Fakedoor's
Privacy Notice

We Fake Door Unipessoal Lda. (“FakeDoor”, “we”, “us” or “our”) respect your privacy and are committed to keeping secure any information we obtain from you or about you in connection to our platform (“Services”). This Privacy Notice is meant to help you understand what information we collect, how we use it and how you can manage your data.

1. What Types of Personal Information We Collect

We collect the following types of personal information about you (“Personal Information”):

Leads (“Visitors”):

• Identity Information (if provided by you): name, age, email address and location (country).
• Technical Information: includes data such as login data, pages visited and when they were visited.

Clients (“Users”):

• Identity information: includes full name, date of birth, country and username.
• Contact Information: includes email address and phone number.
• Billing Information may include taxpayer number, billing address, bank account and credit card information (the last being collected directly by our payment services provider – Stripe).
• Study Progress Information: includes exercises solved, results, number of hours studying subjects, topics completed, type of questions, average test results, score percentages, number of hours spent on the platform, time spent on each question, and how many mistakes were made.
• Technical Information: includes data such as login data, pages visited, and when they were visited.

Parents or Legal Guardians:

• Contact Information: includes name and email address.
• Billing Information: includes taxpayer number, billing address, bank account and credit card information (the last being collected directly by our payment services provider – Stripe).
• Technical Information: includes data such as login data, pages visited and when they were visited.

2. How We Use Personal Information

We use your Personal Information for the following purposes:

• Providing the Services: we use the Personal Information you give us to provide the Services to you. This includes letting you log in to FakeDoor, keeping the Services running, giving you access to your account page, informing you when new services are available and billing you or your parent/legal guardian for the Services chosen. We also remember information about you automatically so that you do not have to type it in every time you visit FakeDoor.
• Communicating with you about our Services: We may send administrative messages and information about changes to the Services or updates on our Privacy Notice and Terms and Conditions. We may also send you surveys or invites to take part in surveys to understand your level of satisfaction with the Services and gather feedback.
• Responding to customer support questions: we use your Personal Information to resolve technical issues you experience with the Services and to ensure that we can repair and improve the Services for all Users.
• Verifying your identity when you contact us.
• Improving the Services: We analyse information about your use of our Services to better understand how Users are engaging with our Services and measure the effectiveness of the Services so we can make improvements and develop our services.
• Providing support analytics to you: we may analyse your Personal Information to give you personalised feedback on your study progress.
• Personalising our Services to you: we may use the information you provide us and the information that we collect about other users to make sure that your use of the Services is customised to your needs.
• Security measures: to monitor activity we think is suspicious or potentially fraudulent, and to identify violations of our Privacy Notice or Terms and Conditions.
• When required by law: FakeDoor will use or disclose your Personal Information where we reasonably believe that such action is necessary to comply with the law and the reasonable requests of law enforcement and also to enforce our Terms and Conditions or to protect the integrity of our Services.

3. Our Lawful Basis for Processing Personal Information

FakeDoor processes Personal Information from its Visitors in the following ways:

• Consent: We process Personal Information (i.e. browsing information) based on the consent of our Visitors and we might schedule a quick call with you to gather your feedback on your use of the platform (only if you consent to it).
• Legitimate Interest: We process Personal Information (contact details) to communicate product news, to provide information about free trials or to send consumer surveys or invites to participate in surveys, aligning with our legitimate interest.

FakeDoor processes Personal Information from its Users or their Parents/Legal Guardians in the following ways:

• Contractual Relationship: Personal Information processing is done as part of our contractual relationship with Users or during the preliminary steps before entering a contract.
• Legitimate Interest: Our legitimate interest in processing Personal Information includes providing services (i.e. responding to inquiries, sending product information, offering customer support or personalising our website in the most effective manner for our Users); monitoring and analysing usage and activities in connection with our Services to improve it; manage our internal operations (i.e. conduct troubleshooting, data analysis and research) and keep our website secure.
• We may also process Personal Information where we need to comply with a legal or regulatory obligation. Please note that if you do not provide us with the necessary Personal Information mentioned above, we may be unable to enter into or fulfil a contract with you.

4. How Personal Information Is Shared

FakeDoor might share certain Personal Information with other service providers. Those providers are regarded as “Processors”. They will only have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to reveal it or use it for other purposes. The processors we rely on comply with the necessary data protection laws’ standards. You can find below the list of our current Processors:

• Stripe: Payment Services
• Google: Authentication/Authorisation Services and Analytics Services
• Microsoft: Authentication and Authorisation Services
• PHC Go: Accounting Services

Unless essential for the purposes for which the Personal Information was collected, we may only provide these third parties with aggregated or de-identified information about you.

We may also share some Personal Information with the competent authorities when required by law, regulations or a decision of a competent regulatory or judicial authority. We don’t sell your Personal Information.

5. Your Rights Over Your Personal Information

You have the following rights regarding the processing of your Personal Information:

• Access your Personal Information and information relating to how it is processed.
• Correct or update any inaccurate Personal Information.
• Delete your Personal Information from our records.
• Transfer your Personal Information to a third party (right to data portability).
• Object to how we process your Personal Information where we are relying on our legitimate interests (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object to the processing of your personal data for direct marketing purposes.
• Withdraw your consent – where we rely on consent as the legal basis for processing at any time.
• Lodge a complaint with your local data protection authority.

Please note that, depending on the circumstances and the nature of your request, it may not be possible for us to do what you asked, for instance, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop.

In some cases, we might request specific information from you to help us confirm your identity and ensure your rights. This is a security measure to ensure that personal data is not disclosed to anyone with no right to access it.

If you would like to exercise any of these rights, kindly write us an email with the request to dataprotection@fakedoor.com.

In addition, users that have chosen to join our waiting list for specific modules, have the right to unsubscribe from this list at any time by emailing us at support@fakedoor.com.

6. How Long Do We Retain Personal Information

We keep Personal Information for as long as it is adequate, relevant and limited to what we need to provide our Services, to comply with the law, to exercise our legal rights, to respond to a legal claim or for other legitimate reasons. The length of time we retain Personal Information depends on the purposes for which we collect and use it. After you have terminated your account, we will make all reasonable efforts to promptly delete your Personal Information from our systems. However, please note that certain financial data, such as invoices, processed through third-party services (e.g. PHC Go), may be subject to their privacy and data retention policies. We do not have control over the deletion of data on their side, and you may need to refer to their privacy policies for more information on their data retention practices.

7. How We Protect Your Personal Information

To keep your Personal Information safe, whether online or offline, we have set some solid security measures. These protections help prevent others from accessing, sharing, changing, or destroying it without authorisation. However, please be aware that you provide Personal Information at your own risk: we cannot guarantee the security of the Personal Information you share with us as no internet or email transmission is completely secure or error-free. It also remains your responsibility to protect the security of your login information (i.e. using strong passwords, not sharing the same password for every online service you use and not sharing the password with someone not trusted – except for a parent or guardian).

8. Where We Store Personal Information

The Personal Information we collect is processed at our servers in Germany and in any data processing facilities operated by the third parties identified above. Some of these facilities are outside the UK and the European Economic Area. Suppose we need to transfer or store information outside the UK or the European Economic Area. In that case, we take the necessary steps required by law to ensure that your Personal Information are kept safe as outlined in this Privacy Notice.

9. No Information from Children Under 13

Our services are not meant for people who are under the age of 13. FakeDoor does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to FakeDoor, please email us at dataprotection@fakedoor.com. We will investigate any notification and, if appropriate, delete the Personal Information from our systems. If you are based in a country or state with an older age requirement, you can only use our Services if you are at or over the age at which you can provide consent to personal data processing. In case you are above 13 but below the age of consent in your country, we may only allow you to use our Services if your parent or legal guardian consents on your behalf for the use of our Services and for the processing of your Personal Information.

10. Links to Other Websites

The Services may contain links to other websites not operated or controlled by FakeDoor (“Third Party Sites”). The information that you share with third parties will be governed by the specific privacy policies and terms of service of third-party sites and not by this Privacy Notice. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the third-party sites directly for information on their privacy practices and policies.

11. Cookies

When you visit our Services, we will send cookies (small text files that contain an identifier – a string of letters and numbers) to your computer. These cookies make it easier for you to log in quickly, improve how you move around the site, remember your preferences, and make your overall experience better. In addition, third-party vendors such as Google, use cookies to serve ads based on a user's prior visits to FakeDoor website or other websites. However, if you turn off cookies, some parts of our Services might not work as well. For more information on how we use cookies, please access our Cookie Notice.

12. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. You can always see the date of the last update at the top of the page.

13. How to Contact Us

If you have any privacy-related questions or requests, you can contact us at: dataprotection@fakedoor.com or by post at Avenida António Augusto de Aguiar, 21, Lisbon, Portugal.