PRIVACY NOTICE Regarding the Personal Information Collected by ETON, S.C
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PRIVACY NOTICE regarding the personal information collected by ETON, S.C. and SERVICIOS ETON, S.A. DE C.V. (hereinafter collectively known as “ETON SCHOOL”) 1.- General 1.1.- ETON SCHOOL is a company committed to respecting the rights on personal information of individuals, as provided in article 16, paragraph II, of the Political Constitution of the Mexican United States, as well as in the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions (Ley Federal de Protección de Datos Personales en Posesión de Particulares), and the corresponding regulations and applicable law. Therefore, such entity makes this privacy notice available so that the individual whose information is guarded (the right holder) will be able to exercise his right to informational self-determination. 1.2.- When an individual accesses and browses the “Privacy Notice” section of the websites, www.eton.edu.mx and https://eo.eton.edu.mx, property of ETON SCHOOL, hereinafter collectively known as “the websites,” such individual (the right holder) acknowledges that he understands and accepts the terms and conditions of this privacy notice, and declares to accept and agree with them, using such electronic means as stipulated in article 1803 of the Federal Civil Code. 1.3.- If the right holder does not accept the terms and conditions of this privacy notice in full, he shall refrain from sharing information with ETON SCHOOL by any means, including its websites. 1.4.- If the right holder keeps using ETON SCHOOL´s websites, either wholly or partially, such action will be deemed as his full and express acceptance of the terms and conditions provided herein. 1.5.- Using ETON SCHOOL´s websites makes such user the right holder (hereinafter, the “right holder” or “right holders”), and it implies full and unconditional acceptance of all the general and specific conditions in this privacy notice in the version displayed by ETON SCHOOL, at the moment such right holder accesses the websites. The parties hereby declare that, as there is no dolus, mala fides, or any other that could affect or void the validity of this instrument, they both agree on the following: 2.- Definitions 2.1.- Personal information.- Any information related to an individual that is, or can be, identified. 2.2.- Sensitive personal information.- Personal information that affects the private life of the RIGHT HOLDER or that could cause discrimination or risk for such right holder in case of misuse. Sensitive personal information, in general, consists of information that could disclose aspects such as the ethnic or racial origin, current or future state of health, genetic information, religious, philosophical and moral beliefs, union affiliation, political opinions, and sexual preference. 2.3.- Right Holder.- The individual (RIGHT HOLDER) identified by such personal information. 2.4.- Keeper.- An individual or private entity (ETON SCHOOL) that has the right to decide how to manage the personal information. 2.5.- Individual in charge.- An individual or private entity that, either isolated or with others, manages personal information on behalf of the keeper. 2.6.- Management.- Collection, use (including access, handling, usage, transfer, and disposition of personal information), disclosure, or storage of personal information by any means. 2.6.1.- Transfer.- Any information communicated to an individual other than the keeper or individual in charge of the management. 2.6.2.- Relay.- The communication of personal information between the keeper and the individual in charge, in Mexico or abroad. 2.7.- Third Party.- The national or foreign individual or entity, other than the keeper or individual in charge of the information. 2.8.- ARCO Rights.- The right to Access, Rectify, Cancel, and Oppose. 2.9.- Tacit Consent.- It will be assumed that the RIGHT HOLDER has agreed with the management of the information when such individual does not express his opposition at the time of receiving the Privacy Notice. 2.10.- Primary Purposes.- The main purposes for which the personal information is requested, which create the relationship between ETON SCHOOL and the RIGHT HOLDER. 2.11.- Secondary Purposes.- The purposes that are not essential for the relationship between ETON SCHOOL and the RIGHT HOLDER, but that are to be managed to contribute to the corporate purposes of ETON SCHOOL. 3.- Identity and Domicile of the Individual in Charge of Managing Personal Information 3.1.- The keepers in charge of managing the RIGHT HOLDERS’ personal information are ETON, S.C. and SERVICIOS ETON, S.A. DE C.V. (hereinafter collectively known as, “ETON SCHOOL”), who will respect the provisions of this Privacy Notice (hereinafter the “Notice” or the “Privacy Notice,” indistinctively), which is made available according to the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions -Ley Federal de Protección de Datos Personales en Posesión de Particulares- (hereinafter the “Act” or “FAPPIGIPI,” indistinctively), and applied regarding personal information of individuals such as clients and/or prospective clients, which ETON SCHOOL manages in order to impart the educational services it provides in all grades and levels, including but not limited to, Early Childhood, Elementary, Middle School, High School, and counseling services in commercial and educational areas provided by ETON SCHOOL to Mexican and foreign customers. 3.2.- For effects of this Notice, the domicile of ETON SCHOOL is Av. Santa Lucía No. 220, Colonia Prados de la Montaña, Alcaldía Cuajimalpa de Morelos, C.P. 05619, Ciudad de México, México. 4.- Personal Information Subject to Management 4.1.- THE RIGHT HOLDER acknowledges and agrees that ETON SCHOOL will manage the following personal information either directly or through individuals in charge, considering the relationship held with each RIGHT HOLDER: 4.1.1.- Clients and prospective clients: full name, date and place of birth, age, sex, nationality, marital status, profession, official photo ID, images or photographs, voice, signature, domicile (street, number, district, city, state, municipality, zip code), landline and mobile phone number, email, TIN, credit/debit card information, bank information (account number, wire code (CLABE), bank), and immigration documents in case of foreign individuals. Student information: name, date of birth, nationality, sex, Population Record Single Number (CURP), previous and current state of health, blood type, medications, images or photographs, voice, and immigration documents in case of international students. Family information: father’s and mother’s full name, domicile (street, number, district, city, state, municipality, zip code), landline and mobile phone number, email, nationality, Population Record Single Number (CURP), date of birth, company where the parent works, sector, area, company website, profession, position, office phone number, family doctor, emergency contacts, contacts for social activities and third party information (name of the person, home phone number, mobile phone number, office phone number, relationship, email), information for tax receipts (name or corporate name, domicile, TIN, email, phone number), a copy of the immigration document (in case of foreigners), and recommendation letters from other schools and from Eton families. Trust Fund Information: student economic support provider’s personal information: full name, date of birth, domicile (street, number, district, city, state, municipality, zip code), and the percentage covered by the student economic support provider. Academic information: SEP/UNAM official report cards, letter of good conduct from the previous school, certification from the previous school that the student does not have any payments due. If the RIGHT HOLDER hires the services provided by ETON SCHOOL for a third party, such RIGHT HOLDER must get said third party’s consent in advance before providing his personal information to ETON SCHOOL. If the third party is a minor, i.e. a student, according to current Mexican legislation, the RIGHT HOLDER declares, under penalty of perjury, that they have the power to provide such minor’s personal information to ETON SCHOOL and accept this Privacy Notice, agreeing to keep ETON SCHOOL safe from any claims that may arise from the non-authorized use of third parties’ and minors’ personal information. ETON SCHOOL hereby declares that it will be able to manage students’ sensitive personal information such as past and present health information, in order to take care of health conditions that such students may have while receiving the educational services, and, per article 9 of the FAPPIGIPI, the RIGHT HOLDER – Client will be required to express his explicit, written, and signed consent to authorize such management, using the corresponding forms. Copies of the following documents: official photo ID, TIN, proof of residence, bank account statement front page, previous SEP/UNAM report cards, letter of good conduct from the previous school, and a recommendation letter from an Eton family. 4.2.- The RIGHT HOLDER hereby agrees, per article 8 of the of the FAPPIGIPI, that ETON SCHOOL will manage his personal information, including financial and asset personal information listed in this clause, in order to comply with the purposes stated in this Privacy Notice. 4.3.- The RIGHT HOLDER hereby agrees, under penalty of perjury, that the information he has provided to ETON SCHOOL