Privacy Policy

Last update: November 20, 2023

This Global Privacy Policy describes the privacy practices of the PALCUS Platform -social platform that PALCUS offers as a website and mobile application (the “PALCUS Platform”). Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. We also provide a supplementary privacy notice for residents of California and a supplementary privacy notice for data subjects in the EEA, Switzerland and the UK (collectively, “Europe”) and Brazil.

About the PALCUS Platform

The PALCUS Platform is a community engagement platform, where people from the Portuguese community in the United States have access to relevant information, such as Portuguese companies, events, news, government delegations, among others. In addition, people can network, hold discussions, including around common interests.

To protect that, we take your privacy seriously and only use personal information to make the PALCUS Platform work well for you.

Privacy Principles

In case you don’t read this entire Privacy Policy, you should walk away with a few key points about PALCUS Platform’s privacy practices:

• Our platform is designed to allow you and others to use your devices to have access to relevant information on the Portuguese community in the United States.

• We use personal information to provide our services, to communicate about existing and new PALCUS Platform features with you, and to comply with our terms and applicable laws.

• We do not sell personal information.

• To create a safe environment on the PALCUS Platform, we may keep record of users’ usage of the PALCUS Platform, to investigate violations of our Community Guidelines or Terms of Service.

Personal Information We Collect

These are the categories of information we collect when you interact with our PALCUS Platform, and examples of how we use the specific types of information.

Information You Provide

• Your account information, namely your first and last name, email addresses and phone number are required to create an account in the PALCUS Platform:

· Your phone number is used to register and log into the application. If you don’t provide us with this information, you will not be able to create an account in the PALCUS Platform.

· For enhanced security, a verification code is sent to your mobile phone to register and login. The PALCUS Platform will send the user a text message per registration and login attempt. Message and data rates may apply.

• Your social profile/bio, such as your, organization name, other email addresses, phone number, profile picture, preferred language, user name, and other information you may choose to include in your profile/bio.

• Your contacts’ phone numbers (if you choose to authorize this). To help users connect with people they know, we offer them the option to invite friends to join them on the PALCUS Platform. To take advantage of this feature, users can opt in to share phone numbers from their address book or add phone numbers manually.

• Names of friends you choose to invite to join you on the PALCUS Platform.

• Conversations that users and group managers have in PALCUS Platform groups.

• Messages you send to and receive from other users on the PALCUS Platform. We review the contents of these messages only if there are user reports or automated systems flags indicating a Trust and Safety violation.

• Interests, usage, and connections, including information about your interests (if you choose to add them) and how you use the PALCUS Platform, such as the types of groups you engage in, content you share, features you use, actions you take, people or accounts you interact and connect with, and the time, frequency, and duration of your use.

• Communications that we exchange with users when they contact us with questions or feedback, including feedback about interacting with other users.

• Payment and transactional data including name, payment card information, bank account number, billing information, and your transaction history. This information is collected by our payment provider, Stripe, and PALCUS does not have access to payment card numbers. In addition to this Privacy Policy and our Terms of Service, information related to your payments or purchases is also processed according to Stripe’s services agreement and privacy policy.

Automatically Collected Information

• Device data, such as device IP address (and derived location), device name and operating system, browser type and settings, telecommunications provider, operating system, the date and time of PALCUS Platform use, interactions with the PALCUS Platform, and the time, frequency, and duration of the interactions.

Usage of Personal Information

We use personal information to:

Provide our services, including to: 

• Invite you to the PALCUS Platform;

• Operate the PALCUS Platform and our business;

• Maintain, improve, and develop the PALCUS Platform and its features;

• Create and maintain your account;

• Facilitate network connections;

• Recommend groups, users to connect to and other content that might be of interest to you;

• Notify you when one of your contacts has joined the PALCUS Platform;

• Engage Stripe to process your transactions with other users or with us;

• Communicate with you about the PALCUS Platform by sending you push notifications with announcements, updates, security alerts, and support and administrative messages, if you have enabled that functionality; and

• Provide support for the PALCUS Platform, and respond to your requests, questions and feedback.

• Allow group managers to share and promote their groups

Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases and special events. You may opt out of our email marketing communications as outlined below. Please note that we may periodically send you transactional emails even after you opt out of direct marketing.

Research and development. We may create and use de-identified information for our business purposes, including to analyze the effectiveness of our PALCUS Platform, to improve and add features to our PALCUS Platform, and to analyze the general behavior and characteristics of users of our PALCUS Platform.

Support and Maintenance. We use third party analytics services to automatically log certain information about your mobile device and how you interact with the PALCUS Platform. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.

Compliance and protection. We may use personal information to:

• Protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);

• Enforce the Terms of Service that govern the PALCUS Platform;

• Enforce our Community Guidelines by investigating potential Trust and Safety violations using the data collected as described in the Personal Information We May Collect section;

• Audit our internal processes for compliance with legal and contractual requirements and internal policies;

• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We do not sell personal information. In the ordinary course of business, we may share personal information with:

Service providers. Companies and individuals that provide services on our behalf or help us operate the PALCUS Platform or our business (such as hosting, development, maintenance, analytics, customer support, email and SMS delivery).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the Terms of Service that govern the PALCUS Platform; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, PALCUS or our affiliates (including, in connection with a bankruptcy or similar proceedings).

How You Share Information on the PALCUS Platform

Public. When you establish an account on the PALCUS Platform, you share certain of your profile information with the PALCUS Platform community on our PALCUS Platform and on the web. This information includes but it is not limited to your profile picture, bio, name, the date you joined, events to which you have RSVPd, and the groups you have joined. Additionally, you may use certain PALCUS Platform features to create and share content among other users, administrators and group managers. If you do share this content then you choose the audience for what you share, and such sharing will be carried out for your own purposes and not PALCUS'.

PALCUS Platform users. PALCUS Platform users with whom you have some affiliation on the PALCUS Platform or other social media accounts may receive notifications about actions you take on the platform, such as joining groups, or creating

or sharing content. You may also choose to authorize other users to share the content you create.

Your Choices

Update, correct, or delete. You can contact us to ask us to update or correct your information. You may also delete your account. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.

Opt out of push notifications. If you opt-in to receive push notifications within the PALCUS Platform, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the app, or deleting the PALCUS Platform.

Disable optional features. Administrators or group managers may disable PALCUS Platform features available to users.

Other Sites and PALCUS Platforms

The PALCUS Platform may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Processing of Personal Information in the United States

The PALCUS Platform has users located across the globe. We are headquartered in the United States with services providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you. Data Security

You use the PALCUS Platform at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the PALCUS Platform, or third party websites. Finally, we cannot control the actions of users on the platform, who may seek to use third party apps or devices to record, store, or share content or communication without other users' prior consent. Please keep this in mind when using the PALCUS Platform.

Children

The PALCUS Platform is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the PALCUS Platform from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the PALCUS Platform. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the PALCUS Platform. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the PALCUS Platform after the effective date of any modified Privacy Policy indicates your acknowledgment of the modified Privacy Policy.

How to Contact Us

You can reach us by submitting a support request to support@palcus.orgor sending a letter to the following mailing address:

The Portuguese American Leadership Council of the United States

9255 Center St. 404

Manassas, Virginia 20110

United States

Notice to California Residents

We are providing this supplemental privacy notice to Consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

We do not sell personal information.

The CCPA grants California residents the following rights:

• Information. Our Privacy Policy describes how we use and share your personal information through the PALCUS Platform, including during the past 12 months. The Policy describes:

• The sources through which we collect California residents’ personal information and the types of personal information collected in the “Personal Information We May Collect” section above.

• The purposes for which we use and share this information in the “How We Use Personal Information” section above and the “How We Share Personal Information” section above.

• How users share information via the PALCUS Platform in the “How You Share Information on the PALCUS Platform” section of the Privacy Policy.

• Access. You can request a copy of the personal information that we maintain about you.

• Deletion. You can ask to delete the personal information that we maintain about you.

The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.

In accordance with the CCPA, PALCUS Platform will not provide the following information in response to access requests for the reasons described:

• Account data such as identity verification codes, unmasked phone numbers, or email addresses, because of the sensitive nature of this information.

• Other users’ and employees’ personal information, including the names and account information of individuals who may have invited you to the PALCUS Platform, other users’ feedback, and employees’ comments because it is information that belongs to another natural person and disclosing it may impact their rights.

• Internal proprietary attributes that enable us to provide various aspects of our PALCUS Platform, including channel and room customization, suspension decisions, and content suggestions, because it is protected by federal and state trade secret law.

• Server logs that are older than 30 days because we use these to ensure the security and integrity of our PALCUS Platform.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

• To request access to or deletion of personal information collected, please email us at support@palcus.org.

• To verify your identity prior to responding to your requests, we may ask you to provide us with your phone number so we can send you a verification code, or with other details that we may need to verify your identity.

• Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with the CCPA.

Notice to European and Brazilian Data Subjects

We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).

Controller and Representative. PALCUS Platform is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “How to Contact Us” section above.

Our representative in Europe is: AVANCEESoftware, Lda, Rua Dom Jose Alves Correia da Silva 75ª, Traseiras - Fracao A, 2410-119 Leiria, Portugal.

You may contact these representatives at https://www.avanceesoftware.com.

Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Personal Information We May Collect” section above, and how we use it in the “How We Use Personal Information” section above.

Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. PALCUS Platform generally relies on one of the following justifications to process personal data:

• Contractual Necessity, to provide you with the PALCUS Platform in accordance with our Terms of Service.

• Legitimate Interests, where it is necessary for our legitimate business purposes, your interest or the interests of a third party.

• Consent, where required by law. Where we rely on your consent to process personal data about you, you have the right to later withdraw your consent in

Type of Personal Data	Purpose	Justification for Processing Personal Data
Account Data	To create and maintain your account	Contractual Necessity
Account Data	To respond to your inquiries	Contractual Necessity Legitimate Interests: Providing you with the support that you request, and improving our PALCUS Platform and related services
Account Data	To enable you to share your profile with other users, and recommend you to others as a person to create friendship relationship	Legitimate Interests: Helping you connect with other PALCUS Platform users
Account Data	In relation to suspended users, to maintain a record of the suspension	Legitimate Interests: Addressing violations of our Terms of Service or our Community Guidelines
Phone numbers of contacts	To enable you to invite your contacts to join the PALCUS Platform and for those contacts to receive invitations Showing you which of your contacts joins or is already on the PALCUS Platform	Legitimate Interests: Enabling PALCUS Platform users to find and connect with people they know Enhancing user experience
Users' call logs	To verify your phone number	Consent: Users consent via device settings to authorize access
Your interests, usage and connections	To improve your experience when using the PALCUS Platform if you choose to select your interests, including recommending groups, users to become friends with, and content	Legitimate Interests: Personalizing your user experience by providing recommendations for content and people to follow
Name and phone number for users you invite	To improve your experience when using the PALCUS Platform if you choose to send invitations to your contacts	Legitimate Interests: Personalizing your user experience, and enhancing it
Messages you send to and receive from other PALCUS Platform users	To enable you to easily communicate with other users while on the PALCUS Platform	Legitimate Interests: Helping you connect with other PALCUS Platform users
Content and communications to the extent associated with personal data	To investigate Trust and Safety violations as described above	Legitimate Interests: Detecting and combating harmful or unauthorized conduct, and promoting a trusting and safe environment on the PALCUS Platform Complying with legal requirements, assisting law enforcement, and