The AMERICAN SCHOOL OF RECIFE – EAR, is a private, not-for-profit school founded in 1957. The school offers a Nursery through Grade 12 instructional program for students. The two semesters comprising the school year extend from August to December and from January to June.

The school is accredited by Cognia (Formerly AdvancED-SACS) in the United States, by the Ministry of Education of Brazil (MEC), the Pernambuco Secretary of Education, and Recife Secretary of Education.

The school is a member of the American International in the Americas AMISA (Formerly AASSA), the Association of American Schools in Brazil (AASB), and the Association for the Advancement of International Education (AAIE).

This Privacy Policy aims to inform, in accordance with the guidelines of the General Data Protection Law, No. 13.709/18 – LGPD, which data may be collected by EAR, when using its communication channels, its portals (www.ear.com.br, https://www.facebook.com/EscolaAmericanaDoRecife, https://www.instagram.com/escola_americana_do_recife, https://twitter.com/EAR_Eagles, https://www.youtube.com/escolaamericanadorecife) that are part of this system, as well as how such information is used and handled.

1-DEFINITIONS

1. User:Person who uses and/or interacts with any of the communication channels of the American School of Recife;

2. Personal Data:Information related to an identified or identifiable natural person;

3. Data Owner:Natural person to whom the personal data that are the object of processing refer;

4. Controller:Natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data;

5. Operator:Natural or legal person, under public or private law, who processes personal data on behalf of the controller;

6. Data Protection Officer (DPO):The person appointed by the controller and operator to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority (ANPD);

7. Treatment Agents: The controller and the operator;

8. Treatment:Any operation performed with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction;

9. Consent:Free, informed, and unequivocal manifestation by which the holder agrees with the processing of his/her personal data for a specific purpose;

10. Blocking:Temporary suspension of any processing operation, by guarding personal data or the database;

11. Elimination:Deletion of data or set of data stored in a database, regardless of the procedure used;

12. International Data Transfer:Transfer of personal data to a foreign country or international organization of which the country is a member;

13. Shared Use of Data: Communication, dissemination, international transfer, interconnection of personal data or shared treatment of personal data banks by public bodies and entities in compliance with their legal powers, or between these and private entities, reciprocally, with specific authorization, to one or more treatment modalities allowed by these public entities, or between private entities;

14. National Data Protection Authority (ANPD): Public administration body responsible for overseeing, implementing, and supervising compliance with this Law throughout the national territory;

15. Cookies: Small files created by websites visited and stored on the user’s computer through the browser, which can be used to identify visitors, customize the page based on the navigability profile, track usage patterns for improvement and control, in addition to facilitating the transporting data between pages on the same site.

2- DATA OWNER RIGHTS

The AMERICAN SCHOOL OF RECIFE provides access to the personal data of users, a right provided for in the General Data Protection Law, No. 13.709/18 – LGPD, through its communication channel with the Supervisor (DPO), to provide its holders safe and reputable access, facilitating their obtainment, in a timely manner and upon request to:

1. Confirmation of the existence of processing (Arts. 18(I), 19, LGPD).

2. Access to data (Arts. 18(II), 19, LGPD).

3. Correction of incomplete, inaccurate, or outdated data (Art. 18(III), LGPD).

4. Anonymization, blocking, or deletion of unnecessary or excessive data or data processed in breach of the law (Art. 18(IV), LGPD).

5. Data portability (Art. 18(V), LGPD).

6. Deletion of personal data processed with the consent of the data subject (Art. 18(VI), LGPD) (unless an exception applies).

7. Information on public and private entities with which personal data has been shared (Art. 18(VII), LGPD).

8. Information on the possibility of denying consent and the consequences of such denial (Art. 18(VIII), LGPD).

9. Revocation of consent (Art. 18(IX), LGPD).

10. Oppose processing based on waiver of consent situations, if there is a breach of law. (Art. 18 §2, LGPD).

3- DATA COLLECTED

Through its communication channels, AMERICAN SCHOOL OF RECIFE may collect information provided by the data subject, such as NAME, EMAIL, PHONE, etc., among other data necessary for the full use of the services provided by the Institution.

The AMERICAN SCHOOL OF RECIFE may also collect other information, automatically generated when using the Institution’s Websites by the User, such as but not limited to, Device ID and address, with date and time, pages accessed, information about clicks on pages, among others.

The AMERICAN SCHOOL OF RECIFE may also use cookies and other similar technologies, always with the consent of the Data Subject, to automatically collect information about the browsing habits and purchasing habits of the User and their preferences.

4- PURPOSE OF DATA COLLECTION

The data and information collected from Users, by The AMERICAN SCHOOL OF RECIFE, may also be used for the following purposes:

1. Make any communication resulting from the activity of the website itself or the identification of the respective recipient;

2. Provide access to the restricted area of ​​the website or its exclusive applications and functionalities;

3. Compliance with a legal or judicial order;

4. Establish, defend, or regularly exercise legal or administrative rights;

5. Prepare general statistics to identify the profile of Users and develop the AMERICAN SCHOOL OF RECIFE;

6. Ensure User safety;

7. Keep the records of Users updated for purposes of authorized contact to be made by telephone, email, SMS, direct mail, or other means of communication;

8. Inform about news, promotions, and events of the AMERICAN SCHOOL OF RECIFE and its commercial partners.

Thus, by accepting this Privacy Policy of the AMERICAN SCHOOL OF RECIFE the User expresses his free, explicit, and informed consent for the AMERICAN SCHOOL OF RECIFE to use the information collected for the proper provision of services, for implementation improvements and innovations in its services, as well as for advertising and statistical purposes.

5- DATA SHARING

All information collected about the User is considered by the AMERICAN SCHOOL OF RECIFE as confidential, and may be shared with third parties only and solely in the following situations:

1. With partner entities of the AMERICAN SCHOOL OF RECIFE, such as technology service providers, among others, to enable the adequate provision of services and delivery of products;

2. For the protection of the interests of The AMERICAN SCHOOL OF RECIFE, if necessary, in any form of conflict, extrajudicial or judicial; or

3. By court order or by request of administrative authorities that have legal competence for its request.

6- DATA STORAGE

All User data effectively collected by The AMERICAN SCHOOL OF RECIFE will be stored on its own or third-party servers, contracted for this purpose, in Brazil or abroad.

Thus, in order to ensure the security of your data, The AMERICAN SCHOOL OF RECIFE employs all reasonable market efforts to ensure the security of its systems in the safekeeping of such data, including the guidelines on security standards established in Decree No. 8.771/ 2016, such as:

1. Use of standard and market methods to encrypt and anonymize collected data, as well as standard forms of encryption to ensure its inviolability;

2. Use of high-tech software to protect against unauthorized access to systems, which are considered a controlled and secure environment;

3. Access to the places where the information is stored, allowing only previously authorized persons, committed to keeping such information in absolute secrecy, which, if not observed, will result in civil liability and the consequences of a judicial measure following the Brazilian law;

4. Use of authentication mechanisms for access to records capable of identifying the person responsible for processing the records, as determined by article 13 of Decree n. 8.771/2016; and

5. Preparation of an inventory containing the time, duration, identity of the employee or person responsible for the access designated by the company and the file accessed, based on connection and application access records, according to article 13 of Decree no. 8,771/2016

7- UPDATE AND/OR DELETION OF DATA

The owner of the information may request the updating or deletion of the data collected about him by the AMERICAN SCHOOL OF RECIFE, by contacting directly the Supervisor – DPO (Data Protection Officer) identified in item 8.

The AMERICAN SCHOOL OF RECIFE undertakes to use its best efforts to meet all requests for updating or deletion within the period provided for in the General Data Protection Law and its regulations.

8- CONTROLLER CONTACT

The AMERICAN SCHOOL OF RECIFE, a private association, registered under the CNPJ/MF No. 25.293.568/0001-79, headquartered at Rua Sá e Souza, No. 408, Boa Viagem, Recife/PE, Brazil, CEP 51.030-065.

9- DATA PROTECTION OFFICER CONTACT – DPO

BLACKBELT IT SOLUTIONS, LTDA Company registered under the CNPJ/MF No. 25.293.568/0001-79, headquartered at Rua do Cupim, No. 132, CXPST 266, Graças, in the city of Recife, in the state of Pernambuco, CEP 52011- 070. emaildpo@ear.com.br

10- COMPETENT LEGISLATION AND JURISDICTION

This Privacy Policy will be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the laws of other states or countries, the Forum of Recife, State of Pernambuco, Brazil being competent to settle any doubt arising from this instrument. The User expressly consents to the jurisdiction of this court, and waives, in this act, the jurisdiction of any other forum, however privileged it may be or may become.

The AMERICAN SCHOOL OF RECIFE

Updated on 09/14/2021