Werkey Terms and Policies

Privacy Policy

This Privacy Policy was updated on July 2, 2021.

Werkey Plataforma Digital Ltd. (“Werkey”, “we”, “the Company”) respects the privacy of users and wants everyone to understand how user data is collected, used and shared. This Privacy Policy covers our data collection practices and the user's rights to access, define or restrict the Company's use of their personal data. Unless we link to another policy or otherwise state, this Privacy Policy applies when you visit or use Werkey's website, mobile applications, APIs or related services (“Services”).

1. Types of Data Collected

We collect data directly from users, such as information entered by the user, data about the user's participation in courses and data from third-party platforms with which the user connects with a Werkey. We also collect certain data automatically, such as information about the user's device and which parts of our Services the user interacts with or uses.

1.1. User provided data

We may collect different data about you, or provided by you, according to 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 data you provide directly, including:

1.1.1. account details

To use certain features (such as enrolling in a course), you must create a user account. When the user creates or updates their account, we collect and store the data provided, such as email address, CPF, password, gender and date of birth.

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, social media profiles 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, 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 you enroll in a course, we collect certain data, including which courses, assignments, and tests the user initiates and completes, exchanges information with content providers (including instructors, platform administrators, and teaching assistants) and other students, and essays, answers to questions, and other items submitted to satisfy course requirements.

1.1.5. Student payment data

When the user makes purchases, we collect certain data about the purchase in question (such as name, email, address, CPF or CNPJ of the user) when necessary to process the order. You are responsible for providing certain payment and invoice data 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 cardholder data, such as full credit card number or authentication data.

1.1.6. Data about payments from content providers or affiliates

If you are a content provider or affiliate, you may link your PayPal or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including the payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include information about your residency, tax identification numbers, biographical information and other personal information necessary for tax purposes. The collection, use and disclosure of your payment, billing and taxation data is subject to the Privacy Policy and other terms of your payment account provider. As an alternative to using the aforementioned means of payment, we may make payments directly to the bank account of content providers or affiliates. The banking information collected will be kept confidential and under no circumstances will it be shared with third parties.

1.1.7. 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 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 your username, profile picture, account ID number, login email address, location, physical location of your login 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

We may invite you to conduct a survey or participate in a promotion (such as a contest, sweepstakes or challenge), whether through the Services or a third-party platform. If you participate, we will collect and store data that you provide as part of your participation, such as your name, email address, date of birth or telephone number. Such data is subject to this Privacy Policy, unless otherwise stated in the official promotion rules 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 prizes, we may need to obtain the user's permission for us to publish some of their information publicly (such as on the winners page). When we use a third party platform to administer a survey or promotion, that third party's Privacy Policy will apply.

1.1.9. communications and support

If you contact us for support or to report a problem or question (regardless of whether you have created an account), we collect and store your contact information, as well as messages and other data about you, such as your name, address email address, location, operating system, IP address and any other data that you provide or that we collect by automated means (discussed below). This data will be used to answer the user and research the question presented, in accordance with this Privacy Policy.

The data listed above is stored by Werkey and associated with the user's account.

1.2. User data is collected by automated means

1.2.1. 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 ("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 the Service, pages visited, resources used, search queries, click data, date and time, and other data related to the use of the Services. 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's account.

2. User Data Collection Method

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

Werkey and service providers acting on Werkey's behalf (such as Google Analytics and third party advertisers) use server log files and tools for automated collection of data such as cookies, tags, scripts, custom links, devices or browsers and web beacons (collectively, “Data Collection Tools” ), when you access and use the Services. These data collection tools automatically track and collect certain system data and usage data (detailed in Types of Data Collected ) when you use the Services. In some cases, we associate data collected through data collection tools with other data we collect, as described in this Privacy Policy.

We use cookies (small files that websites send to a user's device to uniquely identify a user's browser or device, or to store data on a user's browser) to analyze use of the Services, personalize the user experience, facilitate connection to the Services and recognize the user when they return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the Services) to identify whether a page has been visited, identify whether an email has been opened, and more effectively advertise by excluding current users from certain messages. promotions or identifying the source of a new mobile application download .

2.2. Werkey uses the following types of cookies

Preferences: cookies that remember data about the user's browser and preferred settings that affect the appearance and behavior of the Services (such as the user's preferred language).
Safety: cookies used to allow the user to log in and access the Services, protect against fraudulent access, and help detect and prevent abuse or unauthorized use of the user's account.
Functional: cookies that store functional settings (such as the volume level set for video playback).
Session status: cookies that track user interactions with the Services to help us improve the Services and user browsing experience, remember user login details and enable the processing of user course purchases. These are strictly necessary for the Services to function properly. Therefore, if the user disables them, certain features will not work or become unavailable.

The user can configure the web browser to alert him to attempts to insert cookies on the 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.

Some third party partners who provide certain features on our website may also use local storage objects (also known as flash cookies or LSOs) to collect and store data.

2.3. Analysis

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 user's third-party website, the frequency of 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 information that may be of interest to you.

2.4. online advertising

We use third party advertising services such as Facebook, Google ad services and other ad networks and servers to provide advertising about our Services on other websites and applications used by the user. Ads may be based on known information about the user, such as the user's usage data and system data (detailed in Types of Data Collected ) and information that 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 these tracking technologies to serve you personalized advertisements. To help deliver personalized advertising, we may provide service providers with an anonymized, hashed version of the user's email address (in human-readable format) and the content that the user publicly shares on the Services.

When using mobile applications, the user may also receive personalized in-application advertisements. Apple iOS and Android OS provide their own instructions on how to control personalized in-app ads. For other devices and operating systems, please review the privacy settings or contact the operator of the user's platform.

3. 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 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 user requests and orders for specific courses, products, services, information or features:
Communicate with the user about their account:

Send messages and administrative information, including messages received from instructors and teaching assistants, notifications of 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 from the mobile app's "options" or "settings" page).

Facilitate the technical operation of the Services, including troubleshooting, protecting the Services, and preventing fraud and abuse;
Publicize 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;
As 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 certain user data with content providers, other students, companies that provide services to Werkey, our business partners, analytics and data 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 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.

We may share User Data with third parties in the following circumstances or when otherwise described in this Privacy Policy:

With Content Providers: We share data about you with instructors or teaching assistants for courses you enroll in or request information about, so they can improve courses for you and other students. This data may include the user's city, country, browser language, operating system, device settings, the website that brought the user to Werkey and the user's activities on Werkey. 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 course pages they offer to track traffic sources on courses and optimize course pages.
With other students and content providers: Based 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, according to the user's settings.
With service providers, contractors and representatives: We share user data with third party companies that provide services for 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 it 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. According to 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 on usage (detailed in Types of Data Collected ) or de-identified data, as needed. Unidentified data means data from which information such as the user's name and email address has been removed, which is 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 goal 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 social login or 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 are visiting, and set a cookie to enable the feature. User interactions with these features are governed by the third party's Privacy Policy.
To administer 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 entries) or in accordance with the promotion or survey rules.
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 ? data to deliver targeted ads to personalize the user experience (through behavioral advertising) and perform web analytics . Advertisers may also share the data they collect about the user with us. To learn more or opt out of behavioral advertising of participating ad networks, please refer to the " User Choices Regarding Use of Your Data " section in the " User Rights? ". It is worth mentioning that, by choosing not to participate, 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 believe, in good faith, that the disclosure is:

Permitted or required by law;
Requested as part of a judicial, governmental or legal order or process investigation;
Justifiably necessary as part of a valid subpoena, warrant or other legally valid request;
Justifiably 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 Werkey, our users, employees, members of the public or our Services.
We may also disclose user data to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

In cases of transfer of control: if Werkey enters into 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 User Permission: With User Consent, we may share data with third parties outside the scope of this Privacy Policy.

5. Security

We use adequate security based on the type and confidentiality 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 protect the password or contact us in case of suspected unauthorized access to your account.

Werkey adopts adequate security measures to protect 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% secure. Therefore, we cannot guarantee that communications between you and Werkey, the Services or any information provided to Werkey in connection with data collected by us through the Services will be 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. If you suspect a password or account violation, change it immediately and contact our Support Team via email or chat via the help button on our websites to remedy the situation. Alternatively, email us directly to support@werkey.co .

6. Users' Rights

You have certain rights regarding the use of your data, including the ability to opt out of promotional emails, cookies and the collection of data by certain analytics service providers. The user may update or terminate their account within our Services and also contact us to clarify questions regarding individual rights over their 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 choices regarding the use of your data

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

The user can opt out of receiving promotional communications. For this purpose, you can use the unsubscribe mechanism, in the promotional communication you receive, or change the email preferences of the user's account. Please note that regardless of your email preference settings, Werkey will send you transaction and relationship messages related to the Services, including administrative confirmations, order confirmations, important Services updates, 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 may also allow you to control the collection and sharing of location or other data. User can manage their cookie preferences via the cookie banner on Werkey websites, or send an email to support@werkey.co .
For information and to control the cookies used for personalized advertisements from participating companies, consult the consumer service 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 Google display advertising 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 page with instructions for opting out of Google Analytics .

If you have questions about rights, data and the way in which 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 a message via email or chat with the request.
Note: Even after the account is closed, some or all of the user's data will still be visible to others, including but not limited to data that has been (a) copied, stored or disseminated by other users (including in course comments) ; (b) shared or disseminated by you or others (including in your shared content); or (c) published on a third party platform. Even after your account is closed, we will retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including assisting with legal obligations, resolving disputes and enforcing our contracts. We may retain and disclose such data in accordance with this Privacy Policy after your account has been terminated.

To request access, correct or delete personal data, please contact our Support Team via email or chat via the help button on our websites. Alternatively, email us directly to support@werkey.co or write to Werkey Plataforma Digital Ltd. (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 user protection, we may ask that the request be sent to the email address associated with the user's account. You may need to confirm the user's identity before implementing the request. It is worth mentioning that we retain certain data when we have the right to do so, including in the case of mandatory record keeping and in order to carry out transactions.

6.3. Our Policy towards 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 the age of 16 in the European Economic Area) must not use the Services. If we become aware that we have collected personal data from a child below these ages, we will take 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 via email or chat via the help button on our websites, requesting removal of the data. Alternatively, they may email directly to support@werkey.co .

7. Specific Rules for each Jurisdiction

If you reside in California, you have certain rights relating to accessing and deleting your data, as well as knowing with whom we share your data. If you reside in Australia, you have the right to file 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 learn more about the categories and specific personal information we collect about you, as well as access a copy of your personal information.
"Right to Delete" — You have the right to request that the personal information we collect about you be deleted.
"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 you exercising your rights under the CCPA.

To exercise any of your rights under the CCPA, please contact our Support Team via email or chat via the help button on our websites. Alternatively, email us directly to support@werkey.co , or write to Werkey Plataforma Digital Ltda., Av. Cezira Giovanoni Moretti, 655, room 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 the request to be sent to the email address associated with your account, and it may be necessary to verify your and/or your agent's identity before the request can be placed.

Additionally, to learn more about the personal information we collect and how we collect it, please see the sections " What Data We Collect " and " How We Collect Data About You ".

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 " Who 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 chat via 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, email directly to support@werkey.co indicating the same phrase and data mentioned above.

As the Internet industry still works on the basis of “ 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' personal information or data . However, if you are a Nevada resident and would like to request that your personal information not be sold, you can ask not to participate in the sale of confidential information. To do so, contact our Support Team via email or chat via the help button on our websites. Alternatively send an email directly to support@werkey.co , or write to Werkey Plataforma Digital Ltda. Av. Cezira Giovanoni Moretti, 655, room 11, Reserva Jequitibá, CEP 13414-157, Piracicaba – SP – Brazil.

7.3. Users in Australia

If you reside in Australia and would like to file a complaint, please contact the Office of the Australian Information Commissioner ("OAIC"). To contact the OAIC: visit www.oaic.gov.au ; email enquiries@oaic.gov.au ; 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, you consent to the storage of your data on servers located in these countries. By using the Services, you consent 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.

8. Privacy Policy Updates and Contact Information

In the event of material changes to this Policy, we will notify users via email, in-product notices, or other mechanism required by law. Changes will take effect on the day they are posted. Please contact us by email or post if you have any questions, clarifications or conflicts.

8.1. Modifications to this Privacy Policy

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

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 acceptance of the revised Privacy Policy (and agreement to follow and be bound by it). if to her). The revised Privacy Policy supersedes all previous Privacy Policies.

8.2. Interpretation

All capitalized terms not defined in this Policy are defined as specified in the Werkey Terms of Use . Any version of this Privacy Policy in a language other than Portuguese is provided for convenience. In case of conflict with a version not written in Portuguese, the user agrees that the Portuguese version will prevail.

8.3. Doubts

If you have any questions, clarifications or conflicts regarding our Privacy Policy, please contact our Support Team via email or chat via the help button on our websites, or write a message directly to support@werkey.co . Alternatively, you can send a correspondence to Werkey Plataforma Digital Ltda. at address: Av. Cezira Giovanoni Moretti, 655, sala 11, Reserva Jequitibá, CEP 13414-157, Piracicaba - SP - Brazil.