1. Who we are2. Scope3. The PII we collect4. Our use of PII
5. Protection of PII
6. Third party access to your PII
7. Your Rights
8. Where we store your PII and for how long
9. Minors
10. Amendment of this Privacy Policy
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Privacy Policy

Last updated: October 12th, 2020

1. Who we are

References to "we", "our" or "us" in this privacy policy (“Privacy Policy”) means WCHRS Lda, a private limited company incorporated under the laws of Portugal, with registered address at Rua Mouzinho Albuquerque 744, 2º direito, 4450-203 Matosinhos, Portugal, company number 515561886.

For the purposes of data protection laws, we are the "Data Controller" in respect of the personal information collected through our website located at www.wechangers.org (“Site”). This means we are responsible for how the personal information we receive from you is used.

If you have any matter related to privacy issues, please do not hesitate to contact us at privacy@wechangers.org or contact our Data Protection Officer, Bernardo Janson, at bernardo@wechangers.org.

2. Scope

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your personal data (“Personal Identifiable Information” or “PII”).

Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person (i.e., a human being).

You directly provide us with such PII when you use our Site or services or interact with us by, for example, creating an account or contacting us for support. The PII we collect includes, inter alia, identification data or contact data, login information (account and password) and information depending on how you interact with us. We describe this in detail in point 3 of this Privacy Policy.

This Privacy Policy applies only to our Site and to the PII collected through the services provided in our Site. It does not apply to any third-party website or service linked to our Site or referred in our Site. and does not apply to any other website, product, or service operated by us, or to any of our offline activities.

3. The PII we collect

Our goal is to have a very user-friendly and interesting Site. For this purpose, we need to know what information is most relevant to the Site’s visitors, how often they connect, what browser and device they use, what content is mostly read, what region visitors come from and other similar anonymous demographics and statistics. In order to do so, we automatically collect the following PII from users that visit our Site:

IP address
This is done through the use of cookies that we install on your device so that our Site can remember you and provide you with the information you’re most likely to need, and also to compile statistical anonymous information, if you allow us (please see our Cookies Policy).

When setting up an individual account on the Site, it is mandatory to provide, and we will record, the following PII:

  • name
  • address
  • email address
  • birth date
  • areas of interest
  • Brief pitch/bio about you (this information is intended to be shared on the platform. Please refrain from providing us with any sensitive data. By sensitive data, we mean all and any information about your private life, your health, your political or religious views, your ethnic background and, generally, any information that you would not provide to someone you had just met. If you are under 18 years of age, please ask your parent or guardian before providing us with information)

In addition, you may optionally provide us with, and we will consequently record, the following PII:

  • your image
  • your Linkedin® url
  • your Twitter® url
  • organization where you work
  • information that you want to share in public and private areas of the Site, which may include any videos containing your image and voice ("Submitted Content")

Please make sure you are authorized to share all the information provided to us and be aware that you have total control over the Submitted Content you create and communicate in the Site.

4. Our use of PII

We use your PII for the following purposes and under the following legitimacy grounds:
Please note that if you do not provide us with the data when it is necessary, we may be unable to provide you with access to certain services.

Purpose

How we use the PII

Our legal basis for this use of data

Account set-up to benefit from the services of the Site
To register an account on the Site and to populate your profile.
Note:
Minors under 18 years of age are not allowed to share PII on their profiles (i.e., fields are disabled).
Contractual Necessity (when we need to perform a contract we are about to enter into or have entered into with you).
Statistical analysis

We create anonymous data –through aggregated data - for statistical purposes.
Anonymous data for statistical purposes may be created or derived from the PII we collect, but once in anonymous/aggregated form it will not directly reveal your identity.
When we process anonymous data, there is no need for a legal basis.

Security
We might use the PII that we collect to keep our Site operational and secure, namely, to prevent imminent harm to persons or property.
Our legitimate interest to monitor and ensure the security and the proper operation of the Site, associated systems and services of the Site and to comply with the law .
Sending newsletters and communications to you
Communicate with you about the services we provide.
Your consent
Understanding the way our Site is used and our visitor’s preferences.
Information collected through our cookies (statistical information)
Legitimate interest in controlling the technical operation of our Site.
Please note that we are the owners of the anonymous statistical data related to the use of our Site and may use such anonymous data for other purposes.
Interaction with other users
Information posted by you (Submitted Content) in private areas of the Site.
Note:
We encourage parents to discuss with their children that they should never include PII in reviews or comments posted into the Site.
For minors that register with this Site (13 years to 18 years old), we inform that:
- we will moderate your postings to remove PII that can be dangerous to be shared; and
- we will not post your photograph alongside your reviews or comments.
Contractual Necessity.
Legitimate Interests in respect monitoring the content of children who are under 18 to remove any personal data.
Localization of the user
To collect information related with the country and location you are in when our services are being used by you.
Note:
We will never disclose your location to other people without your consent. For minors, the address field will only allow country & city
Your Consent.

5. Protection of PII

We take PII security very seriously and employ the following data security tools to protect your PII:HTTPS: a protocol for secure communication over a computer network which is widely used on the Internet.

  • HTTPS: a protocol for secure communication over a computer network which is widely used on the Internet. HTTPS consists of communication over Hypertext Transfer Protocol (HTTP) within a connection encrypted by Transport Layer Security or its predecessor, Secure Sockets Layer. HTTPS allows for the authentication of the visited website and protection of the privacy and integrity of the exchanged data.
  • Encryption of passwords
  • Firewalls

Unfortunately, even with these measures, we cannot guarantee the absolute security of PII, namely when faced with sophisticated criminal attempts to access our servers.

6. Third party access to your PII

We give or may give in the future certain independent contractors access to PII ("Data Processors"). No Data Processor will be retained without first entering into contracts in which they agree to protect PII using procedures reasonably similar to ours and will only process PII in accordance with our instructions.

Your PII may be accessed by our employees. Our employees are bound to confidentiality obligations and have been informed of proper PII processing procedures.

We may also, in exceptional circumstances, disclose PII to attorneys and investors bound to confidentiality restrictions and to law enforcement authorities, courts and public regulators, whenever such is required by applicable legislation. Finally, we may share PII in connection with a transaction of all or substantially all of our assets.

All the PII regarding our users is stored on secure servers located within the European Union. We will inform our users if we eventually change our policy in relation to this issue and if we, for some reason, export your personal data out of the EEA, we ensure that adequate safeguards are in place, including that the PII collect from you, will be processed under the EU Commission’s model contracts for the transfer of PII to third countries.

7. Your Rights

Before your account can be activated, you will be required to confirm that you have read and agreed to the Site’s Terms of Use and taken knowledge of this Privacy Policy. If you are a minor in your country, and do not understand something about the content of this policy or your rights, please contact your parent(s) or guardian. You can also ask us with doubts by writing to privacy@wechangers.org.

In relation to your personal data collected by us, you have the following rights:

  • Access: Request access to your personal data: you can access and change any PII we store through “My Account” page or by contacting us directly at the following e-mail address: privacy@wechangers.org. The access and correction of your PII is free-of-charge. You acknowledge, however, that all PII you provide must be accurate and updated.
  • Correction: Request correction of inaccurate or incomplete PII that we hold about you;
  • Erase: Request that we delete or limit the PII we hold related to you;
  • Objection: Oppose, at any time and free of charge, the use of your PII for direct marketing or any other form of commercial use;
  • Portability: Request the transfer of your PII in a portable format, in accordance and within the legal limits;
  • Restriction: Request the restriction of processing of your PII until we address your request to establish its accuracy or our reasons for processing it;
  • Withdraw consent: Withdraw your consent to any processing that relies on it as a legal basis. If you wish to do so after receiving an e-mail or SMS from us, we will provide you with a simple option to opt-out or remove yourself from our marketing directory. A minor’s parents who gave an authorization for the processing of their son/daughter’s PII, have the same right to withdraw the parental consent that had been previously given.

How to exercise those rights?

These rights can be exercised by sending us an email to privacy@wechangers.org.

It is your right to also request that we notify third parties with whom we may have shared your PII and also request that they comply with your instructions.

Please note that the Site is a collaborative project where users contribute with content. If you detect that our Site contains PII that should not be publicly disclosed, including images of yourself or of others, please report this immediately to privacy@wechangers.org.

If you wish, you may file a complaint related to the processing of your personal data to a privacy regulatory body. In Portugal, the entity responsible for enforcing privacy law is Comissão Nacional de Proteção de Dados.

8. Where we store your PII and for how long

We store data until it is no longer necessary to provide our services or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.For example:Your account will continue to be active for three years following your last interaction with our Site, since this is the period of time that we believe may lapse between visits for some users who are interested in the Site.

Prior to closing your account, we will notify you asking if you wish to maintain your account active;The technical data (e.g., IP address) collected when you visit the Site will be retained for 90 days.If you sign up for communications from us, we will keep your information until the withdrawal of your consent.

9. Minors

Adolescents (13 years old to 18 years old) can register on our Site to benefit from our services. We will not knowingly collect, use, or distribute PII from children under the age of 13 and we will not require a minor to provide more information that is reasonably necessary in order to participate in an online activity. We strongly advise minors to never provide any photographs of themselves or of others in their profile.

During the registration process, when we ask for the birth date to determine if the user’s age is under 13. If we determine that it is, it will not be possible to conclude the registration process. For adolescents, we may ask for a parent or guardian email address before we collect any personal information. This email address will be used exclusively to confirm parental consent.

We will not use parents’ emails, provided for parental consent purposes, for commercial communications or other purposes.

Please note that minors can choose if they want to share their information with us, but certain features of the Site cannot function for them, such as:be part of the public communities in the Site (i.e., it is only possible for a minor to search and explore public content disclosed in the public communities); the possibility to start a private conversation with any user, with the exception of conversations with community managers; the ability to talk in private channels without the presence of a community manager; the possibility to share information about their social media or other personal links.

Please also note that the minors can be part of private open channels or groups, but only if the channel is monitored by a community manager.If you believe your child under 13 years of age is participating in the services provided by this Site, please contact us.

10. Amendment of this Privacy Policy

We may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the date it is posted, which will be listed at the top of the page as the Last updated date.

For any clarification regarding our Privacy Policy, please feel free to contact us at privacy@wechangers.org.