Privacy Policy

Last updated: 11 August 2026

All Portugal Smart Academy ("Smart Academy", "we", "us", "our") respects your privacy and is committed to protecting the personal data of visitors, customers, and the children who attend our classes. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have under the EU General Data Protection Regulation (GDPR) and the Portuguese data protection law (Lei n.º 58/2019).

Who we are (Data Controller)

DESCOBRILANÇA UNIPESSOAL LDA, NIPC 516940503, operating as All Portugal Smart Academy, is the controller of your personal data. You can reach us at smart@allportugalsmartacademy.com, by phone at +351 910 252 165, or by post at Rua 2 da Matinha, Urbanização da Matinha, Lote A, 5D, Armazém J, 1950-073 Lisboa, Portugal.

What personal data we collect

Depending on how you interact with us, we may collect:

- Contact and identification data of the parent/guardian: name, email, phone number.

- Child's data: the child's name and school grade/age, provided by the parent or guardian for the purpose of enrolling them in the appropriate class.

- Booking and payment data: the class booked, subscription (abonement) and trial history, attendance, and payment status. Card payments are processed by our payment providers; we do not store full card numbers.

- Communications: messages you send us (e.g. via the site chat, contact or trial-request forms, email).

- Consent records: your consent choices, including any consent to photography/video.

- Technical data: collected automatically by our website host (Wix) such as IP address, device and browser information, and cookies, to keep the site working, secure, and to understand usage.

Children's data

Our classes are for children. Our customers are their parents. That one sentence shapes everything in this section.

What we collect about a child, and from whom

We collect a child's first name and school grade or age. That is what we need to place a child in the right group and to know who is in the room. Everything reaches us from the parent or legal guardian: through the trial-request form, in a message, or in conversation. We never ask a child to fill in a form, create an account or give us their own details. If a child writes to us directly, we reply to the parent.

Who registers

Registration for a trial, a class or a subscription is made by a parent or legal guardian, who confirms that they have the authority to act for the child. Under Portuguese law a child can only give their own consent to an online service from the age of 13 (Lei n.º 58/2019, article 16). Our pupils are younger than that or close to it, so we do not rely on a child's consent for anything. The adult decides.

Our legal basis

We use a child's name, grade and attendance to run the classes the parent has booked. The legal basis is the contract with the parent (GDPR, article 6(1)(b)). Anything beyond the running of classes rests on the parent's consent (article 6(1)(a)), which the parent can withdraw at any time by writing to us.

Health information

Sometimes a parent tells us that a child has an allergy, a condition or a need we should know about so the child is safe and comfortable in class. Health information is a special category of personal data under GDPR, article 9. We record it only with the parent's explicit consent, use it only to keep the child safe during classes, share it only with the teacher who is with the child, and delete it when the child stops attending. We do not ask for it as a matter of routine; the parent chooses what to tell us.

Photographs and video

Photographs and video of a child are taken and used only with the parent's separate written consent, given apart from the booking itself. That consent is optional, has no effect on the child's place in class, and can be withdrawn at any time. Once it is withdrawn we stop using the material and remove it from our website and channels within a reasonable period. A child who has not been signed up for photography is kept out of shot.

How long we keep a child's data

While the child attends, and afterwards for as long as Portuguese tax and accounting law requires us to keep the parent's booking records. The child's own details inside those records are limited to what the invoice needs. Health information goes when the child leaves. Photographs go when consent is withdrawn. Trial-request data of children who never enrol is deleted within a reasonable period.

What a parent can do

A parent or legal guardian can see what we hold about their child, correct it, or ask us to delete it. Write to smart@allportugalsmartacademy.com from the address you used to register, tell us the child's first name and group, and we will answer within a month. Deletion of records that tax law requires us to keep will happen when that period ends; everything else goes on request. If you think we hold a child's data without a parent's authority, tell us and we will delete it.

Why we use your data and our legal bases

- To provide the service you request: process bookings, run the trial, manage the subscription, keep attendance (legal basis: performance of a contract).

- To communicate with you about your child's classes, schedule changes, and administrative matters (legal basis: contract / legitimate interests).

- To take payment and keep accounting and tax records (legal basis: legal obligation).

- To use photographs or video of classes on our website and promotional materials, only where you have given separate, optional consent (legal basis: consent, which you can withdraw at any time).

- To send you news or offers about the club, only if you have opted in (legal basis: consent).

- To keep the website and our services secure and working (legal basis: legitimate interests).

Sharing your data

We do not sell your personal data. We share it only with:

- Service providers who help us operate, such as our website and booking platform (Wix), and payment processors, acting on our instructions.

- Authorities, where we are legally required to disclose information.

Some providers (e.g. Wix) may process data outside the European Economic Area; where they do, appropriate safeguards such as Standard Contractual Clauses are applied.

How long we keep your data

We keep personal data only as long as necessary for the purposes above: for the duration of your relationship with the club and afterwards as required for legal, accounting, and tax obligations. Consent-based data (e.g. photos, marketing) is kept until you withdraw consent. Trial-request data of people who do not enrol is deleted within a reasonable period.

Your rights

Under the GDPR you have the right to access your data; to have it corrected or deleted; to restrict or object to processing; to data portability; and to withdraw consent at any time (without affecting processing already carried out). To exercise any of these, contact us at smart@allportugalsmartacademy.com. You also have the right to lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), www.cnpd.pt.

Our website uses cookies and similar technologies, including those set by our host Wix, to keep the site functioning, remember your preferences, keep it secure, and analyse usage. You can control cookies through your browser settings and, where shown, through the site's cookie banner.

Security

We take reasonable technical and organisational measures to protect your data against loss, misuse, and unauthorised access. No method of transmission over the internet is completely secure, but we work to protect your information and to keep our providers accountable.

Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date shows the latest version, and material changes will be posted on this page.

Contact

Questions about this policy or your data: smart@allportugalsmartacademy.com · +351 910 252 165.