Website shakenacademy.pt and associated pages
Pursuant to Regulation (EU) 2016/679 of 27 April – General Data Protection Regulation (hereinafter referred to as the GDPR), Law No. 58/2019 of 8 August and Law No. 41/2004 of 18 August, this Cookie Policy aims to provide information on the cookies and similar technologies used on the website operated by Shaken Academy, Unipessoal Lda. within the scope of its training programmes, the process of collection and processing of data carried out through their use, the respective purposes and retention periods, and the manner in which the User may give, manage or withdraw their consent.
The concepts defined in Article 4 of the GDPR are used in this Cookie Policy (hereinafter referred to as the Policy) and have the same meaning as is assigned to them in that regulation.
1. IDENTIFICATION OF THE CONTROLLER OF PERSONAL DATA AND SCOPE OF APPLICATION
1.1 Shaken Academy, Unipessoal Lda., with NIPC 519.187.261, with registered office at Avenida Infante Dom Henrique n.º 143 – 1.º Piso, 1950-406 Lisboa and with the email address dpa@shakenacademy.pt (hereinafter referred to as the Company) is the entity responsible for the collection and processing of the personal data provided by their Data Subjects in the context of the use of the website shakenacademy.pt and of the landing pages operated by it (hereinafter both referred to as the Website), and is intended to inform the User, under and for the purposes of Article 13 of the GDPR.
1.2 Before accessing or browsing the Website operated by the Company, Users must carefully read its Cookie Policy and its Privacy and Data Protection Policy.
1.3 This Policy is supplemented, in respect of any matter on which it is silent, by the Privacy and Data Protection Policy of Shaken Academy.
2. WHAT COOKIES ARE
2.1 Cookies are small text files that a website places on the User’s device (computer, mobile phone or tablet), through the browser, when the User visits it, and that enable the Website to recognise the device on subsequent visits, remember preferences and collect information about the way in which it is used.
2.2 For the purposes of this Policy, the term “cookies” also covers similar technologies with equivalent functions, such as pixels, tags and the browser’s local storage.
2.3 Cookies may be considered “first-party”, when placed by the Company; “third-party”, when placed by other entities whose services are integrated into the Website (for example, statistical analysis tools, social media and advertising platforms or the payment service provider); “session”, when they are deleted on closing the browser; “persistent”, when they remain on the device for a set period.
3. LEGAL FRAMEWORK AND CONSENT
3.1 The cookies used by the Company on its Website are regulated under Article 5 of Law No. 41/2004 of 18 August and, where they involve the processing of personal data, by Regulation (EU) 2016/679 of 27 April (GDPR) and by Law No. 58/2019 of 8 August.
3.2 Cookies that are strictly necessary for the operation of the Website or for the provision of a service expressly requested by the User do not require consent.
3.3 Cookies that are not strictly necessary are only placed on the User’s device after the User’s prior, freely given, specific, informed and unambiguous consent, given through the cookie management panel displayed on first access to the Website, in accordance with Article 6(1)(a) of the GDPR. Accordingly, continuing to browse, scrolling the page or closing the panel does not constitute consent.
3.4 The cookie management panel enables the User to withdraw their consent as easily as it enables them to give it. The Company keeps a record of the consents given and refused, as proof of compliance with Article 7(1) of the GDPR, under the terms and for the periods indicated in the Privacy and Data Protection Policy.
3.5 Refusal of cookies that are not strictly necessary does not restrict access to the Company’s Website or to its essential functionalities.
3.6 The Company’s Website and training programmes are aimed exclusively at professionals who are of legal age. The Company promotes its programmes through campaigns on social media platforms, and the advertising cookies identified in point 4 are used to display those campaigns and to measure their effectiveness.
3.7 The cookie management panel and the record of consents are provided by the Cookiebot tool, from Usercentrics A/S, whose consent cookie falls within the category of strictly necessary cookies.
4. CATEGORIES OF COOKIES USED
- Strictly necessary — essential for the operation of the Website, for secure browsing and for remembering the User’s own cookie preferences, including the browser’s local storage used for the correct display of content and, where applicable, the payment service provider’s security cookies on the pages in which the enrolment and payment form is embedded - do not require consent.
- Statistical or analytical — enable the Company to understand how visitors use the Website (most visited pages, time spent, traffic source, errors), on an aggregated basis, with the aim of improving its operation and its content - are subject to consent.
- Functional or preference — remember the User’s choices (for example, language) in order to personalise the browsing experience. They are subject to consent.
- Advertising or marketing — intended to display targeted advertising or to measure the effectiveness of campaigns. They are placed by the advertising and social media platforms whose measurement tags are integrated into the Website, the responsible entities being identified in point 6 - are subject to consent and are not placed before such consent is given.
5. LIST OF COOKIES
5.1 The complete and up-to-date list of the cookies that may be placed on the User’s device while browsing the Website operated by the Company is published in the cookie declaration embedded in this page and is also accessible from the «Details» tab of the cookie management panel.
5.2 The declaration referred to in the preceding point indicates, for each cookie, the name, the entity that places it, the purpose, the maximum retention period and the category to which it belongs, as well as the date of its last update.
5.3 The list of cookies is generated from a periodic scan of the Website and updated whenever cookies are introduced, changed or removed and, in the event of any discrepancy, prevails over any enumeration contained in other documents of the Company.
6. THIRD-PARTY COOKIES AND INTERNATIONAL TRANSFERS
6.1 Statistical cookies are placed by Google Ireland Ltd. as part of the Google Analytics service. The information collected may be transferred to servers of Google LLC in the United States of America, under the European Commission’s adequacy decision concerning the EU-US Data Privacy Framework and the applicable standard contractual clauses. The service is configured in consent mode (Consent Mode), and the respective cookies are not placed, nor are identifiers collected, before the User’s consent.
6.2 Where the User makes payment for an enrolment, the payment service provider’s cookies are placed by Stripe Payments Europe, Ltd. (Ireland) exclusively for security and fraud prevention purposes, and are governed by Stripe’s privacy policy, available at stripe.com/privacy.
6.3 Advertising and social media cookies and identifiers are placed by Meta Platforms Ireland Limited, through the measurement tag integrated into the Website. The information collected may be transferred to the United States of America under the standard contractual clauses approved by the European Commission or, where the entity is certified, under the European Commission’s adequacy decision concerning the EU-US Data Privacy Framework. These cookies are only placed after the User’s consent.
6.4 The Company does not control the cookies placed by third parties, nor the information collected by them, and their respective privacy and cookie policies apply, which may be consulted on those entities’ websites.
7. HOW TO MANAGE OR WITHDRAW CONSENT
7.1 The User may, at any time, change or withdraw the consent given for the use of non-essential cookies. To withdraw their declarations of consent, the User may do so by any of the following means:
- In the cookie management panel, accessible via the “Manage cookies” link available in the footer of every page of the Website;
- In the browser settings, which make it possible to block or delete cookies or to receive a warning before cookies are placed. The instructions vary depending on the browser and are available on the help pages of Chrome, Safari, Firefox and Edge, as well as at www.allaboutcookies.org;
- For Google Analytics, through the browser add-on made available by Google for opting out of data collection (tools.google.com/dlpage/gaoptout).
7.2 Withdrawal of consent takes effect for the future and does not affect the lawfulness of the processing carried out up to that point, and cookies already placed may be deleted through the browser settings.
7.3 Blocking strictly necessary cookies may compromise the operation of some parts of the Website.
7.4 The preferences expressed by the User are stored for 12 months. At the end of that period, or whenever the list of cookies is materially changed, the cookie management panel is displayed again in order to obtain consent in accordance with point 3 of this Policy.
8. PERSONAL DATA
Where cookies collect information that makes it possible to identify the User, directly or indirectly (for example, unique identifiers or IP addresses), that information constitutes personal data and is therefore processed in accordance with the Privacy and Data Protection Policy of Shaken Academy, available on the Website, which sets out the lawful bases, the retention periods, the recipients and the rights to which Data Subjects are entitled, including the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (Portuguese Data Protection Authority) (www.cnpd.pt).
9. CHANGES TO THE COOKIE POLICY
9.1 The Company may, at any time, amend this Policy, in particular to reflect changes in the configuration of the Website, in the third-party services used or in the applicable legislation.
9.2 Whenever the changes involve the introduction of new cookies that are subject to consent, such consent will be requested again from the User through the cookie management panel.
9.3 The version in force, indicating the date of the last update, is permanently available on the Website operated by the Company.
10. CONTACTS
For any question relating to this Cookie Policy, the User may contact the Company via the email address dpa@shakenacademy.pt or by post at the following address: Avenida Infante Dom Henrique, n.º 143 – 1.º Piso, 1950-406 Lisboa.