and hosting and service and eventually customer support. These service providers may access the user's personal data and are obliged to use them only as directed by Werkey, to provide the requested service.
- With business partners: we maintain contracts with other websites and platforms that aim to distribute our Services and increase traffic to Werkey. Depending on the user's location, we may share his data with these partners.
- With analytics and data enrichment services: As part of our use of third party analytics tools such as Google Analytics and data enrichment services, we share certain contact information, account data, system data, data about usage (detailed in Types of Data Collected ) or de-identified data, as needed. De-identified data means data from which information such as the user's name and email address has been removed and replaced with a token ID . In this way, providers may provide analytics services or combine user data with information from publicly available databases (including contact and social information from other sources). The objective is to communicate with the user in a more effective and personalized way.
- To administer promotions and surveys: We may share your user data, if necessary, to administer, market or sponsor promotions and surveys that you choose to participate in, as required by applicable law (such as providing a list of winners or making required entries) or in accordance with the rules of the promotion or survey.
- For Advertising: If we decide to offer advertising in the future, we may use and share certain system data and usage data with third-party advertisers and 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 the " Cookies and data collection tools" section of the " How do we collect user data? " section) and use these data to deliver targeted advertisements to personalize user experience (via behavioral advertising) and perform web analytics . Advertisers may also share with us the data they collect about you. To learn more or opt-out of behavioral advertising participating ad networks, see the " User Choices Regarding Use of Your Data " section in the " User Rights? ". It is worth mentioning that, by opting out, the user will continue to receive generic advertisements.
- For security and legal compliance: We may disclose User Data to third parties if (in our sole discretion) we have a good faith belief that the disclosure is:
- Allowed or required by law;
- Requested as part of a court, governmental or legal order or proceeding investigation;
- Justifiably necessary as part of a valid subpoena, warrant or other legally valid request;
- 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 damage to the rights, property or safety of Werkey, our users, employees, members of the public or our Services.
- In cases of transfer of control: if Werkey undergoes a commercial 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 said transition, or in contemplation of a transition (including during an audit).
- Upon aggregation/de-identification: We may disclose or use aggregated or de-identified data for any purpose.
We use appropriate security based on the type and sensitivity of the data being stored. As with any system with Internet access, there is always a risk of unauthorized access. Therefore, it is important that the user protects the password or contact us in case of suspicion of unauthorized access to his account.
Werkey 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 sensitivity of the data. Unfortunately, however, no system can be 100% secure. Therefore, we cannot guarantee that the communications between the user and Werkey, the Services or any information provided to Werkey in relation to the data collected by us 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 the password with third parties. In case of suspected password or account violation, change it immediately and contact our Support Team by email or chat via the help button on our websites to remedy the situation. Alternatively, email firstname.lastname@example.org directly .
6. User Rights
You have certain rights regarding the use of your data, including the ability to opt-out of receiving promotional emails, cookies and the collection of data by certain analytics service providers. The user can update or close his account within our Services and also contact us to clarify doubts regarding individual rights over his personal data. Parents who believe that we have accidentally collected personal data about their minor children should contact us for assistance in deleting this information.
6.1. User options regarding the use of your data
The user can choose not to provide certain data to Werkey, but it is possible that he will not be able to use certain features of the Services.
- The user can opt out of receiving promotional communications. For this, you can use the unsubscribe mechanism, in the promotional communication you receive, or change the email preferences of the user's account. It should be noted that, regardless of the user's email preference settings, Werkey will send messages about transactions and relationships related to the Services, including administrative confirmations, order confirmations, important updates about the Services and notices about our policies.
- The browser or device used by the user may allow the control of cookies and other types of local data storage. Wireless devices can also allow control over the collection and sharing of location or other data. Users can manage their cookie preferences via the cookies banner on Werkey websites, or by sending an email to email@example.com .
- For information and to control the cookies used for personalized advertisements from participating companies, please refer to the consumer opt-out pages for the Network Advertising Initiative , the Digital Advertising Alliance , or if you are located in the European Union, visit the Your On website -line Choices . To opt out of receiving display advertising from Google or to customize Google Display Network ads, go to theGoogle Ads settings page .
- To opt out of allowing Google Analytics to use user data for analysis and enrichment purposes, please visit the Google Analytics Opt-out Instructions page .
If you have questions about rights, data and how Werkey uses the data, the user should contact our Support Team by email or chat through the help button on our websites.
6.2. Access, update and deletion of user personal data
To access and update the personal data collected and maintained by Werkey, the user can:
- To update data provided directly, the User must log into their account and update it at any time.
- To close the account:
- Students, content providers or affiliates should contact our Support Team via the help button on our websites, submitting an email or chat message with the request.
- To request access, correct or delete personal data, contact our Support Team via email or chat via the help button on our websites. Alternatively, email firstname.lastname@example.org directly or write to Werkey Plataforma Digital Ltda. (Av. Cezira Giovanoni Moretti, 655, sala 11, Reserva Jequitibá, CEP 13414-157, Piracicaba – SP – Brazil). Please allow up to 30 days for a response. For the sake of user protection, we may ask that the request be sent to the email address associated with the user's account. It may be necessary to confirm the user's identity before implementing the request. Please note that we retain certain data when we have the right to do so, including for mandatory record keeping and to carry out transactions.
6.3. Our Policy Regarding Children
We recognize children's privacy interests and encourage parents and guardians to take an active role in their children's online activities and interests. Children under the age of 13 (or under 16 in the European Economic Area) must not 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 Werkey may have collected personal data from a child under these ages should contact our Support Team by email or chat through the help button on our websites, requesting removal of data. Alternatively, email email@example.com directly .
7. Specific Rules for Each Jurisdiction
If you are a California resident, you have certain rights related to accessing and deleting your data, as well as knowing who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside the United States should be aware that we transfer data to the US and other areas outside the European Economic Area.
7.1. Users in California
Users residing in California have certain rights under the California Consumer Privacy Act ("CCPA"). If you are an eligible California user, your rights include:
- "Right to Know" — You have the right to ask to know more about the specific categories and personal information we have collected about you, as well as to access a copy of your personal information.
- "Right to Delete" — You have the right to request deletion of the personal information we have collected about you.
- "Right to Non-Discrimination" — If you choose to enforce any of your rights under the CCPA, Werkey will continue to treat you like all other users. In other words, no penalty will apply for exercising your rights under the CCPA.
To exercise any of your rights under the CCPA, please contact our Support Team via email or live chat via the help button on our websites. Alternatively, email firstname.lastname@example.org directly , or write to Werkey Plataforma Digital Ltda., Av. Cezira Giovanoni Moretti, 655, sala 11, Reserva Jequitibá, CEP 13414-157, Piracicaba – SP – Brazil. As part of the CCPA, you may designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent to the email address associated with your account, and it may be necessary to verify your identity and/or that of your agent before the request can be fulfilled.
To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers that have access to it, please see the " Purpose of Your Data " and " With Whom We Share Your Data " sections.
Important: in accordance with the CCPA, Werkey does not sell your personal information or the personal information of any of its users .
As a California resident, you also have the right to request certain details about what personal information we share with third parties for their direct marketing purposes. To submit your request, please contact our Support Team via email or live chat using the help button on our websites with the phrase " California Shine the Light " and include your mailing address, state of residence and email address. Alternatively, send an email directly to email@example.com indicating the same phrase and data mentioned above.
Because the Internet industry is still working on “ Do Not Track ” standards, solutions, and implementations, we currently do not recognize or respond to browser-initiated “ Do Not Track ” signals.
7.2. Nevada Users
As is the case for all users, Werkey does not sell its users' information or personal data . However, if you are a Nevada resident and would like to request that your personal information not be sold, you may ask not to participate in the sale of confidential information. To do this, contact our Support Team via email or chat via the help button on our websites. Alternatively email firstname.lastname@example.org directly , or write to Werkey Plataforma Digital Ltda. Av. Cezira Giovanoni Moretti, 655, sala 11, Reserva Jequitibá, CEP 13414-157, Piracicaba – SP – Brazil.
7.3. Users in Australia
If you live in Australia and would like to make a complaint, please contact the Office of the Australian Information Commissioner ("OAIC"). To contact the OAIC: visit www.oaic.gov.au ; email email@example.com ; call 1300 363 992; or write to GPO Box 5218, Sydney NSW 2001.
7.4. Users outside Brazil
Werkey is headquartered in Brazil, but in order to provide the Services to the user, it is necessary to transfer user data to the United States, Canada, Greece, India and the United Kingdom and process it in these countries. By visiting or using our Services, the user agrees to the storage of his data on servers located in these countries. By using the Services, you agree to the transfer, storage and processing of your data in other countries.
We enter into data processing agreements with our service providers that restrict and regulate the processing of your data on our behalf. By submitting your data or using our Services, you consent to the transfer, storage and processing by Werkey and its processors.
In the event of significant changes to this Policy, we will notify users via email, in-product notices, or other mechanism required by law. Changes will take effect the day they are posted. Please contact us by email or post in case of doubts, clarifications or conflicts.