INTRODUCTION
SABIS Educational Services S.A.L. (collectively referred to as
"SES", "we", "us", "our", "ours") values and takes your privacy rights seriously.
We are committed to being transparent about the data we collect about you, how it
is used, and with whom it is shared as set forth herein. This Privacy Policy (the
"Policy") applies to the data collected from all users of the sltc.sabis.net website
(the "Website") and the services available on the Website (The "Services").
The Website is operated by:
SABIS Educational Services S.A.L.
Orange Zone, Adma
Tel.: +961-9-851851
Lebanon
The terms "you", "your", and "yours" refer to the user or visitor of the Website
(For children below a certain age, depending on the jurisdiction of residency,
these terms shall refer to their parents/legal guardians consenting on behalf of
their child(ren)).
This Policy, together with our Terms & Condition, sets out the basis on which any
Personal Data (as defined below) we may collect about you or that you choose to provide
to us and your choices and rights regarding our use of your Personal Data. It also
explains the purpose(s) of processing your Personal Data, how we keep it safe, and with
whom we share it. Please read the following sections carefully to understand our views
and practices regarding your Personal Data and how we handle it.
We reserve the right to make changes to this Policy at our sole discretion periodically.
Changes to the Policy will be posted on this page.
HOW TO CONTACT US
Questions, comments, and requests regarding this Policy should be addressed via e-mail at dpo@sabis.net
DEFINITIONS
Personal Data:
Personal data is defined as "any information relating to an identified or identifiable
natural person ("data subject"); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier such as
a name, identification number, location data, online identifier, or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural, or social
identity of that natural person."
Data Subject in this Policy refers to:
Any individual using the Website and whose Personal Data is being collected, held, or
processed.
Processing:
means any operation performed on personal data, such as collection, recording, storage,
use, disclosure by transmission, erasure, or destruction.
A cookie:
is a small file of letters and numbers that we store on your browser or your device when
you visit our website for its proper operation
INFORMATION COLLECTED
The type of Personal Data collected on our website about students and parents/legal guardians includes but is not limited to the following:
- Contact Details (e.g. full name, date of birth, phone number, school name, grade, passport copy, photo, E-mail address)
- Health-related Data (e.g. allergies, medications, medical history)
- Travel Details (e.g. flight information, scanned copy of the travel insurance)
- Usage Data (e.g. interest in Website’s contents, access time)
- Online/Technical Identifiers (e.g. IP address)
The Website's visitors and users provide their Personal Data when using the "Contact Us" Form, the "Participant Form" and the "Medical Form". Mandatory details are necessary to respond to your inquiries when you choose to contact us and/or to process the participant's application to attend the "Student Life Training Conference" (the "Conference"). In addition, to administer our website, to monitor, investigate, and report any security breach attempts on our website, we automatically collect the following:
- Information about the browser type and version used
- The visitor's IP address
- The date and time of access
Note: The data stored in the log files is essential for the Website's operation and is
automatically erased within seven calendar days from the access date.
The Policy also applies to the Personal Data we collect from you via cookies and related
technologies to maintain an anonymized user session and provide users with personalized
web pages. You can control how you use cookies by adjusting the settings within your
browser. For further information, please see our "Cookies Policy".
CHILDREN’S PRIVACY
We place a lot of importance on protecting the privacy of young children who may use the website. We do not knowingly solicit or collect Personal Data from individuals under the minimum required ages specified in the concerned jurisdiction where they reside. You must be at the age of majority in your jurisdiction to use our Services. Children under the applicable age are not permitted to submit any form available on the website. Parents or legal guardians of a child under the minimum required age must complete the form and consent to its submission through the website. If you are a parent or legal guardian who believes your child has provided Personal Data to us without your consent, you may ask us to delete such information by contacting us at privacy@sabis.net.
PURPOSE OF DATA COLLECTION AND PROCESSING
The Personal Data we collect and process about you and which you voluntarily provided through the Website, will be used to organize the Conference and/or contact you and respond to your request. This includes, but is not limited to:
- Tracking flights arrivals and departures in order to arrange for transportation and safety
- Maintaining records in case there is an emergency so that we can take proper actions, whether medical or otherwise
- Making the needed reservations and obtaining the required permits
- Preparing all the required material regarding the Conference
- Ensuring the best data handling and avoiding any coordination oversights
- Ensuring a safe visit and learning environment
- Replying to your inquiries
Also, the Personal Data we collect automatically about you is to ensure that the content from our website is presented most effectively for you, to administer our website, and to improve the user experience and performance of our website. No automated or profiling-based decision-making would be performed.
DATA SECURITY
We will securely process your Personal Data. We have implemented administrative, technical, and physical security measures to help prevent accidental or unlawful destruction, 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 website. We make reasonable efforts to restrict access to Personal Data to only employees and agents who need access to such information in order to operate, develop, improve, or deliver our programs, products, and services. The security of the Personal Data collected for the purposes mentioned above is important to us and we confirm to apply acceptable security measures and procedures to ensure the confidentiality, integrity, and availability of the Personal Data.
LINKS TO OUR SOCIAL MEDIA PORTALS
We maintain an online presence on social media networks and platforms in order to communicate with users and interested parties and inform them about our services. Therefore, your Personal Data may be processed beyond the country/geographical region in which you are resident. Depending on the social media provider and/or the online video hosting services (Facebook - Twitter - Instagram - YouTube - Vimeo), they may perform other data processing. For details, refer to the respective platforms' terms of use and data privacy policies. We are not responsible for third-party links to other websites. We are not responsible for the content or data processing generated on third-party websites and accessible by links or hyperlinks on our website. We will also not be responsible for the Personal Data that they share on other websites or social media platforms.
EXTERNAL LINKS
Our website contains links to external websites within the SABIS® Global Network. Please refer to each of these websites' privacy policies to know more about data processing on these external websites.
PERSONAL DATA RETENTION
We will endeavor to keep your Personal Data accurate and up-to-date and not keep it longer than necessary to achieve the purposes mentioned above. You may request to modify any erroneous, inaccurate, misleading, or incomplete Personal Data. The Personal Data you submit under the "Contact Us" form will be stored in our databases for one year only in an anonymized format and would be automatically deleted afterward. Also, the Personal Data we collect from this Website for participation in the Conference will be retained for the duration of the Conference and will then be automatically deleted at the end of the Conference. If, for any reason, the process of an application to join the Conference is stopped before the event start date, we hereby confirm that the Personal Data and any document provided in this application would be automatically deleted. We have no impact over the duration for which data held by social network operators are stored for their own purposes. For details, please refer directly to the privacy policy of the social network platform you are using.
PERSONAL DATA TRANSFER AND SHARING
The website and its related database, where your Personal Data is stored anonymized, are hosted in the LumenSM Minnetonka Permier Select Data Center in Minnesota, United States.
The data center is maintained by authorized SABIS Educational Systems, Inc. personnel.
In addition, the Personal Data collected and sorted by SES, who would be coordinating the Conference preparation with the schools, may be shared with any of the following parties solely in connection with the arrangements of the Conference and for the purposes mentioned above:
- SABIS® Educational Services S.A.L. (mainly the Student Life Organization)
- The school of the participant attending the event
- The Student Life Coordinators attending the event
- The relevant embassy to process the visas
- The travel agency in the local country
- The Hotel upon check-in in the country where the Conference will be held.
- The Hospitals in case of emergencies, medical care, or treatment in the country where the Conference will be held.
- Other health service providers when needed in the country where the Conference will be held.
- The phone stores in the country where the Conference will be held; They will need a copy of the participants' passports if they wish to purchase a local SIM card for their phones.
DISCLOSURE TO THIRD PARTIES WITHOUT PREJUDICE TO THE PREVIOUS CLAUSE
With the exception of the events listed above, we do not pass on your Personal Data to 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 is:
Your informed consent: We process your Personal Data if you have consented to the processing
activity for the purposes mentioned above. You may withdraw 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 for our legitimate interests to provide
you with the Services. Any such Processing is conducted subject to appropriate measures to
protect your fundamental rights and freedoms related to your Personal Data and will, in any
event, be subject to the restrictions provided in this Policy.
DATA SUBJECT RIGHTS
With regards to the specificities of the applicable jurisdictions' laws and regulations, and in certain circumstances, you have certain rights regarding your Personal Data. A summary of each right and how you can exercise it is set out below. The exercise any of these rights, please contact us by sending an e-mail to privacy@sabis.net
- Right of access - You have the right to request a copy of the Personal Data we hold about you from us.
- Right of rectification - You have the right to ask us to correct inaccurate, irrelevant, incomplete, out-of-date, false, or impertinent Personal Data we hold about you.
- 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 receive the Personal Data we hold about you in a structured, generic, commonly used, and machine-readable format. You also have the right to transmit this Personal 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 specific treatment, as well as to revoke the consent you have given us and to opt out of any marketing communications that we may sent you.
- Right to object 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 any concerns or questions, you may contact us using the "Contact Us" page on this Website. For data protection inquiries, or if you consider that we did not process your Personal Data in accordance with the applicable regulations, please contact us by sending an e-mail to privacy@sabis.net
ACCEPTANCE AND CHANGES TO THE POLICY
By using our website, you are explicitly consenting and confirming that you have read and agree to all the terms and conditions in this Privacy Policy. At times, we may change and/or update this Policy. Any changes we may make to this Policy in the future will be posted on this page. We encourage you to periodically review this page for the latest information on our privacy practices.