Privacy Policy
istutter center is part of Narrativexample – Speechcare Lda (a private limited company), established in Portugal, NIPC: 515513482. This Privacy Policy will explain how our organization processes the personal data we collect from you.
This Privacy Policy applies to the processing of your personal data of (1) istutter center on its website, located at https://istutter.center/; (2) all products or services provided by us and described on the website, such as istutter’s Desktop application and istutter’s App mobile application (collectively, the “Platform”).
By visiting or otherwise using the Platform, you consent to the collection, use, and disclosure practices of istutter center described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Platform.
Introduction
istutter center is an online speech therapy service provider. Our main activities are:
o paid individual online therapy sessions (occasionally, sessions may take in small groups of 3 to 4 people);
o paid online and presential training courses (mostly recorded but also web-streamed);
o creation of specialized speech therapy content – for courses, awareness-raising actions, and our company’s own marketing activities -, which we publish on our website and social media accounts (none of these activities makes use of personal data of our clients).
All personal data is stored exclusively in our internally built Platform.
For video communication purposes (either speech therapy sessions or web streamed training sessions), istutter uses Zoom Video Communications, having introduced the following mandatory internal practices:
o speech therapists are always the hosts of these sessions and only allow the entrance of participants after an identity check established at the “waiting room”;
o in order to record the session (partially or fully), speech therapists must clearly warn the participants ahead of the session and repeat this same procedure when the session starts being recorded. The latter warning, which is thereby recorded, is thus given prior to any processing activity as stipulated by 4(11) of GDPR.
What is personal data?
According to Article 4 of the General Data Protection Regulation 2016/ 679, “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”.
WHAT data do we collect and HOW do we collect it?
Our company collects the following data: a) information you provide, b) information we collect from you automatically when you visit our website.
a) Information you provide
Personal data you provide when you register in our website or when you enrol in our online sessions or training.
When we create your Account, we ask for your Personal Data, which includes your first and last name, birthdate, email, phone number, country of residence, professional background, education institution, education certificates, and billing information.
Once you have enrolled in our sessions or courses, this information also includes an indication of personal and familiar speech disorders (such as: stuttering, dyslexia and others; their degree of severity; indication of family members who stutter or have other potentially genetic speech impairments) and very generic psychological and physical wellbeing questions (such as: How do you feel? How was your week? What events mostly impacted your daily routines? How many hours did you practice the learned techniques last week?).
When pursuing speech therapy sessions or training, we will ask you additional information to add to your Account, including professional or educational challenges and training details, as well as keywords or internal surveys that best describe you.
Providing additional information is entirely optional, but enables you to better progress in your sessions or trainings, access valuable non-identifiable statistical data or to find helpful ways of interacting with your speech therapists and, potentially, with other people who are also enrolled in our speech therapy sessions or trainings. The information that you voluntarily provide will only be made available to your speech therapist(s) and coordination team.
b) Information collected automatically
istutter center collects information about you when you access or use our website and platform (“Usage Data”). This Usage Data includes 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). Such information enables us to better adapt our costumer journey to different devices and browsers, and to create relevant content for users from distinct countries and regions.
The methods that may be used on the Platform to collect Usage Data 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, and related data, and may be stored in log files. This data enables us to continuously improve our content and user-experience.
b) Information Collected by Tracking Technologies: Location-identifying technologies, device tokens, and other tracking technologies now and hereafter developed (“Tracking Technologies”) will be used to collect information about interactions with the Platform. Such data allow us to map the customer journey as they interact with our website, enabling a better understanding of their preferences and offering a design that meets their needs.
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. 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: Cookies are alphanumeric identifiers that we transfer to your computer’s (or other device’s) persistent storage medium (e.g., hard drive) through your browser to enable our systems to recognize your browser and tell us how and when pages on our Website are visited and by how many people. We use cookies to enhance visitors’ experiences, to learn more about their use of the Website and to improve quality. Company cookies do not collect Personal Data.
Why do we collect your personal data?
In addition to the purposes set out above, we may disclose Personal Data for purposes related to:
a) Managing and developing istutter’s 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 the Platform.
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 Data is collected, or as permitted or required by law.
If you agree, our company will share your data with our partner companies, so that they may offer you their products and services:
o LPBN Care Lda (commercial names “SpeechCare” and “Centro de Tratamento de Gaguez”), NIPC: 508612829
This anonymized data allows us to identify patterns that will enrich our users’ experiences, such as: “assiduity”, “average age of our customers”, “nationality”, “mother tongue”, “level of satisfaction with our sessions”, “number of hours of practiced techniques” and “average number of sessions per client”.
How will we use your Personal Data?
The istutter center may collect and use Personal Data in the circumstances described above. Personal Data collected by our company 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 reserve the right to send you transactional or informational emails such as customer service communications in connection with the products you have registered to use or changes to the website or policies.
How does istutter center obtain consent?
It is important to us that we collect, use or disclose your Personal Data only where we have your consent to do so or as provided in this Privacy Policy.
By submitting your Personal Data to istutter center’s Platform 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 istutter is required by applicable laws to obtain your explicit consent for the collection, use or disclosure of your Personal Data 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 Data 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.
You may change or withdraw your consent at any time by contacting our coordination team using the contact information set out below (by simply asking to delete all personal data from our database, which we commit ourselves to do immediately). 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.
What are my tracking options?
With respect to istutter’s mobile app, you can stop all collection of data generated by use of the app by uninstalling the app.
How does istutter center safeguard Personal Data?
istutter center’s mobile application will endeavor to safeguard Personal Data using methods that are appropriate to the sensitivity of the information. Specifically, istutter takes the following steps to safeguard any Personal Data that it collects:
a) Protecting the confidentiality of all Personal Data when doing business internally or externally with other organisations.
b) And protecting all Personal Data 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.
How does istutter center store Personal Data?
istutter center collects and stores your information on secure European Union servers accordingly to GDPR rules.
How to correct inaccurate Personal Data?
It is important that any Personal Data istutter center holds about you is accurate and current. istutter center requires you to keep us informed of changes to any Personal Data. You can correct any inaccuracies by directly contacting your speech therapist or by sending an email to [email protected] (for efficiency purposes, please indicate “Personal data correction” or “Personal data update” followed by your “first and last name” in the subject matter).
How do you deactivate your Account?
You can deactivate your Account by contacting us at [email protected] (for efficiency purposes, please indicate “Account deactivation” followed by your “first and last name” in the subject matter). When you do so, data that can identify you will be removed from the Account, including, but not limited to, your email, name, birthdate and photo. Backup copies of this data will be removed from our servers based upon an automated schedule, which means it may persist in our archive for at most thirty (30) days. istutter center may continue to use your de-identified data.
How does istutter’s App handle underaged individuals’ privacy?
All speech therapy or training sessions are preceded by the signature of a valid consent. For all underaged attendees, the valid consent must be signed by their parents or legal guardians. Should you have any questions concerning this matter, please contact us as described in the “How to contact us?” section, below.
How to contact us?
To get more information about istutter’s Privacy Policy, change or withdraw your consent or make a complaint or suggestion under this Privacy Policy, you can contact:
– istutter center’s Coordination Team
Address: Malo Clinic (SpeechCare) Avenida dos Combatentes 43, 1600 Lisboa, 7º, Portugal
Telephone Number: +351917188185
Email Address: [email protected]
– Portuguese Data Protection Supervisor: Comissão Nacional de Proteção de Dados
Address: Rua de São Bento n.º 148-3º 1200-821 Lisboa, Portugal
Telephone Number: +351 213928400
Email Address: [email protected]
Website: https://www.cnpd.pt/
Company’s privacy policy in accordance with:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)