1.1. PAPAYYA INC. registered office at 8 The Green STE A, Dover, Delaware 19901, is the entity responsible for the processing of personal data and determines the purposes and means of their processing.
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1.2.  By using the website, application, forms, or any of our services (hereinafter “Services”), you are consenting to the terms described in this Privacy Policy (“Policy”).
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1.3. Without prejudice to the need to read this document, you should also consult the Terms & Conditions that explain our objectives, our mission, and how, through your interaction, we may come into contact with your personal data.

2.1. The National Data Protection Law (Law no. 58/2019, of August 8, hereinafter “LPDP”) and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, hereinafter “GDPR”) ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

2.2. Under the law, personal data means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

2.3. The personal data collected and processed by PAPAYYA INC are those you voluntarily provide to us through the different means of capture when you interact with us through our Services, i.e., through the several  moments of interaction with the user better explained in the Terms and Conditions. However, filling in this information may be necessary to access or obtain certain personalized information or services provided.

2.4. The categories of personal data collected will differ depending on the data subject’s interaction with the Services and their own interests during each visit.

2.5. Under no circumstances will personal data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, or data concerning the data subject’s sex life or sexual orientation be requested, except in occasional situations where such requests may occur, and the data subject has freely and expressly consented to their disclosure. However, for the proper provision of the training services provided by PAPAYYA INC, health-related and genetic data may be requested to fulfill the contractual obligations subscribed to.

2.6. Under no circumstances will PAPAYYA INC provide the personal data you provide to third parties without the prior consent, except in cases necessary to provision the requested services.

2.7. This consent, as you will see, whenever requested for various purposes, will always be free, express, and substantiated by a clear and unambiguous positive act. Nonetheless, we will seek to ensure that the ease with which consent is provided is similar to that of its withdrawal, if desired by the user.

2.8. PAPAYYA INC cannot be held responsible for the introduction of personal data of third parties by the user for the receipt of any commercial contact. You must confirm the correct input of the submitted data or ensure that, if you submit third-party data, they are informed of this Privacy Policy and Terms and Conditions and agree to them and to such submission

2.9. PAPAYYA INC may, however, disclose this data to comply with legal obligations or in the course of subcontracting relationships established for its own purposes, always subject to adequate guarantees, without your authorization.

2.10.  By accepting this Privacy Policy, you give your informed, expressed,  freely, and unambiguous consent for the personal data provided to be included in a file under the responsibility of PAPAYYA INC, whose processing under data protection legislation complies with appropriate technical and organizational security measures.

2.11. PAPAYYA INC thus maintains this database, which will contain the records of users who provide their personal data, which will be collected and processed automatically by PAPAYYA INC and kept in the system solely for the purpose of fulfilling the contractual and legal obligations associated with the service provided.

3.1. PAPAYYA INC processes your personal data for the following purposes:
Provision of the requested training services;
Sending of promotional/marketing communications from PAPAYYA INC.

3.2. PAPAYYA INC, with its Online Training service, may need to collect Sensitive Data (Special Categories of Data), such as Health Data: weight, height, gender, medical, sporting, and dietary history, prior to providing the service. This data will only be requested for the proper provision of the fore mentioned service (Training) and won’t ever be used for any other purpose than the execution of the contract and its related obligations. We will not use this personal data for marketing purposes under any circumstances.

3.3. PAPAYYA INC, with its Online Training service, may also request your full name, date of birth (to ascertain the necessary legal age), taxpayer identification number, and address – because the invoice related to the payment made and related to the Service Provided may be sent. Such a request will have the sole purpose of invoicing the services provided.

3.4. PAPAYYA INC, with its Online Training service, may collect (or subcontract a provider that guarantees this payment process on its behalf) information related to the chosen payment method (such as Card Type and Expiration Date) and other financial data necessary to process your payment.

3.5. PAPAYYA INC, with its Online Training service and its services, may carry out automated decisions, such as profiling, for statistical purposes and to promote its content and services, personalized to the interests and needs of its users and clients.

3.6. PAPAYYA INC may conduct various surveys. If it does, they will be either anonymous or your informed and freely given consent will be requested for them, and they will be deleted as soon as the conclusions of the study are completed, with this data not being used for any other purpose.

3.7. If you consent, we will send you marketing communications and news about products, services, events, and other promotions from PAPAYYA INC that may be of interest to you. After consenting, you may object to this sending at any time.

4.1. To exercise your right of access, rectification, cancellation and opposition, forgetting and portability of your personal data, you can send a written communication to the following email address: “legal@papayya.com”. In this exercise of rights, you must specify your request, which will be promptly attended to within the legal deadlines.

4.2. In the specific case of wanting to exercise the right of opposition by not receiving marketing communications, you can do so at any time by:

5.1. PAPAYYA INC uses appropriate security measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, or access, and against any other unlawfully form of processing, taking into account the current state of technology, the nature of the data stored and the risks to which they are exposed.

5.2. PAPAYYA INC guarantees the confidentiality of the data that may be provided because they are included in a secure server (256-bit SSL) that encrypts/codes them. You can verify that your browser is secured if the padlock symbol appears or the address starts with https instead of http.

5.3. However, since the Internet is not completely secure, we warn you that your personal data may circulate on open networks without security conditions, to which PAPAYYA INC is not related, and cannot be held responsible for any risks of unauthorized access or use by third parties.

6.1. Your data is stored by PAPAYYA INC for the purposes described here, to verify your registration on this website and subscription to our services, as well as to verify the exercise of your rights within the allowable deadlines according to the guidelines of the supervisory entities.

7.1. PAPAYYA INC is not responsible for any acts or omissions of third parties, particularly regarding links to other websites and their content.
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7.2. In the event of a merger, acquisition, restructuring, dissolution or insolvency of PAPAYYA INC, your data may be transferred to third parties as a commercial asset, always in compliance with applicable law and maintaining your rights as data subject, particularly with regards to the consent given and the rights of opposition, access, rectification, erasure, limitation and portability.
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7.3. In case of possible legislative or commercial changes, PAPAYYA INC reserves the right to modify this Policy at any time, so you should consult it whenever you use the Services.
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7.4. For more information, please contact us by email at “legal@papayya.com”.

8.1. In accordance with the law, the data subject has the right to lodge a complaint with the competent control authority on matters relating to the protection of personal data, which, without prejudice to another being identified, will be the National Data Protection Commission (CNPD) www.cnpd.pt.