Updated in October 2024

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 cadmus.sabis.net website (the “Website”) and the services available on the Website.

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.

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, 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 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 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.”

Data Subject: Any individual using the Website and whose personal data is being collected, held, or processed.

INFORMATION COLLECTED

The type of Personal Data collected on our Website includes the following:

• Contact Details (e.g. full name, E-mail address, phone number)
• Content Data (e.g. text input)
• Usage Data (e.g. interest in Website’s contents, access time)
• Usage Data (e.g., interest in Website’s contents, access time)
• Online/Technical Identifiers (e.g. IP address) 

The Website’s visitors provide their Personal Data when using the "Contact us" form and/or subscribing to our newsletters. Mandatory details are necessary to make contact with 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 automatically erased within 7 calendar days.

This Policy also applies to the Personal Data we collect from you via the use of cookies and related technologies to maintain an anonymized user session and to provide users with personalized web pages. You can control how you use cookies by adjusting the settings within your browser. 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. 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 who are under the minimum required ages specified herein. You must be at the age of majority in your jurisdiction to use our Services. Individuals under the applicable age may use our Services only through a parent or legal guardian's supervision and with their involvement. 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

Any of the information we collect from you may be used in the following ways:

1. Personal Data you give to us voluntarily. The personal data collected and stored about you will be used to respond to your inquiries when you contact us, or to send you our newsletters when you sign up for receiving them, and where you have consented to be contacted for such purpose. 
2. Personal Data we collect automatically about you. To ensure that the content from our Website is presented most effectively for you, to administer our Website, and 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 whether on the personal data you provide voluntarily or the personal data we automatically collect from you.

You may request to stop receiving any marketing material by sending an e-mail to privacy@sabis.net or by clicking on the "unsubscribe" button at the bottom of the marketing material received email.

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, 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 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.

If a breach of information happens, we will inform you by e-mail as soon as we have knowledge 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.

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

PERSONAL DATA RETENTION

We will endeavor to keep your Personal Data accurate and up-to-date, and not keep it for longer than is necessary. 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 information we collect from you for our newsletter subscription would be deleted once you unsubscribe.

Cookies will remain stored on your device until you delete them.

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 you are using.

PERSONAL DATA TRANSFER AND SHARING

SABIS Educational Systems, Inc., maintains our Website and databases where the personal data of the data subjects covered by this Policy is stored in an anonymized format. Therefore, your Personal Data will be transferred to SABIS Educational Systems, Inc., Eden Prairie, Minnesota, USA, which works together with the processor Lumen Technologies, Inc., USA, on the provisioning of IT systems.

As this website is operated by SES, your personal data may be accessed by authorized personnel from SES to ensure that the Services are adequately provided. 

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 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 dependent on the purpose for the 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 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 for our legitimate interests, to provide you with the Services, such as connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and 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

You have specific rights related to the processing of your Personal Data, which may be exercised under certain circumstances. 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, 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.
• 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 format, 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 any concerns or questions, you may contact us by 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.