Privacy Policy

Protecting privacy, safeguarding personal data, and treating both transparently, ethically, safely, and responsibly are essential values of School of the Nations, registered under CNPJ 00.580.852/0001-03 in the National Register of Legal Entities.

 

This Privacy Policy establishes how School of the Nations, as the Controller of Personal Data, collects, uses, shares, and treats the Personal Data of individuals in performing the educational services it provides. This policy also contains information on the rights and obligations derived from the General Personal Data Protection Law no. 13.709/18 and other applicable laws.

 

1. UPDATES TO THIS PRIVACY POLICY

 

Whenever legislative changes regarding the object of this policy occur, this policy will be modified. The updated document will be published on the institution’s website and communication app to publicize such changes. Such changes will be valid, effective, and binding at the time the document is published on any official communication channel of School of the Nations.

 

2. WHAT DATA ARE USED, AND HOW ARE THEY COLLECTED?

 

The personal data of current and former students and that of their parents or guardians, school employees, and people who make transactions or register directly or indirectly with School of the Nations will be entered into the institution’s database and duly treated with the maximum zeal, care, and attention they require.

 

We request and store only those data relevant to the purposes for which they are collected. Such purposes are clearly communicated either through this privacy policy or a consent form.

 

The Personal Data referred to above include enrollment, financial, and transactional data, such as those that follow.

 

  • Enrollment data, including the name, date of birth, gender, identification number, Brazilian social security number, and/or other identification documents, such as a driver’s license, photo, residential and business addresses, residential, business, and cell phone numbers, e-mail addresses, profession, marital status, nationality, and place of birth, among others.

  • Sensitive Personal Data, including, among others, blood type, Rh factor, religion, ethnicity, or other sensitive personal data, following applicable legislation or as described in a consent document signed by the person (or their legal guardian) whose sensitive personal data is collected.

  • Financial and transactional data for the purposes of collecting payments and providing services, among others.

  • Data on third parties, including affiliation, parents’ names, representatives, those who are represented, guarantors, counterparties, attorneys, employees, and beneficiaries of products and services such as insurance, credit cards, and payments, among others.

  • Information regarding devices, device data (such as the Advertising ID, operating system, and screen size), connection data (such as the date, time, and IP address, the network used), the device identification number, and device usage. Geolocation data may also be collected through our app when using features such as those required when using the student pick-up and drop-off options.

  • Information about browsing habits, including the pages and functions accessed on our website and app, the number of clicks, and the pages and apps used to access our website and app (for example, if you visit a website that has a link to the School’s website and app, or if you access third-party pages from links on the School’s website and app, such actions will be collected).

  • Social Media and Platform Data, including interactions you have with the School through social networks such as Facebook, Twitter, Instagram, LinkedIn, and YouTube.

  • Personal data reaches the School through several means, such as consent received directly from you as a result of the provision of services; from public or publicly accessible sources (i.e., the Internet, communication channels, social media, public records, and other sources), as permitted by law.[1]

 

3. HOW DO WE USE YOUR DATA?

 

School of the Nations processes personal data in accordance with the legal requirements foreseen in the General Data Protection Law (LGPD). This includes complying with legal and regulatory obligations, executing contracts, and fulfilling legitimate interests of the School and third parties to protect the life or physical safety of the Owner of such data or third parties, among others guaranteed by the relevant legislation.

 

We may also process Personal Data and other information depending on the objective. For example, the School uses your personal data to:

  • Register contact information and exchange information prior to signing a contract.

  • Enroll a person as a student — enrollment documents.

  • Separate students into classes.

  • Identify and prepare materials.

  • Organize classrooms.

  • Contact parents or guardians to communicate incidents, report emergencies, and schedule appointments, among others.

  • Control authorization for students to leave campus.

  • Accompany academic performance.

  • Promote the safety and physical integrity of students, employees, and visitors through monitoring and surveillance systems, such as closed-circuit video.

  • Comply with legal and regulatory obligations, as well as judicial, administrative, and arbitration orders and decisions.

  • Protect your rights, those of the School and third parties for the regular exercise of rights, including in contracts and judicial, extrajudicial, administrative, or arbitration proceedings.

 

4. COOKIES

 

Cookies allow the collection of data related to browsing depending on the type of device used, the authorizations granted by you through your device settings, and the functionality used in each application. We may use our own or third-party cookies on our website and application.

 

What are cookies?

 

Cookies are small text files that may or may not be added to the browser of a device. These files store and recognize data that ensure the website or application functions correctly and help us identify your preferences.

 

Types of cookies and their purposes

 

Cookies collect data for different purposes related to the functionality of our website and application. See the types of cookies we use below.

  • Operation: to ensure correct access and operation of applications

  • Authentication: to recognize the user, allow access (including areas of restricted access), provide content, offers, and/or services from strategic partners

  • Security: to assist in monitoring and detecting unauthorized activities, prevent fraud, and protect the information of the user, School, and third parties

  • Research, analysis, and performance: to verify, measure, and analyze the audience, performance, and use of applications by users.

 

Can I disable cookies and other forms of information collection?

 

You can disable or delete cookies and other data collection technologies in your browser settings and the operating system settings of your device, except for operating cookies which, if disabled, will not allow you to use the websites or applications.

 

Users should remember that if certain cookies are disabled, the website, application, or some of their features or functionality may not function properly.

 

5. INTERNATIONAL DATA TRANSFER

 

The personal data entrusted to School of the Nations may be transferred to and processed in other countries in accordance with the hypotheses provided for in the LGPD and other applicable legislation.

 

An example of a situation where international data transfer is necessary is the use of the Power School platform, which is hosted in the United States. PowerSchool is currently the student information system used by the School to record and store information relevant to students and the School.

 

6. HOW LONG DO WE KEEP YOUR DATA?

 

The period for which School of the Nations stores Personal Data depends on the purpose for which they were collected. It is certain, however, that your data will be stored for the time necessary to comply with legal, regulatory, and contractual obligations, to manage risk in the regular exercise of administrative, judicial, and arbitration proceedings, and for other purposes provided for in this Privacy Policy.

 

7. DATA SECURITY

 

The security and protection of personal data and School of Nations’ information is a priority. The School establishes processes and controls to prevent, detect, and respond to incidents and protect your data from unauthorized access and use, promoting security risk management, including cyber, and building a strong security foundation.

 

We believe that information must be protected regardless of where it is, whether at a service provider, an international unit, or at a partner, throughout its life cycle, from the moment it is collected, through processing, transmission, storage, analysis, and disposal.

 

We take care of data following strict standards of security and confidentiality to provide students, parents, and guardians with a safe and reliable environment. We use tools and technologies to maintain the integrity, confidentiality, availability, authenticity, and legality of information and protect it from unauthorized access.

 

Additionally, we restrict access to data to the extent necessary, with strict confidentiality and secrecy obligations and by adopting security criteria.

 

However, if School of the Nations is required by law or court order, it will provide the data requested.

 

8. YOUR RIGHTS

 

The LGPD guarantees rights to persons from whom data are collected. You have the right to the following.

  • Access to your personal data and confirmation of its processing

  • Have incomplete, inaccurate, or outdated data updated and corrected

  • Anonymize, block, or delete unnecessary or excessive data or data that are processed in violation of the provisions of the LGPD

  • Data portability or transferability (subject to applicable norms)

  • Receive information on the public and private entities with which the Controller shared data

  • Receive information on the possibility of not providing consent and the consequences of such denial

  • Revoke your consent at any time and free of charge, upon express request

  • Request the deletion of Personal Data Processed with consent, except in cases where the maintenance of such data is necessary or permitted by law

  • Oppose the treatment of data carried out, based on other legal grounds, in the event of non-compliance with the LGPD, noting that there may be situations in which the School may continue to carry out the Treatment and refuse such requests.

 

Under certain circumstances, the School may continue to store and treat some data, even after receiving a request to delete, block, or anonymize it, or after it has been opposed, to, for example, comply with legal, contractual, or regulatory obligations to protect and exercise the rights of the School, contractors and/or students, to prevent illicit acts, and in judicial, administrative, and arbitration proceedings, including for questioning by third parties about activities, and in other cases provided for by law.

 

9. DATA PROTECTION OFFICER

 

For further information about this Policy or how we manage your personal data, please contact the Data Protection Officer at dpo@edn.org.br.

 

10. APPLICABLE LAW

 

Brazilian law is applicable to this Privacy Policy. All disputes shall be presented in the forum of the headquarters of School of the Nations.

 

11. QUESTIONS ABOUT THIS POLICY

 

In compliance with legal requirements, School of the Nations has appointed its Data Protection Officer, who, pursuant to Article 5, item VIII of the LGPD, is the person responsible for receiving complaints and communications from owners of the data, provide clarifications and receive communications from the National Authority, train employees and contracted parties regarding the practices to be taken in relation to the protection of personal data of clients and execute other measures.

 

If you have questions about this policy, please contact the Data Protection Officer at dpo@edn.org.br.

Version 1.0 - June 30, 2022

[1]To exemplify the means by which data can reach our internal database, we mention the following situations.

  • Data provided by you (the owner of the data), when, for example, filling out registrations, forms, proposals, simulations, subscriptions, memberships, employment applications, accessing the School website or apps, searching or expressing interest in educational services.

  • Data generated about you as a result of your relationship with School of the Nations, such as information about hiring and services, or when you interact with the School via its website, applications, communication channels, establishments, centers, and service locations.