Privacy Notice

LORIS MALAGUZZI LEARNING COMMUNITY, ASOCIACIÓN CIVIL, hereinafter “The School”, with registered address at Calle Francisco I. Madero, número 380 in Colonia Santa Anita in Tlajomulco de Zúñiga, Jalisco, Mexico, in strict compliance with the Federal Law for the Protection of Personal Information in Possession of Private Entities (“the Law”), and its regulations, informs parents, the student body and interested parties that “The School” protects and safeguards their personal information to prevent damage, loss, destruction, theft, misplacement, alteration, and unauthorized handling.

Personal and sensitive information collected by the company will be used to provide a comprehensive service by “the School”, to provide services and products requested, to notify about new services or products related to those already contracted or acquired, to communicate regarding changes to them, to evaluate the quality of the service we provide, to send communications, to deal with complaints and clarifications, and where relevant, to handle it for purposes compatible with those mentioned in this Privacy Notice, and that are considered similar for legal purposes, and in general to fulfil the obligations that we have entered into with you.

For the abovementioned purposes, we require the following Personal Information:

1. Name of the parents, students and siblings
2. Name of the guardians, those who hold legal custody over the child and relatives of the students
3. Residential address of the parents and students
4. Work address of the parents/guardians
5. Residential and work address of references in case of an accident or emergency
6. Telephone numbers: cellular, home, work and others where “The School” can contact parents/guardians, students, relatives and references.
7. Email addresses of parents/guardians, students, relatives and references
8. Nationality of parents
9. Parents’ occupations
10. Academic degree of parents and siblings
11. Personal references
12. Marital status of the parents
13. Medical history of the student
14. Name, telephone number and address of the family doctor
15. Medical conditions of the student
16. Medicines that “The School” should administer to the student
17. Information about the student’s daily routine before and after school
18. Family dynamics
19. Vaccination record of the student

In addition to the above, “The School” collects sensitive personal information, which will be handled in accordance with Article 19 of the Federal Law for the Protection of Personal Information in Possession of Private Entities.

WHAT INFORMATION DO WE COLLECT?

The personal information that you provide to “The School” through this website https://habitatschool.mx, through the use of our online, written and/or telephone services includes: (i) personal details. In order to verify that the personal information provided is correct and up-todate, “The School” may search for, and where relevant collect, information from other sources.

The staff member responsible for this can request Personal Information from parents or students or those responsible for them. The COLLECTION OF PERSONAL INFORMATION will include official identification (voting card, passport, driving license, military ID card); photographs; marriage certificate; CURP (Unique Population Registry Code); proofs of address, resumé and medical reports.

You consent to the handling of your personal information and/or contents in the documentation provided in accordance with the terms and conditions of this Privacy Notice.

WHAT DO WE USE THE INFORMATION FOR?

The personal information we collect is used for: (i) identification and verification purposes; (ii) contact; (iii) informative purposes; (iv) to offer and deliver our goods and services; (v) to offer the contracting of services.

In the collection and handling of personal information, we comply with all the principles stipulated in the Law and its Regulations: lawfulness, quality, consent, information, purpose, loyalty, proportionality, and responsibility.

Who do we share your information with? “The School” can transfer your personal information to national or foreign third parties, to subsidiary companies and those affiliated with “The School”; service providers for promotion and sales activities of our services; by requirement from an authority, and to comply with obligations derived from a legal matter between the subject of the personal information and any of the companies of “The School”.

To that end, “The School” may hire one or several third parties as service providers selected to support promotion or sales activities of our services; to handle and manage personal information collected through this Portal, or by any other different means, as well as to verify the information you provide, and “The School” may therefore send it to said third party or parties only in order to provide the services contracted.

It is understood that you consent to the transfer of your personal information, unless stated otherwise.

The personal information you provide to “The School” can be compiled and recorded in a database exclusively owned by “The School”.

“The School” is not responsible for the content or privacy policies of sites external to this portal, with the understanding that the educational authorities or affiliates of the school should also safeguard and protect personal information.

The handling of personal information with educational authorities.

The personal information collected will be protected, incorporated and handled, as necessary, in the Personal Information Systems managed by the federal educational authority and the local educational authorities, called “National Student Registry” (RNA, as per acronym in Spanish) and the “National Register for Issuing, Validating and Registering Academic Documents (RODAC, as per acronym in Spanish), which have both been duly registered in the List of Personal Information Systems with the Federal Institute of Access to Public Information (IFAI, as per acronym in Spanish) on July 8, 2009 (www.ifai.org.mx).

The foregoing is in accordance with the terms established by Articles 3 and 5 of the Political Constitution of the United Mexican States, Articles 1, 2, 7, 10, 12, 13, 14, 30, 37, 54, 55, 56, 57, 60, 61, 62, 63, 64 and other related and applicable provisions of the General Law on Education, as well the terms of local legal provisions for educational matters and its professional practice.

Said registers and the handling of data associated with them will be subject to the provisions of the Federal Law for Transparency and Access to Government Public Information, to the Federal Law for the Protection of Personal Information in Possession of Private Entities, to the provisions deriving from said laws, and the corresponding local legislation in force.

The personal information collected for the purposes of this form and that which are derived from the provision of educational services will be transferred to the local and federal educational authorities, exclusively for the exercise of their duties.

Specifically, the abovementioned registers have the following primary purposes:

(1) To generate and back up relevant information for decision-making in the educational planning and evaluation processes; in this case the information will be dissociated from its owner; (2) To protect the identity of students, directors, teachers, parents or guardians, and other stakeholders in the national educational system; (3) To facilitate the mobility and transfer of students in the national educational system; (4) To prevent falsification of school records, report cards, transcripts, assessment reports, certificates, diplomas, degree certificates, grades and other documents issued by the institutions that make up the national educational system; and to facilitate the verification of authenticity of the cited documents through physical or electronic validation; (5) To simplify education processes and services using the electronic registers that facilitate the review of school records (pre-enrollment, enrollment, re-enrollment, transfer, issue of duplicates, revalidation and equivalence of studies, accreditation of teaching profiles, authorization and official recognition and validation of studies; authentication of documents, accreditation of knowledge, skills and others related to school record-keeping), and in general, (6) To offer citizens and society as a whole greater certainty and simplification in the administrative processes relating to the education sector. The central authority responsible for the Registers in question isthe Undersecretariat for Planning and Evaluation of Education Policy of the Secretariat of Public Education, which will act directly or through the General Directorate of Accreditation, Incorporation and Revalidation, located at Av. Universidad Número 1200, Colonia Xoco, Delegación Benito Juárez, C.P. 03330 in Mexico City. Pursuant to Article 22, Section III of the Federal Law on Transparency and Access to Public Government Information, it is not necessary to obtain the consent of the subject of the information, with regard to information transferred between liable parties or between departments and entities, when used forthe performance of their authorized duties. The foregoing information is provided in compliance with the Seventeenth of the Guidelines for Protection of Personal Information published in the Official Gazette of the Federation on September 30, 2005.

WHAT SECURITY OR CONTROL MEASURES DO WE USE TO PROTECT YOUR PERSONAL INFORMATION?

The Information will be handled pursuant to the Federal Law on the Protection of Personal Information in Possession of Private Entities and its Regulations. “The School” implements security measures to guarantee the confidentiality of the Information, as well as security, administrative, technical and physical measures to protect your personal information and to prevent damage, loss, alteration, destruction, use, access or improper disclosure of the same. Only authorized persons from the Data Privacy Department, will have access to your Information.

Likewise, we inform you that “The School”, through its website development provider, has implemented the necessary and adequate security measures for the correct protection of your information, which are the same measures we expect our service providers to have in place, including services provided by subsidiarity companies or affiliates of “The School”.

All information and personal information that you provide through the use of our online, written and/or telephone services will constitute a database that belongs to “The School”. The information is stored for protection purposes to prevent loss, improper use, or alteration.

“The School” can use cookies or IP addresses to confirm your identification when accessing our online services, with the sole purpose of providing a personalized service since it allows us to determine your preferences through recording your use of our portal, and in this way identify your habits and preferences to offer you our products and services. We do not collect personal information from users through the use of cookies, under the terms of the Law and its Regulations. The protection of privacy of personal information of minors is especially important for “The School”.

For this reason, when we are made aware of personal information of minors, it is handled in compliance with the guidelines and requirements established in the Law and its Regulations at all times.

WHICH AREA IS RESPONSIBLE FOR HANDLING AND MANAGING PERSONAL INFORMATION?

The area responsible for handling and managing personal information is the “Data Privacy Department”, which can be contacted by email at coord.admin@habitatlc.mx, or directly in our offices located at Calle Francisco I. Madero número 380 in the Colonia Santa Antina in Tlajomulco de Zúñiga, Jalisco, Mexico.

HOW CAN YOU RESTRICT THE USE OR DISCLOSURE OF YOUR PERSONAL INFORMATION?

You can write to “The School” if you wish to restrict the use or disclosure of your personal information in order to stop receiving information about offers, promotions and advertising of additional products and services. You can send your request to the Data Privacy Department, via the email address mentioned above.

With regard to the use of cookies, the “Help” button can be found in the toolbar of most browsers, which will tell you how to block or allow cookies.

HOW CAN YOU EXERCISE YOUR ARCO RIGHTS AND REVOKE CONSENT GRANTED?

As the subject of personal information, you can exercise your right of access, rectification, cancellation and opposition to the handling of personal information, hereinafter referred to as ARCO Rights, or revoke the consent you granted to “The School” for the handling of your personal information, by sending your request directly to the Data Privacy Department, via email to coord.admin@habitatlc.mx, by going directly to our offices, or by sending a written request to the address: Calle Francisco I. Madero número 380 in the Colonia Santa Anita in Tlajomulco de Zúñiga, Jalisco, Mexico, addressed to the Head of the Data Privacy Department.

Said request must contain, as a minimum, your name, full address, documents that verify your identity, clearly indicating how you are related to the Company and specifying clearly and accurately the personal information to which you request access, rectification, updating or cancellation, the components or documents where your personal data appears, and indicating the reasons why you wish to access your personal information, or the reasons you would like your information to be updated, rectified or cancelled.

Once this is received, the Data Privacy Department will have a period of 20 working days to respond to the request; however, this period may be extended for an equal duration, which will be notified by the means indicated by you for said purpose, indicating the reasons for said extension, in accordance with Article 32 of the law.

Likewise, we inform you that, under the terms of the Law and its Regulations, as of January 6, 2012, you can initiate the procedure for Protection of ARCO Rights with the Federal Institute of Access to Information and Protection of Personal Information (IFAI, as per acronym in Spanish) within 15 days following the date that “The School” responds to your request, and you deem it unsatisfactory, or if “The School” has not responded to your request within the indicated period.

Modifications to the Privacy Notice. We reserve the right to amend this Privacy Notice at any time. In the event of changes to this Privacy Notice, this will be communicated to you, requesting the use of the channels authorized by the Law for said purpose, but always through our Portal https://habitatschool.mx/

Consent for handling personal information. The subject of personal information states that he/she has read and agreed to the terms and conditions of the Privacy Note made available, understanding the purpose of collecting and handling their personal information, as well as the procedure to exercise their ARCO Rights.

Last update to this Privacy Notice: September 6, 2017.

LORIS MALAGUZZI LEARNING COMMUNITY, ASOCIACIÓN CIVIL

Address: Calle Francisco I. Madero número 380 in the Colonia Santa Anita in Tlajomulco de Zúñiga, Jalisco, Mexico

Telephone Nos.: (33) 3109 3297 and (33) 1645 8356

Portal https://habitatschool.mx/

Email of the Data Privacy Department: coord.admin@habitatlc.mx