Pursuant to Article 79 of the Civil Code, Regulation (EU) 2016/679 of 27 April - General Data Protection Regulation of the European Union, Law No. 58/2019 of 8 August and Law No. 34/2013 of 16 May, this Image Rights Policy (hereinafter referred to as the Policy) establishes and governs the terms and conditions for the assignment, use, collection and processing of the image rights granted to Shaken Academy, Unipessoal Lda. (hereinafter referred to as the Company) by their holders, within the scope of the training programmes developed and delivered by it (hereinafter referred to as the “Programme”, a term which covers any training programme developed and delivered by the Company, namely AI Dive for Business and MBAI).
1. OBJECTIVE OF THE POLICY AND CONTROLLER FOR THE PROCESSING OF IMAGE RIGHTS
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, is the entity responsible for the collection and processing of the image rights assigned and granted by their holders (hereinafter referred to as User or Users) for the purposes indicated in point 2 of this Policy.
1.2. This Policy is intended to inform the User of the terms and conditions relating to image rights and applies to the collection of consent and authorisation for the assignment of the use of the image rights granted to the Company, through the registration forms for the Programme, available on its websites and landing pages or made available to participants, including to employees of client entities that contract the Programme.
1.3 The User must read this Policy carefully and decide freely whether they wish to assign the use of their image rights to the Company, prior to assigning them.
2. PURPOSES AND OBJECTIVES FOR THE COLLECTION OF IMAGE RIGHTS
2.1 Any image captured is collected, processed and used exclusively within the limits of the Programme and of the Company’s other training activities, and may only be used for the following purposes and in the following contexts:
- For promotional, advertising and educational purposes in respect of the Company's activities, initiatives and events;
- For the purposes of formalising the registration process and managing the User's participation in the programme, activities, initiatives and events of the Company;
- For security purposes in and of the Company's premises;
2.2 The User acknowledges and accepts that the disclosure referred to in the preceding point may take place through the following channels and to the following recipients: (i) the Company’s websites, social media profiles and institutional materials; (ii) media outlets; (iii) institutional partners of the Programme and, in editions contracted by client entities, the respective client entity; (iv) participants, trainers and workers of the Company, within the scope of the programme’s activities, always for the sole purpose of promoting the programme, activities, initiatives and events of the Company.
The Company exercises no control over the subsequent use that such entities or persons may make of the images after their disclosure.
2.3 The Company accepts no responsibility for the capture, use, reproduction, editing and disclosure of the User’s image, voice and video which is collected without the express authorisation of the Company and outside the scope of this Policy.
2.4 For the purposes of the security of the Company’s premises, namely for the protection of persons and property, images of Users will be collected by a CCTV video surveillance system, when sessions take place at the Company’s facilities, pursuant to Law No. 34/2013 of 16 May, which regulates private security activity, Law No. 58/2019 of 8 August – Personal Data Protection Law and Regulation (EU) 2016/679 of 27 April - General Data Protection Regulation of the European Union (hereinafter referred to as the GDPR).
2.5 Pursuant to the preceding paragraph, the images will be collected and processed exclusively by the Company’s own surveillance and security system, duly accredited under the applicable legislation in force, and for the sole purpose of ensuring security and protection in and of the Company’s premises.
2.6 The processing of images through a video surveillance system is based on the Company’s legitimate interest in the protection of persons and property, pursuant to Art. 6(1)(f) GDPR, and does not depend on the User’s consent, the images being retained for a period of 30 days, pursuant to Article 31(2) of Law No. 34/2013 of 16 May and Article 19 of Law No. 58/2019 of 8 August.
2.7 The processing of images for the purposes set out in point 2.1, subparagraphs (a) and (b), is based on the User’s consent, pursuant to Art. 6(1)(a) GDPR and Article 79 of the Civil Code, and may be revoked at any time in accordance with point 5.4 of this Policy.
3. AUTHORISATION AND ASSIGNMENT OF THE USE OF IMAGE RIGHTS
3.1 A User who accepts the terms of this Policy and authorises the assignment of image rights grants the Company the right to capture, use, reproduce, edit and disclose their image, obtained by any means, including photographs, voice and video, in the context of the Company’s programme, activities, initiatives and events, provided that it is used exclusively for the purposes and objectives described in point 2.1, subparagraphs (a) and (b), of this Policy.
3.2 The authorisation of assignment given by the User further permits the said images and recordings to be archived and reproduced in part or in full, always within the purposes and limits described in the preceding points.
3.3 Under the terms of the authorisations and consents referred to in the preceding points, the User understands and accepts that no consideration or remuneration is due to them and that, as such, they will not claim any payments or credits arising therefrom.
3.4 The User authorises the capture, use, reproduction, editing and disclosure of their image to take place through the following channels and to the following recipients: (i) the Company’s websites, social media profiles and institutional materials; (ii) media outlets; (iii) institutional partners of the Programme and, in editions contracted by client entities, the respective client entity; (iv) participants, trainers and workers of the Company, within the scope of the programme’s activities, always for the sole purpose of promoting the programme, activities, initiatives and events of the Company.
3.5 For the purposes of the preceding paragraphs, any image which is collected without the conditions of this Policy and/or any applicable legal provision in force having been met shall be immediately deleted by the Company.
3.6 The authorisation of assignment given by the User is personal, free and autonomous, and may not be given by the client entity on behalf of its employees, and refusal to give it does not condition registration for, or participation in, the Programme.
4. RETENTION PERIODS AND ARCHIVING OF IMAGES
4.1 Images collected under this Policy are archived for a maximum period of 8 (eight) years from the date on which they were captured or until the revocation of the authorisation and consent given by the User, after which they will be deleted.
4.2 Revocation of the authorisation and consent referred to in this Policy takes effect for the future and does not affect the lawfulness of the use and disclosure of the images carried out under the authorisation previously given.
4.3 In the event of revocation of the authorisation, the Company ceases using the images and takes steps to remove them from the communication channels under its direct control, namely websites and its own social media profiles.
4.4 The User acknowledges that images already published or distributed on physical media, in promotional materials already produced, or by third parties under point 2.2, remain on those media, and that it is not technically possible to ensure their removal.
5. RIGHTS OF THE HOLDER OF THE IMAGE RIGHTS
5.1 The Company guarantees the defence of all the rights of Users relating to the protection of their personal data and image rights, in accordance with the legislation in force.
5.2 The User has the right to request from the Company access to the images collected which concern them; their rectification; their erasure; restriction of processing; objection to processing; and the right to their portability, under the terms of the legislation governing the processing of personal data, as applicable.
5.3 The use of the image rights assigned to the Company may only be accompanied by the name or other identifying element of the User if the User expressly authorises it.
5.4 Without prejudice to the provisions of points 2.4 and 2.5, the User has the right, at any time, to revoke their authorisation and consent regarding the assignment of the image rights granted for promotional, advertising and educational purposes in respect of the Company’s activities, initiatives and events.
5.5 Pursuant to the preceding paragraphs, the User’s rights must be exercised via the following email address: dpa@shakenacademy.pt.
5.6 In such contact, the User must, in any case, send a copy of a document proving their identity (avoiding, where possible, sending a copy of their citizen card), specifying the right or rights they wish to exercise.
5.7 The User has the right to lodge complaints with the supervisory authority (Comissão Nacional de Proteção de Dados (Portuguese Data Protection Authority) - https://www.cnpd.pt/), when dissatisfied with the way in which their personal data is processed.
6. PRIVACY AND DATA PROTECTION POLICY
The Company’s Privacy and Data Protection Policy applies to all images, videos and sounds which are collected under this Policy
The version of this Image Rights Policy currently in force was published on 14 October 2026.