SES Inc. Data Privacy Framework Privacy Notice
Effective on: 01/28/2024
Introduction and Scope
SABIS Educational Systems INC. ("SES INC" "we," "us," "our") takes the protection of personal data very seriously. This Data Privacy Framework Privacy Notice (the "Notice") is directed at data subjects whose personal data we may receive from our customers or business partners in our hosted education administration and HR software applications. This Notice does not apply to personal data we collect by other means, such as personal data that we receive directly through SES INC and International School of Frankfurt's (ISF) own publicly accessible websites.
EU-U.S. Data Privacy Framework
SES INC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. SES INC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/ .
Dispute Resolution
Where a privacy complaint or dispute cannot be resolved through SES INC"s internal processes, SES INC has agreed to participate in the VeraSafe Data Privacy Framework Procedure . Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/ .
Categories of Personal Data
The following is a non-exhaustive list of categories of personal data we process:
Biographical data - names, date of birth, government-issued identification numbers, address, email address, phone number;
Demographic data - age, gender, race, income;
Content data - text, images, videos, username and login information;
Financial data - employment and tax information;
Personally Identifiable Information within students" academic records;
Health data of students; and
Payroll, HR benefits, and criminal backgrounds of SES INC employees.
Controllership
In the context of this Notice, ISF acts as the data controller. SES INC acts as a data processor for the personal data we process.
Purpose of Processing
We process personal data for the following purposes:
Education administration;
School Management; and
Human resources.
When the purposes of processing are satisfied, we will keep your personal data for one year only in an anonymized format and will be automatically deleted afterward.
Data Subject Rights
SES INC acknowledges the right of EU individuals to access their personal data pursuant to the Data Privacy Framework and will grant individuals reasonable access to personal information it received pursuant to the Data Privacy Framework Principles. In addition, SES INC will take reasonable steps to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or processed in violation of the Principles. An individual may request to access their information, or otherwise correct, amend, or delete their information in line with the EU-U.S. Data Privacy Framework Principles by contacting us at privacy@sabis.net.
Sharing Personal Data with Third Parties
We share personal data with our service providers, who process personal data on behalf of SES INC. Such third parties include but are not limited to, those that are:
Managing our IT systems and infrastructure; and
Providing support for marketing and communications.
Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your personal data to such third parties, or we will require those third parties to maintain at least the same level of confidentiality that we maintain for such personal data ourselves. SES INC remains liable for the protection of your personal data that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
Other Disclosure of Your Personal Data
We may disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company"s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any personal data, for any legal business purpose.
If we must disclose your personal data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain the privacy or security of your personal data.
Access & Review
If you are a data subject about whom we store or process personal data, you may have a right to request access to, and the opportunity to update, correct, or delete, such personal data. To submit such requests or raise any other questions, please contact us by email at privacy@sabis.net or by completing a Request Form at our “Contact Us” webpage.
Changes to this Privacy Notice
If we make any material change to this Notice, we will post the revised Notice to this web page and update the “Effective” date above to reflect the date on which the new Notice became effective.
Contact Us
If you have any questions about this Notice or our processing of your personal data, please write to our Privacy Team by email at privacy@sabis.net or by postal mail at:
SABIS Educational Systems
Attn: Joel de Leon, Legal Counsel
6385 Beach Rd
Eden Prairie, MN 55344
USA
Please allow up to four weeks for us to reply.
Binding Arbitration
If your dispute or complaint cannot be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Data Privacy Framework"s Recourse, Enforcement and Liability Principle and Annex I of the Data Privacy Framework.
Regulatory Oversight
SES INC is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.