PRIVACY POLICY
Updated on September 2021
INTRODUCTION
SABIS Educational Services S.A.L. (collectively referred to as “SES”, “we”, “us”, “our”, or “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 uniapp.sabis.net web application (the “Website”) and the services available on the Website (the “Services”).
The recipient and controller of the data is:
SABIS Educational Services S.A.L.
Registered in Lebanon under company number 52471
Adma - Orange Zone – Jounieh
Lebanon
The terms “you,” “your,” and “yours” refer to the user of the Website/Services.
This Policy, together with our Terms of Use, 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 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 addressed to our Data Protection Officer 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.”
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.
PURPOSE OF THE WEBSITE
The purpose of the Website is to allow eligible registered SABIS® students to apply to several universities by filling in and submitting their unified university application to their chosen university(ies)/college(s).
INFORMATION COLLECTED
The type of personal data we collect about you include the following:
- Personal Details (e.g. name, home address, E-mail address, phone number, official transcript, diploma, tests scores)
- Content Data (e.g. text input)
- Identity Verification (e.g. photo, passport number, date of birth)
- Usage Data (e.g. interest in website’s contents, access time)
- Online/Technical Identifiers (e.g. device information, IP address)
We collect your personal data through an “Online University Application” form, which allows you to apply to a number of universities selected by you.
To contact us, you may provide your personal data by using the “Contact us” form. The mandatory fields are necessary to make contact with you and process your inquiry.
To improve the way our website functions, to monitor, investigate, and report any security breach attempts of 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 operation and is erased within 7 working days.
This Policy also applies to personal data we collect from you via the use of cookies and related technologies to provide users with personalized web pages. Cookies are small files of letters and numbers that we store on your browser or your device when you visit our site. They help us to improve our site and to deliver a better and more personalized service. Some of the cookies we use are essential for the site to operate properly. You can control how you use cookies by adjusting the settings within your browser. For further information, please see our “Cookies Policy”.
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, 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
PURPOSE OF DATA COLLECTION
Any of the information we collect from you may be used in the following ways:
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1. Information you give to us voluntarily
- Personal data will be collected and stored about you, being an eligible registered SABIS® student, to allow you to apply to several universities by submitting a unified application that will be shared with the university(ies)/college(s) selected by you. In addition to responding to your inquiries when you choose to contact us.
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2. Information we collect automatically about you
- To ensure that content from our site is presented most effectively for you, to administer our website, and to perform internal statistical and trend analysis to improve the user experience and performance of our website.
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 and we confirm to apply acceptable security measures and procedures to ensure the confidentiality, integrity, and availability of the data.
In respect of any actual personal data breach, we will inform you as soon as we have knowledge and become aware of the event.
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.
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.
The information you submit under the “Online University Application” and the “Contact us” forms will be stored in our databases in the United States in an anonymized format for twenty-five years after your graduation.
Our Data Center and databases are maintained by SABIS Educational Systems, Inc., Eden Prairie, Minnesota, USA, which works with the processor CenturyLink Inc, Monroe, Louisiana, USA, on the provisioning of IT systems.
We do not store any financial details about you in our databases. When applicable, if you make a payment to complete the “Online University Application” fee on our Website, the details you are asked to submit will be provided directly to our payment provider PayFort International FZ LLC via a trusted secured connection.
Cookies will remain stored on your device until you delete them.
PERSONAL DATA TRANSFER AND SHARING
Your personal data will be provided to third-party partner universities/colleges to assist you as a Grade 11 or 12 student, studying at a SABIS® member school, in applying to specific partner universities/colleges online. By applying through the Website, you explicitly confirm that we may transfer your personal data to the university(ies)/college(s) you are applying for and solely for the Purpose listed above.
We will not disclose your personal data to any other entities under any circumstances, unless required by law, regulatory or governmental authority, or further to your request/approval.
Your financial information will be directed to a trusted secured online gateway provided by PayFort International FZ LLC to complete the “Online University Application” fee payment, when applicable.
LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
Our legal basis for processing your personal data is dependent on the purpose for processing as described in this Policy. In general, we process your Personal Data under the following legal bases:
Your Consent
By explicitly consenting to this Policy you are giving us permission to process your personal data specifically for the Purpose identified.
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 of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. However, please understand that by withdrawing your consent you will not be able to access/use the Website.
Legitimate Interests
We process your personal data for our legitimate interests, to provide you with the Services. Any of such processing is conducted 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 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 complain to the Data Protection Authority (DPA) in the country where you reside, or the alleged infringement of data protection laws has taken place.
ADDITIONAL INFORMATION
For any concerns or questions, you may contact us
- 1. Using the “Contact us” page on this website
- 2. Emailing us at: privacy@sabis.net
- 3. Writing us at: SABIS Educational Services S.A.L., P.O. Box: 811, Adma – Orange Zone, Jounieh – Lebanon
ACCEPTANCE AND CHANGES TO THE POLICY
By using our Website/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.