Last updated: October 2026
1. Data Controller
The data controller responsible for your personal data is COMO UM NATIVO, UNIPESSOAL LDA, NIPC 518 492 680, with registered office at Praceta São Francisco Xavier, n.º 2, 4.º A, 2685-107 Sacavém, Portugal. Share capital: €6.000,00. Commercial registry: Conservatória do Registo Comercial / RNPC.
You can contact us at: benelipor@gmail.com.
2. Data We Collect
We collect the following categories of personal data:
- Account data: email address, password (hashed), first name, middle name (optional), last name, phone number and country code, and your consent choices (marketing consent, terms acceptance).
- Profile data: optional profile photo, and any changes you make to your account information in the Personal Hub.
- Purchase data: course or product purchased, price paid, payment status, payment transaction ID, terms version accepted, acceptance language, acceptance date, and IP address at the time of acceptance.
- Learning data: course progress, lesson completion status, last-viewed lesson, and enrollment status (active, expired, etc.).
- Forum data: thread titles, post content, optional images you upload, and your display name.
- Contact inquiries: name, email, subject, and message when you use the contact form.
- Communication data: messages sent to you via the Personal Hub inbox or email broadcasts, and your interaction with them.
- Technical data: pages visited, access times, browser type, and IP address (for security and terms-acceptance evidence).
3. How We Use Your Data & Legal Basis
| Purpose | Legal Basis |
|---|---|
| Creating and managing your account | Performance of a contract (Art. 6(1)(b) GDPR) |
| Processing course enrollments and product purchases | Performance of a contract |
| Processing payments via Base44 Payments (Wix) | Performance of a contract |
| Delivering course content and tracking your progress | Performance of a contract |
| Sending you account-related emails (verification, password reset, purchase confirmations) | Performance of a contract |
| Sending marketing, educational, and update content | Your explicit consent (Art. 6(1)(a) GDPR) — you can withdraw at any time |
| Operating the forum and displaying user-generated content | Your consent and legitimate interests in running the community |
| Responding to contact inquiries and support requests | Legitimate interests (Art. 6(1)(f)) and your consent to be contacted |
| Analytics and usage measurement (Google Analytics 4) | Your consent (loaded only after you opt in via the cookie banner) |
| Security, fraud prevention, and maintaining audit logs | Legitimate interests in protecting the platform |
| Compliance with legal and tax obligations | Legal obligation (Art. 6(1)(c) GDPR) |
4. Specific Data Flows
Account & Personal Hub: Your account data is used to authenticate you, display your profile, manage your enrollments and purchases, and show your learning progress. You can edit your profile at any time from the Personal Hub.
Courses: Enrollment records link you to specific courses. Lesson progress tracks which lessons you have completed and which you last viewed, so you can resume where you left off.
Shop: Product orders record what you purchased, the price paid, and the download link (for digital products). Terms acceptance evidence (version, language, IP, date) is recorded at checkout.
Payment: Payments are processed by Base44 Payments (powered by Wix). We receive the transaction status and order reference, but your card details are handled entirely by the payment provider — we never see or store them.
Messages: Admin messages and broadcasts appear in your Personal Hub inbox. Broadcasts are sent to selected recipients based on consent and audience criteria.
Forum: Your posts and threads are visible to other registered users in the language zone you posted in. Your display name is shown alongside your content.
Marketing consent: You can grant or withdraw marketing consent at any time from your Personal Hub. Withdrawing consent does not affect account-related emails (verification, purchase confirmations).
Security: We maintain user activity logs for administrative purposes (enrollments, access changes, blocks, messages). These logs are visible only to admins.
5. Data Recipients & Processors
We do not sell your personal data. We share data with the following processors, each under a data processing agreement:
| Processor | Purpose | Data Shared |
|---|---|---|
| Base44 platform (hosting, database, auth, file storage) | Operating the entire application | All account, learning, and content data |
| Base44 Payments / Wix (payment processing) | Processing checkout and payments | Email, billing name, and payment amount |
| Google Analytics 4 (consent-gated) | Anonymous usage statistics | Page URLs, browser data, anonymized IP (only with your consent) |
| YouTube / Vimeo (embedded video) | Course intro videos and lesson videos | IP address and viewing data (subject to their privacy policy) |
| Base44 SendEmail | Email delivery (verification, broadcasts, admin messages) | Email address and message content |
| Locallista (optional, admin-controlled) | Quality badge widget | No personal data shared by our site; the widget loads independently |
6. International Data Transfers
The Base44 platform and some processors may process data outside the European Economic Area (EEA). Where this occurs, appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or the processor's participation in an approved certification framework. You can request a copy of these safeguards by contacting us.
7. Data Retention
We retain your personal data as follows:
- Account data: For as long as your account is active. You can request deletion at any time.
- Purchase and enrollment data: For the duration of your access period, plus the period required by accounting and tax law (typically 10 years in Portugal).
- Terms acceptance evidence: Retained for the legal retention period to prove consent at the time of purchase.
- Forum content: Retained for as long as the forum is active, unless you request deletion of your posts.
- Activity logs: Retained for administrative and security purposes for a reasonable period.
- Marketing consent records: Retained to prove consent was given and when it was withdrawn.
8. Your Rights
Under the GDPR and Portuguese Law 58/2019 (Lei de Implementação do RGPD), you have the following rights:
- Right of access: Request a copy of your personal data.
- Right to rectification: Correct inaccurate or incomplete data.
- Right to erasure: Request deletion of your account and associated data (subject to legal retention obligations).
- Right to data portability: Receive your data in a structured, machine-readable format.
- Right to object: Object to processing based on legitimate interests.
- Right to withdraw consent: Withdraw marketing consent at any time from your Personal Hub or by contacting us.
- Right to restrict processing: Request that we limit how we use your data temporarily.
- Right to lodge a complaint: You can complain to the Portuguese Data Protection Authority (CNPD — www.cnpd.pt).
To exercise any of these rights, contact us at benelipor@gmail.com. We will respond within 30 days.
9. Cookie Table
The following cookies and trackers are used on this site. You can manage your preferences at any time via Cookie Settings.
| Name | Provider | Purpose | Category | Lifetime | Type |
|---|---|---|---|---|---|
| cun_cookie_consent | Como Um Nativo | Stores your cookie consent preferences | Necessary | Persistent (until changed) | First-party (localStorage) |
| como_lang | Como Um Nativo | Remembers your language preference (Hebrew/English) | Preferences | Persistent | First-party (localStorage) |
| Auth tokens | Base44 platform | Keeps you logged in and authenticates requests | Necessary | Session / persistent | First-party |
| _ga, _ga_* | Google Analytics | Anonymous traffic measurement and page views | Analytics | Up to 2 years | Third-party (Google) |
No marketing cookies are currently active on this site. If marketing cookies are added in the future, they will only load after you explicitly consent.
10. Security
We apply reasonable technical and organisational measures to protect your data, including encrypted authentication, access controls limited to authorised admins, and private file storage for course materials. No method of transmission or storage is 100% secure, but we strive to protect your information using industry-standard practices.
11. Changes to This Policy
We may update this Privacy & Cookie Policy from time to time. The "last updated" date at the top of the page indicates when the policy was last revised. Material changes will be communicated via your Personal Hub or email where appropriate.
12. Contact
For any question about your personal data or this policy, contact us at benelipor@gmail.com.
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