Privacy Policy INTRODUCTION SABIS® SUN International School – Baku (collectively referred to as the "School", "we", "us", "our", or "ours") values and takes your privacy rights seriously. We are committed to be 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 personal data collected from all users of the sabissun.sabis.net website (the “Website”) and the services available on the Website (the “Services”). The Website is operated by: SABIS® SUN International School – Baku Zigh Highway, 22km towards H. Aliyev Int’l Airport, Dreamland, Baku, Azerbaijan The terms “you,” “your,” and “yours” refer to the user or visitor of the Website/Services and/or the parent or legal guardian of a student as applicable. This Policy, together with our Terms & Conditions, sets out the basis on which any personal data 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 of processing your personal data and how we keep it safe. 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 periodically to this Policy at our sole discretion. Changes to the Privacy Policy will be posted on this page. HOW TO CONTACT US Questions, comments, and requests regarding this Policy should be sent to the following e-mail address: privacy@sabis.net DEFINITIONS 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.” Processing: Any operation performed upon personal data, including but not limited to collection, storage, use, erasure, recording, disclosure, transmission, alteration, distribution, etc. Data Subject: Any individual whose personal data is being collected, held, or processed. INFORMATION COLLECTED ON OUR WEBSITE The type of personal data collected about you may include the following: Contact Details (e.g., name, home address, e-mail address, phone number) Content Data (e.g., text input) Identity Verification (e.g., date of birth, nationality, passport number) Usage Data (e.g., interest in Website’s contents, access time) Online/Technical Identifiers (e.g., device information, IP address) We collect most of the personal data held about a Data Subject directly from you through the submission of an “Interest Form” or an “Application Form” essential to process your application by providing you with the requested Services and contacting you. On occasions, visitors provide their personal data when interacting with our Website by submitting the “Contact Us” form where the mandatory details are necessary to contact you and process your inquiry. To improve the way our Website functions for visitors, and to monitor, investigate, and report any security breach attempts on our Website, we automatically collect: Information about the browser type and version used The user'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 erased within 7 days. This Policy also applies to personal data we collect from you via the use of cookies and related technologies to maintain an anonymized users’ 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”. We place a lot of importance on protecting the privacy of young children who may use the Website. We do not knowingly collect any personal data from children under the age of 18. If you think that your child provided this kind of information on our Website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records. Parents or legal guardians of a child under the age of 18 must complete the needed forms and consent to the submission of any information to us. PURPOSE OF DATA COLLECTION Any of the information we collect from you may be used in the following ways: 1. Information You Give to Us Voluntarily Personal data will be collected and stored about the student and his/her family for evaluation, admission, and/or communication purposes. Where we collect and receive your Personal Data, we will use it to respond to your inquiries when you contact us or to send you our newsletter when you sign up for it, and where you have consented to be contacted for such purpose. 2. Information We Collect Automatically About You To ensure that content from our site is presented most effectively for you, administer our Website, and perform internal statistical and trend analysis to improve our website's user experience and performance. No automated or profiling-based decision-making would be performed. DATA SECURITY 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, 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 information to only employees and agents who need access to such information to operate, develop, improve, or deliver our programs, products, and services. The security of your personal data, collected for the above-mentioned purposes, is important to us. We confirm applying acceptable security measures and procedures to ensure the confidentiality, integrity, and availability of the data. LINKS TO OUR SOCIAL MEDIA PORTALS We maintain an online presence on social media networks and platforms to communicate with users and interested parties and inform them about our services. If you choose to interact with a third-party service when using our Website, such as Facebook, Instagram, or YouTube, your data may be processed beyond your country/geographical region. Depending on the social media provider, it may be that other data processing activities are performed by them. For details, refer to the following terms of use and data privacy policies of the respective social media portals. Facebook The provider of this platform is Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, US. For further details about how Meta Platforms, Inc. processes your information, please refer directly to the Facebook Data Policy found at: https://www.facebook.com/privacy/explanation Instagram The provider is Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, US. For further details about how Meta Platforms, Inc. processes your information, please refer directly to the Instagram Data Policy found at: https://help.instagram.com/519522125107875 Twitter We use the short messaging service Twitter. The provider is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. You may adjust your Twitter data privacy settings independently via your user account. To do so, click on this link and log in: https://twitter.com/personalization For further details please refer to the Twitter privacy policy: https://twitter.com/de/privacy LINK TO ONLINE VIDEO HOSTING We use Vimeo, the online video hosting service from Vimeo Inc., 555 West 18th Street New York, New York 10011, on our Website. You may adjust your Vimeo data privacy settings by referring to their privacy policy found at: https://vimeo.com/privacy 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 the processing of data on these external websites. USE OF GOOGLE ANALYTICS The Website uses Google Analytics – a web analytics service from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. (“Google”) – to generate reports on the Website activities, which help us improve our services using active IP anonymization. For more information about Google Analytics cookies, you can access the following link: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage To opt-out of Google Analytics (relating to your use of our Website), you can adjust your cookies settings, or you can download and install the Browser Plugin available by visiting: https://tools.google.com/dlpage/gaoptout?hl=en USE OF GOOGLE MAPS We use Google Maps on our Website. Google Maps is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The Google Maps plug-in is included by embedding the service on our Website using what is known as iFrames. When loading these iFrames, Google may collect and process information (including personal data) under certain circumstances. We cannot exclude the possibility that Google may also transmit this information to a server in a different country. We do not collect any data when you use Google Maps through our Website. The purpose of having Google Maps on our Website is to display our address and make further information available to you by providing access routes to the respective locations; therefore, making it possible for you to plan your journey independently. Information on Google’s existing Privacy Shield certification and other relevant data on Google’s data processing within the framework of the use of Google services can be found at: https://policies.google.com/privacy The legal basis for the processing of personal data described herein is for your legitimate interest in benefiting from the great services which Google Maps offers. USE OF HUBSPOT We use the services of HubSpot for the registration and communication processes. The HubSpot features utilized by our website include the platform’s customer relationship management system, mass email feature, forms feature, landing page feature, sending one-to-one emails, and real-time live chat feature. HubSpot is an American developer of software products for inbound marketing, sales, and customer service. The personal data collected using HubSpot services may be processed in the USA. Further information about the use and protection of data by HubSpot is provided on the HubSpot website at the following link: https://legal.hubspot.com/privacy-policy. When you choose to fill out the forms online, your personal data will be accessed through the HubSpot platform by our authorized employees, who help us in providing you with these services. PERSONAL DATA ERASURE AND STORAGE DURATION We will endeavor to keep your information accurate and up-to-date, and not keep it for longer than is necessary. Information 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 information we collect from you for our newsletter subscription would be deleted once you unsubscribe. Information you submit under the “Interest Form” will be stored in our databases in an anonymized format for two years in case of students’ non-admission and for twenty-five years after the student’s graduation/departure from the school in case of prospective students’ acceptance. Information you submit under the “Application Form” will be stored in our databases in an anonymized format for twenty-five years after the student’s graduation/departure from the school. 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 social network operators’ privacy policies. PERSONAL DATA TRANSFER AND SHARING We are part of the SABIS® Global Network. Therefore, your personal data will be transferred to SABIS Educational Systems, Inc., Eden Prairie, Minnesota, USA, which works together with the processor CenturyLink Inc, Monroe, Louisiana, USA, on the provisioning of IT systems. SABIS Educational Systems, Inc., maintains our Website and databases where the personal data of Data Subjects covered by this Policy is stored in an anonymized format. If you choose to register for receiving our newsletter, your E-mail address will be stored in the Website’s databases in an anonymized format and shared with SABIS Educational Services S.A.L., Adma, Orange Zone, Lebanon, which provides this service on our behalf. And, to operate, develop, improve, deliver, and support the Websites and the Services, your personal data is transferred to SABIS Educational Services S.A.L., Adma, Lebanon, where access to your personal data is restricted to authorized personnel. DISCLOSURE TO THIRD PARTIES WITHOUT PREJUDICE TO THE PREVIOUS CLAUSE We do not pass on your personal data to third parties without first obtaining your consent. However, we may be required to disclose your personal data if we receive a valid request from 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 dependent on the purpose of processing and may vary as described in this Policy and the service you are using. In general, we process your personal data under the following legal bases: Your 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 of 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 processing activity conducted is subject to appropriate measures to protect your fundamental rights and freedom related to your personal data, and in any event, will be subject to the restrictions provided in this Policy. DATA SUBJECT RIGHTS 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. To 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 from us a copy of the personal data we hold about you. Right of rectification – you have the right to ask us to correct inaccurate or incomplete data we hold about you. Right to request deletion – in certain circumstances, you can ask for the data we hold about you to be erased from our records. 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, 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. 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 object to our processing of your personal data, you have the right to lodge a complaint with your national Data Protection Authority (DPA). ADDITIONAL INFORMATION For any concerns or questions, you may contact us by: Using the "Contact us" page on this Website Emailing us at: privacy@sabis.net ACCEPTANCE AND CHANGES TO THE POLICY By using our services, you signify your agreement to this Privacy Policy. Any changes we may make to this Policy in the future will be posted on this page.
