PRIVACY NOTICE

Updated in November 2024

INTRODUCTION

 

This Privacy Notice (the "Notice") applies to the data collected from all users of the (Insert the URL[EH1] ) web application (the "Application") and the available services (the “Services”).

 

The Application is provided by:

SABIS Educational Services S.A.L. – Lebanon (SES LEB)

Orange Zone, Street No.15, Adma, Keserwan, Lebanon

Telephone: +961 9 851951

 

The Application is operated by:

 

Insert the school full name (the “School”)

The school’s full Address

Telephone and email [EH2] 

 

 

The main Services provided by the Application, which is used by Authorized Users at the School, include contact management, meeting booking , enrollment management, report generation, and analytics. Additionally, the Application facilitates the creation of both physical and electronic forms, designed to collect Personal Data from End Users for various purposes, such as expressing registration interests , booking meetings, participating in events , and subscribing to School newsletters and other communications.

This Notice covers:

 

• The Personal Data collected from the School’s Authorized Users, as defined below.
• The Personal Data collected from the End User, as defined below. 

 

This Notice sets out the basis for processing any Personal Data collected through the Application , how it is protected, and with whom it may be shared.

This Notice may be updated periodically, and any changes will be posted on this page.

 

HOW TO CONTACT US

Questions, comments, and requests regarding this Notice should be addressed via e-mail at [Insert the School’s email]. 

 

DEFINITIONS

Personal Data: Personal data is defined as "any information relating to an identified or identifiable natural person".

 

End User: Prospect parents, leads, and other interested individuals who are submitting their Personal Data through the E-forms created by the School’s Authorized Users for the purposes listed below. 

 

School Authorized Users: Authorized users designated by the School to operate the Application. 

 

Data Subject: In this document, the School Authorized Users and End Users will be jointly referred to as “Data Subject(s)”. 

 

INFORMATION COLLECTED

The types of personal data collected on the Application include, but are not limited to, the following:

 

• Contact Details (e.g., full name, E-mail address, phone number)
• Work-related Data for the Application Authorized User (e.g., Job title/position)
• Content Data (e.g., text input)
• Usage Data (e.g., interest in the Application’s contents, access time)
• Online/Technical Identifiers (e.g., IP address)

End Users provide their Personal Data when they fill out a form/E-form to express their interest in school admissions, participate in school-organized events, or subscribe to receive news and updates from the School. Mandatory information is required to enable the School to contact the End User and process their inquiry.

To improve the way the Application functions, monitor, investigate, and report any security breach attempts of the Application, the following is collected[EH3] [NA4] :

• Information about the browser type and version used
• The visitor's IP address
• The date and time of access

This Policy also applies to the Personal Data collected via [EH5] [NA6] the use of cookies and related technologies to maintain an anonymized user session and to provide users with personalized web pages. Data Subjects can control the use of cookies by adjusting the settings in their browser. A cookie is a small file consisting of letters and numbers that is stored on the Data Subject’s browser or device when visiting the application for its proper operation. For further information, please see our "Cookies Policy."

 

PURPOSE OF DATA COLLECTION

Any Personal Data collected through the Application may be used in the following ways:

 

• Personal Data provided voluntarily: For School Authorized Users, this Personal Data will be used to create and maintain their accounts for accessing and operating the Application. 

For End Users, the collected Personal Data will be processed by Authorized Users for the specific purpose for which it was collected. For example, Personal Data collected from an End User via an interest form will be used to assist with the admission process. Similarly, Personal Data collected for an event will be used to register the End User for that specific event.

• Personal Data collected automatically: This data helps ensure the content from the Application is presented effectively, aids in administering the Application, and supports internal statistical and trend analysis to enhance user experience and Application performance.   

 

No automated or profiling-based decision-making will be performed.

 

 

DATA SECURITY[EH7] [NA8] 

We will process (collect, store, and use) your Personal Data in a secure manner.

 

We have implemented administrative, technical, and physical security measures to help prevent accidental or unlawful destruction or loss, alteration, unauthorized disclosure, transfer, or access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our Application.

 

Role-Based Access Control (RBAC) has been implemented to ensure data security, allowing access only to authorized personnel from the School. This also applies to authorized employees from SES LEB, who may access the personal data upon the School’s request for technical support.

 

We make reasonable efforts to restrict access to Personal Data to only employees and agents who need it to operate, develop, improve, or deliver our programs, products, and services.

 

We value the security of your Personal Data collected for the purposes mentioned above and confirm that we will apply acceptable security measures and procedures to ensure its confidentiality, integrity, and availability.

 

If a breach of information occurs, we will notify you by e-mail as soon as we become aware of it.

  

PERSONAL DATA RETENTION[EH9] 

We will endeavor to keep your Personal Data accurate and up-to-date and retain and process it for as long as necessary for the specified purposes. You may request to modify any erroneous, inaccurate, misleading, or incomplete Personal Data. 

The retention of Personal Data differs according to the purpose of its collection. Details are as follows: 

• Admission Interest: Data will be retained until August 1 of the academic year of interest. (would it be automatically deleted?)[NA10] 
• Event Interest: Data will be retained for 10 days after the event. (would it be automatically deleted?)
• News & Update Interest: Any Personal Data collected from End Users for news and update subscriptions will be deleted upon their un-subscription or request by sending an email to the School (if possible add an email address)
• Parent Data: Data will be retained as long as the student is enrolled and will be deleted one year after the student leaves the school. (automatic deletion)

 

Personal Data Hosting and Sharing

The Application and its related databases are maintained by SES LEB and hosted on the Microsoft Azure Cloud in Europe. Personal Data collected through the Application will be stored in the School’s designated database within Microsoft Azure.

Authorized SES LEB personnel may access Personal Data, as directed by the School, to ensure proper service delivery and provide technical support. Additionally, Personal Data collected from the Services may be transferred to the School’s local server to provide the Data Subject with educational, administrative, and registration support when applicable.

 

DISCLOSURE TO THIRD PARTIES WITHOUT PREJUDICE TO THE PREVIOUS CLAUSE

We will not share your Personal Data with third parties without first obtaining your informed consent. 

 

However, we may be required to disclose your Personal Data if we receive a valid request from a judicial authority, the police, or other law enforcement agency, regulatory or government authority in your country of origin or elsewhere. 

 

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA

Our legal basis for processing your Personal Data depends on the processing purposes and may vary as described in this Notice and the Services you are using. 

 

We process your Personal Data under the following legal basis:

 

Your informed consent: We process your Personal Data if you have consented to the processing activity. You may revoke your consent at any time by sending an e-mail to privacy@sabis.net. Doing so will bar us from further processing your Personal Data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn.

Legitimate Interests: We process your Personal Data in our legitimate interest to provide you with the Services available on the Application. 

 

DATA SUBJECT RIGHTS

Under certain circumstances, you have specific rights regarding your Personal Data. Below is a summary of each right and instructions on how to exercise it. If you would like to exercise any of these rights, please contact us by sending an e-mail to privacy@sabis.net[NA11] .

• Right of access ­– You have the right to request a copy of the personal data we hold about you.
• Right of rectification ­– You have the right to ask us to correct inaccurate, irrelevant, incomplete, out-of-date, false, or impertinent data we hold about you.
• Right to request deletion – In certain circumstances, you can ask for the inaccurate, irrelevant, incomplete, out-of-date, false, or impertinent data we hold about you to be erased from our records. Personal Data that is deleted from the Application may still be held on the school servers on a need-to-have basis.
• Right to restriction of processing – Under certain conditions, you have the right to ask us to restrict the processing of your personal data.
• Right of portability – ­You have the right to have the data we hold about you in a structured, generic, commonly used, and machine-readable format. You also have the right to transmit this data to another organization where technically feasible.
• Right to object – You have the right to object to certain types of processing, such as direct marketing. You are allowed, for well-founded and legitimate reasons related to a particular situation, to refuse to provide your personal data or to have it subject to a certain treatment, as well as to revoke the consent you have given us and to opt out of any marketing communications that we may send you.
• Right to object to automated processing, including profiling – Profiling-based activities are not carried out under any circumstances.
• Right to lodge a complaint – If you have a legal basis to object to our processing of your Personal Data, you have the right to complain to the Data Protection Authority (DPA) in the country where you reside or the alleged infringement of data protection laws that have taken place.

 

CONCERNS AND INQUIRIES

For data protection inquiries, please contact us by sending an e-mail to privacy@sabis.net.[EH12] 

 

ACCEPTANCE AND CHANGES TO THE NOTICE

By using the Application, the Data Subjects explicitly consent to and confirm that they have read and agreed to all the terms and conditions in this Notice.

 

[NA13] 

This Notice may be occasionally changed and/or updated. Any changes that may be made to this Notice in the future will be posted on this page. Data Subjects are encouraged to periodically review this page for the latest information on privacy practices.