Updated in February 2025

INTRODUCTION

CADMUS^® International School – Basra (collectively referred to as the "School", "we", "us", "our", or "ours") values and takes your privacy rights seriously. We are committed to being transparent about the information we collect about you, why we collect it, how it is used, and with whom it is shared as set forth herein.

This Privacy Policy (the “Policy”) applies to the personal data collected when you visit or view this website (the “Website”) and access or use the available services (the “Services”).

The operator of this website is:

CADMUS^® International School - Al Basra
facing Southern Technical University,
Al Zubair Street, Al Basra, Iraq

info@cadmusbasra.sabis.net

+964 787 000 04 04

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 for any personal data we may collect about you or that you choose to provide 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.

DEFINITIONS

Personal Data: Personal data includes any information, regardless of its source or format, that can identify an individual either directly or indirectly. This includes, but is not limited to, names, personal identification numbers, addresses, contact numbers, license numbers, records, bank and credit card numbers, photographs, videos, and any other information of a personal nature.

Processing: Any operation performed upon Personal Data, including but not limited to collection, storage, use, erasure, recording, disclosure, transmission, modification, distribution, etc.

Data Subject: Any individual whose personal data is being collected, held, or processed, i.e., the individual to whom the Personal Data relates.

INFORMATION COLLECTED ON OUR WEBSITE

The types of Personal Data the School collects about prospective students, students, and parents and/or guardians (‘Parents’) before, during, and after a student’s enrollment at the School, as well as other individuals/visitors who come into contact with the School, include the following:

• Contact Details (e.g. name, home address, E-mail address, phone number)
• 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)

The School collects the Personal Data held about a Data Subject through an "Interest Form," or other forms filled out by Parents, which are essential to process your application and to contact you.

Occasionally, the Website’s visitors provide their Personal Data using the "Contact Us" form. Mandatory details are necessary to contact you and process your inquiry.

To improve the way our Website functions for visitors/users 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

This Policy also applies to Personal Data we collect from you via cookies and related technologies to maintain an anonymized user session and 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.

Children's Privacy

We place great importance on protecting the privacy of young children who may use the Website. We do not knowingly solicit or collect Personal Data from individuals under the minimum required ages specified herein. You must be of the age of majority in your jurisdiction to use our Services. Individuals under the applicable age may use our Services only through parental or legal guardian 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. Information You Give to Us Voluntarily

• The Personal Data submitted through the ‘Interest Form’ will be used to communicate with the Data Subject who submitted this form and expressed interest in the School, and to initiate the admission process when applicable.
• The Personal Data submitted via the "Contact Us" form will be used to contact you and address your request.
• The Personal Data you provide when subscribing to the SABIS^® newsletter will be used to send you the newsletter whenever it is issued.

2. Information We Collect Automatically About You

The Personal Data collected automatically through cookies or the web server logs is used to ensure that content from our Website is presented in the most effective manner for you. This data is also used 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.

You may request to stop receiving any marketing material by sending an E-mail to privacy@sabis.net or clicking the "unsubscribe" button.

DATA SECURITY

We will securely process (collect, store, and use) your Personal Data.

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 take appropriate steps to restrict access to Personal Data to authorized employees and agents who require it for the operation, development, improvement, or delivery of our programs, products, and services. This is accomplished through Role-Based Access Control (RBAC) and Multi-Factor Authentication (MFA), as well as logging and auditing, among other security measures.

We value the security of your Personal Data collected for the purposes mentioned above, and we confirm that we will 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.

With that, your Personal Data may be processed beyond the country/geographical region in which you reside. Depending on the social media provider and/or the online video hosting services (Facebook - Instagram), they may perform other data processing. For details, refer to the respective platforms' terms of use and data privacy policies.

We are not responsible for third-party links to other websites. We are not responsible for the content or data processing generated on third-party websites and accessible by links or hyperlinks on our Website. We will also not be responsible for the Personal Data that they share on other websites or social media platforms.

EXTERNAL LINKS

The Website includes links to external sites within the SABIS^® Global Network, such as the SABIS^® Careers or the SABIS^® Newsletter. Please refer to the privacy policies of each external site within the SABIS^® Global Network to understand how your data is being processed.

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.

USE OF GOOGLE MAPS

We use Google Maps on our Website. Google Maps is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The Google Maps plug-in is included by embedding the service on our Website using what is known as iFrames. When loading these iFrames, under certain circumstances, Google may collect and process information (including personal data). We cannot exclude the possibility that Google may transmit this information to a server in a different country.

We do not collect any data when you use Google Maps through our Website.

The purpose of having Google Maps on our Website is to display our address and make further information available by providing access routes to the respective locations, making it possible for you to plan your journey independently.

Information on Legal frameworks for data transfers and other relevant data on Google’s data processing within the framework of the use of Google services can be found at https://policies.google.com/privacy and https://policies.google.com/privacy/frameworks.

The legal basis for the Processing of Personal Data described herein is your legitimate interest in benefiting from the services that Google Maps offers.

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 to fulfill the purposes outlined in this Policy unless otherwise required by law.

The Personal Data you submit under the “Contact Us” form will be stored in the Website’s databases for one year in an anonymized format and automatically deleted afterward. The Personal Data you submit under the “Interest form” will be stored in the Website’s database for one year in an anonymized format and automatically deleted afterward.

Also, the Personal Data we collect from you for our School’s newsletter subscription will be deleted once you unsubscribe.

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 policies of the social network operators.

PERSONAL DATA TRANSFER AND SHARING

The School is part of the SABIS^® Global Network.

Therefore, Personal Data collected on the Website will be transferred to SABIS Educational Systems, Inc., located in Eden Prairie, Minnesota, USA, which collaborates with the processor Lumen Technologies, Inc., 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 and anonymized.

The Personal Data stored in the Website’s database hosted by SABIS Educational Systems, Inc. is backed up locally in the US Data Center and online using the Barracuda Cloud Backup service. The latter is a cloud backup solution that utilizes Azure and Amazon AWS cloud infrastructure in the US.

In addition, authorized employees from SABIS Educational Services S.A.L., based in Adma, Lebanon, may access your Personal Data stored in the Website’s data base for various support purposes. If you choose to register to receive the SABIS^® newsletter, your E-mail address will be stored in our databases in an anonymized format and shared with SABIS Educational Services, Adma, Orange Zone, Lebanon, which provides this service on our behalf.

DISCLOSURE TO THIRD PARTIES WITHOUT PREJUDICE TO THE PREVIOUS CLAUSE

We do not share the Personal Data collected on this Website with third parties without obtaining your consent. However, we may be required or need to disclose your Personal Data in the following circumstances:

• If we receive a valid request from the police, law enforcement agencies, regulatory bodies, or government authorities in the country of origin or elsewhere.
• We may share your Personal Data with other schools and companies within the SABIS^® Network for academic and technical support purposes.
• We may share your Personal Data with our service providers in order to provide you with the necessary services. These service providers can be provided upon request and when applicable.
• We may share your data with relevant service providers for contract execution and business development.

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA

Our legal basis for processing your Personal Data depends 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 consent to the processing activity. You may revoke your consent anytime 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.

Legal Obligations

We process your Personal Data as needed to comply with laws and regulations.

Legitimate Interests

We process your Personal Data for our legitimate interests to provide you with the Services, such as 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

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 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.
• 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 withdraw your consent for Personal Data Processing – You shall inform us of this through any available means in accordance with Law provisions.
• 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:

1. Using the "Contact us" page on this Website
2. Emailing us at: info@cadmusbasra.sabis.net
3. Questions, comments, and requests regarding this Policy: privacy@sabis.net

ACCEPTANCE AND CHANGES TO THE POLICY

By using our Website and Services, you agree to and consent to this Privacy Policy. Any changes we may make to this Policy in the future will be posted on this page.