Política de Privacidade

Last Updated: 30.09.2017

1 - Purpose

At ADHARA, LDA ("Adhara," "us," "we," or "our") privacy is important to us. This Privacy Policy describes how we collect and use personal information through our online interface (“HarryFlash App”), and the circumstances under which we may share this information. This Privacy Policy applies to the privacy practices of Adhara on its website, located at http://adhara.education, on the HarryFlash App mobile application (together with the website, the “Platform”) and to Adhara’s other interactions with users of the website, application, or Platform. When using the Platform, there may be additional notices about information practices and choices. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at privacy@adhara.online. Your use of our Platform is also governed by our Terms of Use.


By visiting or otherwise using the Platform, you agree to the Platform’s Terms of Use and consent to Adhara the collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Platform. If you do not agree and consent, please discontinue use of the Platform, and uninstall all related downloads and applications.


2 - Definition of personal information

For the purposes of this Privacy Policy, “Personal Information” means information about an identifiable individual.


3 - Type of personal information collected

As you use our Platform, we collect certain information about you and your use of the Platform. The information we collect falls into three different categories: (a) information you provide us; (b) information we collect from you automatically when you use our Platform; and (c) information we collect from our partners and other sources.

- Information you provide

Adhara may collect information you provide directly to Adhara and/or its service providers (the “Service Providers”) when you use our Platform. This includes but is not limited to:

a) Personal Information you provide when you create an account (the “Account”) or register on the Platform. When you create an Account, we collect personal information from your social network (name, email address, birth date, gender and city), or according to the registration we ask for Personal Information, which may include your first and last name, birthdate, education institution and email address. Once you have completed the registration process, you may at any time provide additional information to your profile, including education and training details, working city. Providing additional information is entirely optional, but enables you to better identify yourself and find new opportunities in the Platform to build and leverage your professional network. The information that is publicly available or you voluntarily provide will be published in your profile, which isn’t accessible to users browsing the HarryFlash App mobile application.

b) Personal Information you provide when you update your account.

c) Personal Information you provide when you participate in a survey or promotion.

- Information collected automatically

Adhara, its Service Providers, and/or Adhara’ partners or affiliates may automatically collect certain information about you when you access or use the Platform (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Platform, and data regarding network connected hardware (e.g., computer or mobile device). The methods that may be used on the Platform to collect Usage Information include:

a) Log Information: Log information is data about your use of the Platform, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.

b) Information Collected by Tracking Technologies: Location-identifying technologies, device tokens, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Platform.

i) Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content based on your location.

ii) Device Tokens: A device token is a unique identifier issued by the operating system of your mobile device. You may sign up to receive “push notification” messages through the Platform. To ensure messages reach the correct devices, we rely on a device token unique to your mobile device. While we may be able to access a list of the tokens, the mobile app and tokens do not reveal your identity, unique device ID, or contact information to us.

iii) Cookies: Like in most website owners’, Adhara uses cookies and web log files to track website usage. A cookie is a tiny data file which resides on your computer which allows Adhara to recognize you as a user when you return to the website using the same computer and web browser. Like the information you enter at registration or when you update your profile, cookie and log file data is used to customize your experience on our website. We use cookies to improve the quality of our service by storing user preferences and tracking user trends. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

Some information about your use of the Platform may be collected using Tracking Technologies across time and services, and used by Adhara’ and third parties for delivering the Platform.


4 - Information Adhara collects from partners and other sources

We may collect Personal Information that you have provided to our subsidiaries, affiliates, business partners and/or businesses related to Adhara for purposes set out below. Adhara is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices. As a general rule, Adhara collects Personal Information directly from you. If third parties hold information Adhara requires, we will endeavor to ensure the information has been collected with your consent.

Specifically, we may collect and use Personal Information that is aggregated and anonymised (the “Analytic Information”) from our subsidiaries, affiliates, business partners and/or businesses related to Adhara, for various business purposes, including, without limitation, enabling us to provide the Platform. This Analytic Information, because it is aggregated and anonymised, is no longer Personal Information as it cannot be used, alone or in conjunction with other information, to identify an individual. We may use this Analytic Information in a variety of ways, including to help analyze site traffic, understand users’ needs and trends, and to improve our products and services. We may use this information by itself or aggregate it with information we have obtained from others.

Further, we may use, transfer, lease, sell or otherwise commercialise Analytic Information for any and all purposes without notice or obligation to you, provided that the Analytic Information does not indicate your identity and cannot be used, alone or in conjunction with other information, to determine your identity. You will not have any rights arising from the creation, collection or use of the Analytic Information.


5 - The motives why we collect your personal information

We collect Personal Information for purposes related to managing and developing our businesses and operations, including but not limited to:

a) Establishing, managing and terminating business relations with you.

b) Informing you of our products and services other than those that you have specifically requested.

c) Reviewing the products and services that we provide to you, or that you provide to us.

d) Tracking and analysing trends and patterns related to our businesses and operations for market research related purposes.

e) Providing you with the Platform.

f) Creating aggregated information or Analytic Information that does not individually identify you.

g) Complying with applicable law or regulatory requirements.

h) And any other reasonable purpose to which you consent. In addition to the foregoing, we may also use and disclose your Personal Information for other purposes, which we will disclose at the time of collection.


6 - The use of your personal information

Adhara may collect and use Personal Information in the circumstances described above. Personal Information collected by Adhara is used only for the purpose identified at the time of its collection, as described in this Privacy Policy, or for other purposes which are disclosed to you and to which you consent.

We may also use your Personal Information to investigate security breaches or cooperate with government authorities pursuant to a legal matter.

Adhara is committed to complying with European Anti-Spam Legislations. In the case of personal contact information provided in conjunction with any newsletter or other marketing initiatives, you can withdraw your consent to receiving those communications and unsubscribe from any Adhara subscriptions at any time by contacting our Privacy Officer using the contact information provided below. In addition, commercial electronic communications sent by Adhara to which you have subscribed will further contain an unsubscribe mechanism.

We reserve the right to send you transactional or informational emails such as customer service communications in connection with the products you have purchased or changes to this site or policies.


7 - Disclosure of your personal information

In addition to the purposes set out above, we may disclose Personal Information for purposes related to:

a) Managing and developing Adhara’ businesses and operations.

b) Managing your Account.

c) Providing you with the Platform.

d) Creating and maintaining a responsible business relationship with you.

e) Creating aggregated information or Analytic Information that does not individually identify you.

f) Communicating with you on topics related to your Account, Platform, and other matters related to Adhara.

g) Informing you of our products and services other than those that you have specifically requested.

h) Tracking and analysing trends and patterns related to our businesses and operations for market research related purposes.

i) Interacting with you on social media.

j) And other purposes identified when the Personal Information is collected, or as permitted or required by law.

Personal Information is disclosed to third parties for purposes set out above including but not limited to:

a) A third party, in the event of a change in ownership of all or a part of Adhara through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you indicate otherwise.

b) Third party service providers, affiliates and business associates including an organisation or individual retained by Adhara to perform functions on its behalf.

c) Any third party, where you have provided your consent for such disclosure or where disclosure is required or permitted by law.

In addition, you can direct us to share data with other parties. Once you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy.

On rare occasions, we may use or disclose your Personal Information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

Adhara may share or sell aggregated, de-identified data that does not identify you with partners and the public in a variety of ways. When we provide this information, we take technical measures to ensure that the data does not identify you and cannot be associated back to you.

Notification respecting service providers internationally

Adhara may use and disclose certain Personal Information to third party service providers and to affiliated entities in connection with the performance of certain technological or administrative functions, such as data management. From time to time, these third party service providers may be located outside of Portugal. Prior to making this disclosure, Adhara will take appropriate steps to ensure that the third party service providers safeguard the Personal Information and use the Personal Information only for authorized purposes set out in this Privacy Policy or in accordance with applicable laws.

To ask any questions or to obtain written information about Adhara’ policies and practices regarding those service providers, you may write to our Privacy Officer at the address listed below in the “Contact us” section.


8 - Adhara obtainment of consent

It is important to us that we collect, use or disclose your Personal Information only where we have your consent to do so or as provided in this Privacy Policy. Depending on the sensitivity of the Personal Information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our Terms of Use, we will assume your consent to the collection, use and disclosure of your Personal Information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.

By submitting your Personal Information to Adhara or obtaining our services, you consent to the collection of and use of your personal data in the manner described in this Privacy Policy. To the extent that Adhara is required by applicable laws to obtain your explicit consent for the collection, use or disclosure of your Personal Information in accordance with this Privacy Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

We may collect, use or disclose your Personal Information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide products or services to you or acquire products or services from you.

In certain cases, we collect express consent; otherwise, we assume, unless you advise us otherwise, that by receiving a copy of this Privacy Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your Personal Information as explained in this Privacy Policy.


9 - Tracking options

With respect to Adhara’ mobile apps, you can stop all collection of data generated by use of the app by uninstalling the app. You may also be able to exercise specific privacy choices, such as enabling or disabling certain location-based services or push notifications, by adjusting the permissions in your mobile device.


10 - Adhara protection of your personal information

Adhara will endeavor to safeguard Personal Information using methods that are appropriate to the sensitivity of the information. Specifically, Adhara takes the following steps to safeguard any Personal Information that it collects:

a) Protecting the confidentiality of all Personal Information when doing business internally or externally with other organisations.

b) And protecting all Personal Information with appropriate and effective security safeguards, including physical, administrative, and technology safeguards, against such risks as loss or theft, unauthorised access, disclosure, copying, use or destruction, regardless of the format in which it is held.


11 - Adhara storage of your personal information

Adhara collects and stores your information on a secure, European server. For our overseas visitors, your data may be collected and stored on secure, offsite servers that meet the laws and policies of your country.


12 - Correction of inaccurate personal information

It is important that any Personal Information Adhara holds about you is accurate and current. Adhara requires you to keep us informed of changes to any Personal Information. You can correct any inaccuracies by accessing and modifying the information provided in your Account.


13 - Retaining your personal information

Adhara retains Personal Information in accordance with its legal or business practices. We retain your Personal Information up to one year after you cease to be a Adhara active Platform user. You will be considered an inactive user after one year with no activity in the Platform, starting from the date of your last access. Once the Personal Information is no longer required to fulfill the purpose for which it was collected and no longer required or permitted to be retained for legal or business purposes, it is securely destroyed or made anonymous.


14 - Access to your personal information

Any data that you provide to Adhara can be accessed and modified from your Account. If you remove data from your profile, it will no longer appear to you or others who use the Platform. Backups of that data will remain in association with your Account and in our archive servers until deleted in accordance with our data retention schedule.

You can also ask to see the Personal Information that we hold about you. If you want to review, verify or correct your Personal Information, please contact our Privacy Officer using the contact information set out below. Please note that any such communications must be in writing.

When making an access request, we may require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the Personal Information that we hold about you. We may charge you a fee to access your Personal Information but we will advise you of any fee in advance. If you need help in preparing your request, please contact our Privacy Officer.

Adhara may not be able to provide you with access to your Personal Information, in situations where such refusal is permitted or required by applicable law or regulatory requirements. Adhara will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.


15 - Your obligations

As a user, you have certain obligations toward the other users with whom you will be communicating. Certain of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members, such as the HarryFlash App mobile application:

You must, at all times, respect the terms and conditions of the then-current Privacy Policy and the Terms of Use agreement. This includes respecting all intellectual property rights which may belong to third parties (such as images and videos).

You must not download or otherwise disseminate any information which may be deemed to be injurious, defamatory, violent, offensive, racist, sexist or xenophobic, or which may otherwise violate the purpose and spirit of the HarryFlash App mobile application and its community of users.

You must not provide information to Adhara and/or other users which you believe might be injurious or detrimental to your person, professional or social status.

Any violation of these guidelines may lead to the restriction, suspension or termination of your Account by Adhara, as we take these principles seriously and consider them to be the basis on which our users adhere to the Platform.


16 - Deactivation of your account

You can deactivate your Account by contacting us at support@adhara.online. When you do, data that can identify you will be removed from the Account, including but not limited to your email, name, birthdate. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period.


17 - Questions or concerns related to our services

You can direct any questions or concerns about this Privacy Policy to Adhara’ Privacy Officer (support@adhara.online). Adhara maintains procedures to receive and investigate complaints and complainants will be advised of the results of any such investigation.


18 - Adhara cope with children’s privacy

The Service is not directed to individuals of less than 18 years of age. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in the “Contact Us” section, below.


19 - Changes to this privacy policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. We will post any revised version of this Privacy Policy on our website.


20 - Contact US

To get more information about Adhara’ Privacy Policy, change or withdraw your consent or make a complaint or suggestion under this Privacy Policy, you can contact:

Name: ADHARA, LDA.
Address: Rua de Argoncilhe, n.º 362; 4505-074, Argoncilhe, Santa Maria da Feira, Aveiro, Portugal.
Telephone Number: +351 911919023
Email Address: support@adhara.online
Website: www.adhara.online