Privacy Policy

Effective date: 20/04/2026

This Privacy Policy explains how Seven Links, Lda, trading as Portuguish (“Portuguish”, “we”, “us”, or “our”), collects, uses, stores, shares, and otherwise processes personal data in connection with www.portuguish.pt  and any related pages, products, services, member areas, lessons, communications, and features we make available.

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection and privacy laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) where applicable, and other laws that may apply depending on your location and our processing activities.

1. Data Controller

The controller responsible for the processing of your personal data is:

Seven Links, Lda
Urbanização Encosta do Vau, Bloco 18
8500-326 Portimão
Portugal
Email: info@portuguish.pt 

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, you can contact us at info@portuguish.pt.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed in connection with:

• visits to www.portuguish.pt  and related pages;
• purchases and use of our digital products and services, including The Portuguese Puzzle, The Foundation Course, and Live Lessons;
• account registration, login, and use of member-only areas;
• newsletter subscriptions, lead forms, and other forms submitted through the Website;
• communications by email, website forms, booking tools, comments, messages, WhatsApp, or similar channels;
• testimonials, reviews, comments, and other user-submitted content;
• cookies and similar technologies, including local storage and session storage.

3. Categories of Personal Data We May Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

3.1 Identity and contact data

This may include:

• first name and last name;
• email address;
• phone number;
• billing address or country, where relevant;
• account login details and related account identifiers.

3.2 Transaction and payment-related data

This may include:

• product or service purchased;
• subscription status;
• order details;
• payment status;
• limited billing-related information;
• payment method type.

We do not generally store full card details ourselves. Payments are processed through third-party payment providers.

3.3 Account and member-area data

This may include:

• account registration data;
• account access and login-related data;
• member-area usage;
• course progress or participation-related information;
• comments, submissions, and interactions within account or course environments.

3.4 Communications and user-submitted content

This may include:

• emails and support messages;
• messages sent through forms;
• booking requests;
• WhatsApp messages if you choose to contact us through WhatsApp;
• comments, testimonials, reviews, homework, exercises, voice notes, or other content you choose to submit to us.

3.5 Technical and usage data

This may include:

• IP address;
• browser type and version;
• operating system;
• device identifiers;
• referring URL;
• pages visited;
• session data;
• date and time of access;
• usage events and interactions with the Website, checkout, and member areas.

3.6 Marketing and analytics data

This may include:

• information about whether you opened or clicked emails;
• advertising attribution data;
• campaign or referral information;
• website analytics data;
• cookie and similar technology identifiers.

3.7 Public review/profile information

Where reviews are displayed through third-party tools such as Elfsight, public review information from the source platform may be displayed or processed, which may include:

• name or username;
• public profile picture;
• public rating or review text;
• source platform information.

4. How We Collect Personal Data

We may collect personal data:

• directly from you when you fill in forms, make a purchase, create an account, subscribe to emails, book a call, submit a review, comment, or contact us;
• automatically through cookies and similar technologies when you visit or use the Website;
• through our website, course, checkout, and email platforms;
• from payment providers in connection with purchase confirmations and payment status;
• from booking providers when you schedule appointments or calls;
• from third-party platforms where you submit a public review that is later displayed via an embedded review tool;
• through communications you send us by email, WhatsApp, comments, or similar channels.

5. Purposes of Processing and Legal Bases

We process personal data only where we have an appropriate legal basis or other lawful justification under applicable law.

5.1 Contract

We process personal data where necessary to take steps at your request before entering into a contract, and to perform a contract with you, including to:

• create and manage your account;
• process purchases and subscriptions;
• provide access to our products, services, and member areas;
• manage billing, renewals, and cancellations;
• deliver lessons, courses, downloads, and related support;
• respond to customer service requests related to your purchase or account.

5.2 Consent

We process personal data on the basis of your consent where required or appropriate under applicable law, including:

• sending marketing emails where consent is required;
• placing non-essential cookies or similar technologies;
• using analytics, advertising, or targeting technologies where consent is required;
• processing certain optional submissions or communications where consent is the appropriate basis.

You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

5.3 Legitimate interests

We may process personal data where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms. This may include:

• operating, securing, and improving the Website and our services;
• administering our business;
• detecting, preventing, and investigating fraud, abuse, unauthorized access, or misuse;
• maintaining records;
• responding to enquiries;
• managing reviews, testimonials, comments, and community features;
• protecting our legal rights and enforcing our terms;
• limited direct marketing where permitted by law;
• measuring performance and improving our content, offers, and services.

5.4 Legal obligation

We may process personal data where necessary to comply with legal obligations, including accounting, tax, consumer, regulatory, complaint-handling, or law-enforcement related obligations.

6. If You Do Not Provide Personal Data

Where we need certain personal data to provide a product, service, account, booking, or response, and you do not provide that data, we may not be able to provide the relevant service or complete the relevant transaction.

7. How We Use Personal Data

We may use personal data to:

• operate and maintain the Website;
• provide our products and services;
• create and manage user accounts;
• process purchases, subscriptions, bookings, renewals, and refunds where applicable;
• communicate with you about your account, purchase, booking, support request, or enquiry;
• send service-related emails and administrative notices;
• send newsletters or marketing communications, subject to applicable law and your preferences, and any consent or opt-out choices that apply;
• personalize and improve user experience;
• understand website usage and improve content, products, offers, and site performance;
• manage comments, submissions, testimonials, and reviews;
• protect the Website, our users, and our business from fraud, abuse, spam, and security threats;
• comply with legal, tax, accounting, consumer protection, and regulatory obligations;
• establish, exercise, or defend legal claims.

8. Communications, Comments, Submissions, and User Content

If you submit comments, messages, exercises, homework, testimonials, reviews, voice notes, emails, WhatsApp messages, or other materials to us, we may process that content:

• to communicate with you;
• to provide support or feedback;
• to operate our services and community features;
• to improve our educational services;
• to administer reviews, comments, or member interactions;
• where relevant, to promote our business in accordance with applicable law and our Terms.

Please avoid sending sensitive personal data unless it is necessary and appropriate in the context.

9. Testimonials and Reviews

We may display reviews or testimonials relating to our business or services.

Where reviews are embedded or displayed through third-party review tools such as Elfsight, public information associated with the review on the original platform may appear, such as:

• name or username;
• profile image;
• rating;
• review text;
• source platform.

Where we directly collect or reuse testimonials ourselves beyond what is publicly displayed through the relevant source platform, we may do so on the basis of consent, legitimate interests, or another lawful basis, depending on the circumstances.

10. Booking and Scheduling

If you book a call, lesson, or appointment through YouCanBook.me or another scheduling tool we use from time to time, the relevant provider may process your personal data to enable scheduling, reminders, and calendar coordination.

11. Email Marketing and Communications

We may send:

• service emails and transactional emails relating to purchases, subscriptions, bookings, or account activity;
• onboarding emails related to our products or services;
• newsletters and marketing communications, where permitted by law or where you have opted in.

You can unsubscribe from marketing emails at any time using the unsubscribe link in the email or by contacting us.

Even if you opt out of marketing, we may still send non-marketing communications where necessary for contractual, service, or legal reasons.

12. Payments

Payments may be processed through one or more third-party providers, including:

• Stripe
• PayPal
• Kajabi Payments
• Apple Pay
• Google Pay
• Klarna

The relevant payment provider may collect and process payment and transaction data in accordance with its own privacy terms and legal obligations. We generally receive limited transaction-related information required to confirm payment, manage access, administer subscriptions, and handle customer service.

13. Third-Party Providers and Service Categories

We use third-party service providers and tools to operate our Website and business. Depending on your interaction with us, these may include providers in categories such as:

• website hosting, infrastructure, and content delivery;
• website and member-area platform services;
• payment processing;
• email and communication tools;
• booking and scheduling tools;
• analytics and advertising tools;
• cookie consent management;
• embedded content providers;
• video conferencing and course delivery tools;
• review/testimonial tools;
• support, security, and anti-abuse services.

Providers we may use include, for example:

• Kajabi
• Stripe
• PayPal
• Kajabi Payments
• Apple Pay
• Google Pay
• Klarna
• Google Analytics
• Google Ads
• Meta
• Microsoft Clarity
• CookieScript
• YouCanBook.me
• Gmail
• Kajabi email tools
• Zoom
• Brainscape
• WhatsApp
• YouTube
• Vimeo
• Wistia
• Elfsight
• security, infrastructure, and anti-bot providers such as Cloudflare and similar services.

We do not sell personal data for money. However, we use third-party analytics and advertising tools, and some data disclosures involving cookies, pixels, and similar technologies may be considered “sale,” “sharing,” or targeted advertising under certain laws. Users can manage their cookie and privacy choices at any time through our Privacy Choices / Cookie Preferences tools.

We may share personal data with third parties where necessary to operate our business, provide services, comply with law, protect rights, or process data on our behalf under appropriate contractual arrangements.

14. International Transfers

Some of our service providers or their sub-processors may process personal data outside the European Economic Area, the United Kingdom, or Switzerland.

Where personal data is transferred internationally, we take steps intended to ensure that an appropriate level of protection applies, including, where relevant:

• adequacy decisions;
• Standard Contractual Clauses;
• contractual, technical, and organizational safeguards;
• other lawful transfer mechanisms recognized under applicable law.

Because the providers, locations, and technical arrangements we use may change over time, we do not guarantee that processing always takes place in a single country or region.

15. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including for:

• providing services and maintaining accounts;
• managing subscriptions, purchases, and support;
• complying with legal, tax, and accounting obligations;
• resolving disputes;
• protecting our legal rights;
• enforcing agreements;
• maintaining business records.

Retention periods vary depending on the type of data and the reason for processing. When personal data is no longer required, we will delete it, anonymize it, or securely retain it only where legally required or justified.

16. Your Rights

Subject to applicable law, you may have rights in relation to your personal data, which may include the right to:

• request access to your personal data;
• request rectification of inaccurate or incomplete personal data;
• request erasure of personal data;
• request restriction of processing;
• object to certain processing;
• request data portability;
• withdraw consent at any time where processing is based on consent;
• lodge a complaint with a supervisory authority.
• opt out of certain processing, including, where applicable, targeted advertising, sale or sharing, or certain profiling-related activities;

To exercise your rights, please contact us at info@portuguish.pt .

We may ask you to verify your identity before responding to a request. We may also need to retain certain information where required by law or where we have a lawful basis to do so.

If you are in Portugal, you may lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), without prejudice to any other administrative or judicial remedy available to you.

17. Security

We use appropriate technical and organizational measures intended to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

However, no system, website, email transmission, or method of electronic storage is completely secure, and we cannot guarantee absolute security.

18. Children

Our Website and services are not intended for children under the age of 16. We do not knowingly collect personal data from children under 16 in a manner requiring parental consent under applicable law.

If you believe that a child has provided us with personal data unlawfully, please contact us and we will take appropriate steps.

19. Cookies and Similar Technologies

We use cookies and similar technologies, including local storage and session storage, on our Website and in connection with our services.

These technologies may be used to:

• operate the Website and core services;
• maintain sessions and account functionality;
• keep the site secure;
• remember user choices and preferences;
• enable checkout and payment-related functionality;
• measure site usage and performance;
• support analytics;
• support advertising, retargeting, and campaign measurement, where applicable and permitted by your consent choices, privacy settings, or other lawful basis available under applicable law.

Some cookies and similar technologies on our Website are set by Kajabi and related infrastructure providers as part of the operation of the website platform, checkout, account, login, hosting, security, and core service delivery environment. Where these technologies are strictly necessary to provide the Website or services requested by the user, they may be used without prior consent.

Other cookies and similar technologies, such as advertising-related technologies, are used only where required consent has been given, or otherwise in accordance with applicable law, your privacy choices, and any available opt-out mechanisms.

You can review or update your cookie choices at any time through the Cookie Preferences mechanism made available on our Website.

19.1 Cookie categories we use

We may use the following categories of cookies:

Strictly Necessary
These are required for core website, security, login, consent, session, anti-abuse, and checkout-related functions.

Functionality
These support enhanced functionality, user experience, preferences, and certain platform-related features.

Performance
These help us understand how visitors use the Website and improve performance, content, and user experience.

Targeting
These may be used by advertising and marketing partners to support campaign measurement, remarketing, and ad effectiveness.

19.2 Examples of cookies and similar technologies we use

The exact cookies and similar technologies in use may change over time, but they may include technologies relating to:

• session and consent handling;
• anti-bot and security protections;
• checkout and payment fraud prevention;
• account and member-area operation;
• analytics tools such as Google Analytics and Microsoft Clarity;
• advertising tools such as Meta and Google Ads;
• embedded content or third-party tools;
• local storage and session storage entries used by our platforms or integrations.

Examples may include cookies relating to:

• consent preferences;
• session handling;
• CSRF protection;
• Cloudflare and security services;
• load balancing and infrastructure services;
• Stripe payment and fraud-prevention services;
• Kajabi platform and member-area functionality;
• Google Analytics;
• Microsoft Clarity;
• Meta advertising tools;
• Google advertising tools;
• certain embedded tools or review widgets.

19.3 Checkout and payment technologies

When a user accesses checkout, billing-related pages, or certain payment options, additional cookies or similar technologies may be used by payment, security, and fraud-prevention providers such as Stripe, PayPal, Google Pay, Apple Pay, Klarna, and related providers.

These technologies are used to:

• process payments;
• maintain secure checkout;
• prevent fraud and abuse;
• support transaction integrity;
• provide payment method functionality.

The exact technologies used may vary depending on the user’s browser, device, account state, selected payment method, and the services available at the time.

19.4 Logged-in and member-only areas

When users access logged-in or member-only areas, additional cookies or similar technologies may be used to:

• maintain login sessions;
• secure accounts;
• deliver course content;
• support member-area functionality;
• support comments, content submissions, and related interactive features.

19.5 Cookie and similar technology list

Below is a summary of the main cookies currently identified on our Website. Because our Website relies on third-party services and platform features, this list may change from time to time.

Strictly necessary

Name	Provider / Domain	Expiration	Description
vs_uniques_offer	www.portuguish.pt	6 months	Used by the platform in connection with offer-page handling and related platform behavior on the Website.
AWSALBTGCORS	Amazon Web Services, Inc. www.portuguish.pt	1 week	This cookie is used to support load balancing, ensuring that visitor page requests are routed to the same server in any browsing session.
rl_session	.portuguish.pt	11 months 4 weeks	This cookie is used for managing user session on the website. It typically maintains the user's state during the session, ensuring that users remain connected and their interactions with the site are coherent throughout their visit. This can include keeping users logged in, tracking their actions, or persisting settings during the session.
__stripe_mid	Stripe Inc. .www.portuguish.pt	1 year	Used by Stripe for fraud prevention and secure payment processing on checkout or billing-related pages.
__cf_bm	Cloudflare Inc. .www.portuguish.pt	29 minutes 57 seconds	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.
vs_uniques_landing_page	www.portuguish.pt	6 months	Used by the platform in connection with handling a user’s initial landing page context and related page behavior on the Website.
POPUP-CSRF-TOKEN	www.portuguish.pt	Session	Security token used in connection with popups, forms, or interactive site features.
__stripe_sid	Stripe Inc. .www.portuguish.pt	1 year	Used by Stripe to support secure payment processing and fraud prevention during a checkout or billing session.
vs_uniques_template_metadata	www.portuguish.pt	6 months	Used by the platform in connection with template-related page behavior and rendering on the Website.
rl_anonymous_id	.portuguish.pt	11 months 4 weeks	Used by the platform to maintain an internal identifier associated with website operation and session-related functionality. This identifier may support platform operation across visits.
AWSALBTG	Amazon Web Services, Inc. www.portuguish.pt	1 week	This cookie is associated with the Amazon Web Services Elastic Load Balancing functionality for routing client request on the server.
m	Stripe m.stripe.com	1 year 1 month	This cookie is generally used for performance and optimization of payment processing services, facilitating caching of content on the browser to make pages load faster.
_kjb_session	www.portuguish.pt	1 day	This cookie is used to track the user's session for maintaining the functionality of the website, ensuring that users' session states are maintained as they navigate through the site.
CookieScriptConsent	CookieScript www.portuguish.pt	2 months 4 weeks	This cookie is used by Cookie-Script.com service to remember visitor cookie consent preferences. It is necessary for Cookie-Script.com cookie banner to work properly.
_dd_s	www.portuguish.pt	15 minutes	This cookie is used to store session data, ensuring that visits to a website are consistent during a session. It may include data such as how the visitor interacts with the site's pages, any preferences selected, and can help in error management.
_csrf_token	Cloudflare Inc. www.portuguish.pt	11 months 4 weeks	This cookie is used by Cloudflare to identify trusted web traffic.

Performance

Name	Provider / Domain	Expiration	Description
_ga	Google LLC .portuguish.pt	1 year 1 month	This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
_clck	.portuguish.pt	11 months 4 weeks	This cookie is used to track user interactions and engagement on the website to improve user experience and website functionality.
_clsk	Microsoft .portuguish.pt	1 day	This cookie is associated with Microsoft Clarity analytics software. It is used to store information about the user's session and to combine multiple page views into a single user session for analytics purposes.
_ga_XH7W36ELLJ	.portuguish.pt	1 year 1 month	This cookie is used by Google Analytics to persist session state.

Targeting

Name	Provider / Domain	Expiration	Description
_gcl_au	Google LLC .portuguish.pt	2 months 4 weeks	Used by Google AdSense for experimenting with advertisement efficiency across websites using their services
_fbp	Meta Platform Inc. .portuguish.pt	2 months 4 weeks	Used by Meta to deliver a series of advertisement products such as real time bidding from third party advertisers
IDE	Google LLC .doubleclick.net	1 year	This cookie is set by Doubleclick and carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Functionality

Name	Provider / Domain	Expiration	Description
elfsight_viewed_recently	Elfsight core.service.elfsight.com	14 seconds	This cookie is used to record which items a user has viewed recently on the website to provide an enhanced user experience by showing related content or products based on the user's browsing history.
_cfuvid	.elfsight.com	Session	This cookie is used for purposes of tracking users across sessions to optimize user experience by maintaining session consistency and providing personalized services.

Please note:
The cookies and similar technologies used on our Website may change from time to time, including as a result of platform updates, embedded content, checkout functionality, third-party services, and changes to our tools or providers. We review this information periodically and update this Privacy Policy where appropriate.

In some jurisdictions, certain analytics, advertising, or similar processing activities may be carried out on the basis of notice, opt-out, legitimate interests, contractual necessity, or another lawful basis where permitted by applicable law.

20. Third-Party Content and Integrations

Our Website or services may include or rely on third-party content, media players, embeds, messaging tools, reviews, scheduling tools, video or lesson tools, and other integrations. Examples may include YouTube, Vimeo, Wistia, Zoom, Elfsight, WhatsApp, or similar tools.

If you interact with such content or integrations, the relevant third party may process personal data in accordance with its own privacy practices.

21. WhatsApp

We may offer WhatsApp as an optional contact method. If you choose to contact us through WhatsApp, your message, phone number, and related metadata may be processed by WhatsApp and its related providers in accordance with their own privacy terms. This may involve international transfers.

You are under no obligation to use WhatsApp to contact us.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The most current version will be posted on this page, together with the updated effective date or last updated date. Where appropriate, we may also notify users of material changes by website notice, email, or other reasonable means.

23. Contact

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact:

Seven Links, Lda
Urbanização Encosta do Vau, Bloco 18
8500-326 Portimão
Portugal
Email: info@portuguish.pt