PRIVACY POLICY
Updated on May 2022
INTRODUCTION
SABIS® Educational Services S.A.L. (collectively referred to as “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 stars.sabis.net website (the “Website”) when they access or use the services available on the Website (the “Services”).
The recipient and controller of the data is SABIS® Educational Services S.A.L., Orange Zone – Adma,
Lebanon
The terms “you,” “your,” and “yours” refer to the user or viewer of the Website/Services, 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 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 privacy@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.
INFORMATION COLLECTED
The type of personal data collected includes the following:
- Contact Details (e.g., name, e-mail address)
- Content Data (e.g., text input)
- Usage Data (e.g., interest in Website’s contents, access time)
- Online/Technical Identifiers (e.g., device information, IP address)
On occasions, the Website’s visitors provide their personal data by using the “Contact us” form. Mandatory details are necessary to make contact with you and process your inquiry.
To improve the way our Website functions for visitors, 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
The data stored in the log files is essential for the Website 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 to 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”.
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
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 the personal data of children under the age of 16 on this Website. Children under the age of 16 (“Minor”) are not permitted to submit their personal data to us. Parents or legal guardians of a child under the age of 16 must complete the form and consent to its submission to us. If we learn that we have collected personal data from a Minor without their parent’s/guardian’s consent, we will delete that information as quickly as possible.
PURPOSE OF DATA COLLECTION
Any of the information we collect from you may be used in the following ways:
- Information You Give to Us Voluntarily
Personal data will be collected and stored about you for the purpose of responding to your inquiries when you contact us, and where you have consented to be contacted for such purpose. - Information We Collect Automatically About You
To ensure that content from our site is presented in the most effective manner 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 in order 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.
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.
If you choose to interact with a third-party service when using our Website, such as Facebook, or Instagram, your data may be processed beyond your country/geographical region. Depending on the social media provider (Facebook - Instagram), 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 the Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, US. For further details about how Meta Platforms, Inc. process your information, please refer directly to the Facebook Data Policy found at: https://www.facebook.com/privacy/explanation
Instagram
The provider is the Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, US. For further details about how Meta Platforms, Inc. process your information, please refer directly to the Instagram Data Policy found at: https://help.instagram.com/519522125107875
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.
Please refer to the Cookies Policy to check the cookies’ storage duration on your device.
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
Being part of the SABIS® Global Network, 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.
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 for 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.
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. Marketing communications are not carried out.
- 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 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.
