Privacy Policy

Updated: 4/8/2022

This Privacy Policy explains what personal information Portuguese Forum Organization companies (“we”, “us”, or “our”) collect, use, share and otherwise process about individuals (“you”) interacting with our Offerings (“Information”). Also, this Privacy Policy does not apply to Digital Services that are online services targeted at children.

Our family of companies is made up of a number of different legal entities and business units. In this Privacy Policy, the Controller or Controllers (“Controller”) of your Information means the company that decides the purposes for which it is processed and how it is processed. Which company is the Controller in relation to the processing of your Information will depend on which Offering you are using; it will often be the company responsible for providing that Offering, as may be set out in our terms and conditions.

In some circumstances, more than one Controller may be responsible for processing your Information, for example, where Information is shared with other companies for a purpose set out in this Privacy Policy.

Under the laws of some countries outside the South African Area, we may need your consent to our processing of your Information set forth in this Privacy Policy. Subject to any indications you may give us to the contrary, such as opting out or not opting in if asked, and where permitted by law, by providing Information or otherwise interacting with our Offerings, you consent to our use of Information in accordance with this Privacy Policy.

SCOPE OF THIS PRIVACY POLICY

Please read this policy carefully. It explains the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us. This Privacy Policy covers both our online and offline data processing activities, including Information that we collect through our various Offerings such as those set out below: 

Digital Services:

• Our websites, including activities run through our websites, such as surveys, research studies, focus group tests, promotions, competitions and prize-draws, purchases within our services, calls to action for user-generated content (“UGC”) and subscribing for newsletters;
• Mobile apps, including activities run through our apps, such as those listed for our websites;
• Our fan pages/channels/accounts on third party social networks (e.g. official pages on Facebook, Instagram, Twitter).

Please note that we may combine Information that we collect via one source (e.g. a website) with Information we collect via another source (e.g. a mobile app), including with Information possibly collected by a one of our companies or a third party (as further described below). Please also note our Offline Services may involve you interacting with our Digital Services and vice-versa, for example, where you book a studio tour or your participation to a marketing event through a one of our websites. Certain Offerings (for example, some branded theme parks, online stores, and in-app purchases) are not operated by us but by a third party licensee or the app store; any processing of your personal information by such a licensee or app store is not subject to this Privacy Policy, so please check carefully whether the relevant terms and conditions refer to additional companies.

THE INFORMATION WE COLLECT

We collect, use, share and otherwise process the following categories of Information:

1)Information we may collect from you:

• Registration, account, and sign-up Information, including information about you when you register or sign up with us for one of our Offerings (e.g. name, username, password, email, contact details, date of birth or age, interest in our content, etc.) 
• Information about your purchase of an Offering, including relevant payment information (e.g. credit card information). We may also process Information about trial periods, redemptions of rewards or promotions, periods without an active subscription, payment history and any missed payments.
• Information about your use of, or participation in an Offering, including information about whether you have opened an email we have sent you, how you (including any account you use) interact with a Digital Service, content that you have viewed or posted, advertisements you have interacted with, games you have played and the level you reached, your preferences and interest in and use of various features, programs, services and content available on a Digital Service. This may also include demographic information, including at an individual or household level.
• Information you provide when participating in consumer surveys, research studies or focus group tests, including online or written replies and where applicable the recording of your audio or video interviews.
• Entries to promotions, competitions, prize-draws or calls to action, including images, videos and text.
• Camera access, including where for some Digital Services, we ask for permission to access your device’s camera. If you grant permission, you may be able to take pictures or video within the app experience, to send them to us, or to access certain augmented reality (“AR”) features. Some of these features may rely on camera systems to track movements of your eyes and other facial features or your immediate surroundings to apply AR effects.
• Sensitive data, including where you choose to share Information as part of one of our Offerings, or where you provide Information during one of our surveys or feedback sessions, including, where permitted by applicable law, information relating to your physical or mental health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, or your political beliefs. In some Offerings that include dynamic entertainment features, we may with your consent and in accordance with applicable law, collect information such as via facial scanning, eye tracking, or skin response that may be considered biometric.
• Information about your social media engagement, including your interactions with our fan pages/channels/accounts in third party communities, forums, and social media sites, services, plug-ins, and applications (“Social Media Sites”). This may include posts, your ‘likes’ and other user-generated content that you may provide, as well as details about yourself such as your name, user ID, profile photo, birthday, and, where you allow us to, lists of friends and people you follow. For information about how you can customize your privacy settings on Social Media Sites, and how those Social Media Sites handle your personal information and content, please refer to their privacy help guides, privacy policies, and terms of use.
• Information shared on public or community forums, including where you share photos, letters, videos or comments, while participating in online forums. Depending on your privacy settings, this Information or content and your username may become public on the Internet or within a community of users. We cannot prevent further use of this Information once you share it in a publicly available or community forum. Please refer to the specific forum’s privacy policies for further information on how they handle your Information. 
• Information about your location, including where it is derived from device information (such as an IP address or country code), your device’s interactions with our Digital Services, or, with your consent, Information about your device’s precise location (e.g. geolocation via mobile devices).
• Event Information, including images and clips, whether captured via a booth or by other means by us or a third party on our behalf, and other Information relating to the organisation and management of an event, such as food allergies and other individual requirements. 
• Technical/usage Information from your device, including the type of device, browser, unique device identifier, operating system, internet provider, mobile device identifier and/or mobile advertising identifier, connected device identifier (including that of a connected television), IP address, network attributes, television device and application attributes and settings, and other device or browser attributes and settings. 
• Information about your customer queries, including when you contact us through one of our customer helpdesks, email addresses, customer service chat boxes, forms or ticketing systems, Social Media Sites and customer call-centres, where calls may be recorded. 

2)Information we may collect about you, from other sources, including friends:

Information from other sources. On occasion, we combine Information with other online information we receive, including usage information about your interactions with other websites and with online advertising and media. We also supplement or combine Information with Information from a variety of other sources or outside records, including third-party data providers that provide us with Information such as demographics, transaction and purchase history; Information about the content and advertisements you interact with. We may also receive Information about you from your friends who invite you to interact with any of our Digital Services. We may receive Information from third parties with which you have a subscription agreement that includes access to our content or services.

Information from friends. In certain situations, we may enable friends using our Offerings to provide Information about you. For example, someone can submit Information on our websites to invite you to participate in an Offering, make recommendations or share content through one of our apps, or have multiple players sharing the same game session. By processing these requests, we may receive your Information, including your name, contact details, or information about your interest in and use of our Offerings. 

Providing Customer Services 

We may use your Information for the purpose of providing Customer Services, including dealing with your queries and complaints (including troubleshooting), whether you contact us by telephone, email, chat boxes, forms or ticketing services, letter, website or via a Social Media Site.

In countries where our processing of Information requires a lawful basis, we rely upon the following:  

• Some types of processing activities will be necessary for us to perform our contract with you to provide an Offering. 
• Some types of processing activities will be necessary to comply with our legal obligations.
• Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Responding to our customer queries and complaints;
  • Tracking the progress and effectiveness of our response; and
  • Improving our Customer Services.

Detecting, preventing and investigating criminal and other illegal activities

We may use your Information for the purpose of detecting, preventing or investigating criminal activities (including fraud and copyright infringement), protecting user safety and enforcing our civil rights in the courts. For example, where necessary, we may share your Information with law enforcement bodies or use it to take legal action against you to enforce our rights.

In countries where our processing of Information requires a lawful basis, we rely upon the following:  

• Some types of processing activities will be necessary to comply with our legal obligations.
• Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Protecting our business interests and rights, privacy, safety and property, or that of our customers and users;
  • Establishing, exercising or defending legal claims; 
  • Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain.

Compliance with legal obligations 

We may use your Information for the purpose of complying with our legal obligations, including accounting rules, responding to Individual Rights Requests and responding to requests from regulators, judicial authorities and law enforcement or governmental bodies.

In countries where our processing of Information requires a lawful basis, we rely upon the following:

• These types of activities are necessary to comply with our legal obligations.

DATA RETENTION

In broad terms, we will only retain your Information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of Information and the reason that we have collected the Information in the first place. For example, some Information related to the provision of our Offerings to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of Information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defence of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.

COOKIES AND OTHER TECHNICAL INFORMATION

When you visit our Digital Services, we, third party service providers, and partners may use “cookies” or similar technologies, such as pixels and SDKs to (i) provide, develop, maintain, personalize, protect, and improve our Digital Services and their content (ii) perform analytics, including to analyse and report on usage and performance of our Digital Services and any advertisements displayed on or delivered by or through them (iii) protect against, identify, and prevent fraud and other unlawful activity (iv) create aggregate data about groups or categories of our users (including advertising audiences), and (v) for us, our partners and third party service providers to deliver, target, offer, market, or personalise advertising relating to our Offerings or the offerings of our clients and partners (including limiting how often you see an advertisement). 

Cookie Description 

1. Required cookies 

These cookies are required to enable core website functionality 

Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our Digital Services and use their features, such as accessing secure areas. If you disable these cookies, some or all of the Digital Services’ features may not work. 

2. Performance cookies 

These cookies allow us to analyze usage of our Digital Services so we can measure and improve performance 

Performance cookies or similar technologies: They collect information about how you use our Digital Services, so that we can analyze traffic, understand users’ interactions, and improve the relevant Digital Service. Our emails and newsletters may contain a ‘web pixel’ to let us know how you have interacted with what we have sent you. For games, these technologies collect information about your gameplay, including accomplishments, use of features and other in-game activities. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. You can find out more information by clicking on the Google Analytics cookies usage resource link: https://tools.google.com/dlpage/gaoptout?hl=en 

3. Functionality cookies  

Functionality cookies or similar technologies: These allow our Digital Services to remember choices you make (such as your username or the region you are in) and provide enhanced, more personalized features, including personalized content. They may also be used to provide Digital Services you have asked for, such as watching a video or commenting on a blog. 

4. Advertising cookies 

These cookies are used by advertising companies to serve ads that are relevant to your interests 

Social media cookies or similar technologies: These are used when you share Information using a social media sharing button or ‘like’ button via our Digital Services, or when you link your account or engage with our content on or through a Social Media Site, such as Facebook or Twitter. The Social Media Site will record that you have done this, and this Information may be linked to targeting/advertising activities, including building custom audiences. 

Advertising cookies or similar technologies: Some of our Digital Services may use a third-party advertising network, or an affiliated company, to deliver targeted advertising. They may also have the capability to limit the number of times you see an advertisement and track your browsing or usage across our Digital Services and Social Media Sites.  

Managing cookies and other technologies. For Digital Services in some jurisdictions, including the EEA, you may learn more information about our use of cookies and other technologies, and provide or withdraw consents, or set your cookie preferences and in some cases object legitimate interest purposes for processing your personal information, by clicking Manage Cookies+ or otherwise adjusting cookie preferences. These settings are accessible on a site or app specific basis, at any time through the ‘Manage Cookies+’ link or a similar link located on webpages or in application settings. You may also use your app/browser settings to set your cookie preferences. 

For many Digital Services in the EEA, we participate in the IAB Europe Transparency & Consent Framework, which is described in more detail by navigating to the IAB’s website, and complies with its specifications and policies on applicable websites and apps. OneTrust operates the consent management platform with the identification number 28. 

Marketing communications. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences, you can (i) log in to an account you may have created with us to adjust your settings (where the feature is available) or (ii) otherwise submit a request by navigating to our Individual Rights Request Portal. You can also follow the ’unsubscribe’ instructions provided in any marketing email you receive.

Ad choices. On our own or working with affiliates or third parties, we may present advertisements and engage in data collection, reporting, ad response measurement, and site analytics on our Digital Services and on third party websites across the Internet and applications over time. We, our affiliates, or third parties may use cookies, web beacons, pixels, SDKs, or similar technologies to perform this activity. They obtain information about applications you use, websites you visit, and other information from across your devices and browsers and across websites, services, and apps over time, in order to help serve advertising that will be more relevant to your interests on and off our Digital Services and across your devices and browsers. This type of advertising is known as ‘interest-based advertising’. We, our affiliates, or third parties may also use this information to associate your different browsers and devices together for interest-based advertising and for other purposes like research, analytics, internal operations, fraud prevention, and enhancing consumer experiences.

NOTIFICATION REGARDING UPDATES

From time to time, we may update this Privacy Policy. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you are up to date.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, you can contact us and our Data Protection Officer at info@portugueseforum.org.za

COMPLAINTS

If you are unhappy with how we have dealt with your query, in the first instance please contact us at info@portugueseforum.org.za. If you are still unhappy with our response, you may have the right to complain to your Data Protection Authority. Please contact us at info@portugueseforum.org.za to obtain details of how to contact them.