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Privacy Policy

Updated in January 2025

INTRODUCTION

SABIS ULINK department of Ulink College of Shanghai (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 data we collect about you, how it is used, and with whom it is shared as set forth herein.

This Privacy Policy (the "Policy") applies to the data collected from all users of the https://www.sabisulink.cn/ website (the "Website") and the services available on the Website (the "Services").

The operator of the Website and Personal Information Handler: SABIS® ULINK department of Ulink College of Shanghai.

The terms "you," "your," and "yours" refer to the user or viewer of the Website / Services, as applicable.

This Policy, together with our Terms & Conditions, sets out the basis on which any Personal Information we may collect about you, or that you choose to provide to us, and your choices and rights regarding our use of your Personal Information. 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 Information 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.

HOW TO CONTACT US

Questions, comments, and requests regarding this Policy should be addressed via E-mail at info@sabisulink.sabis.net or in writing to the following address:

Address: No.559, Laiting South Road, Jiuting, Songjiang District, Shanghai, China

DEFINITIONS

Personal Information

means any and all kind of information recorded by electronic or other means, related to identified or identifiable natural persons, not including information after anonymization handling.

Data Subject

refers to the natural persons whose information is the subject of information handling.

Data Handling

refers to any operation carried out with Personal Information, under the terms and limits determined by the Personal Information Protection Law of the People’s Republic of China (“PIPL”).

INFORMATION COLLECTED ON OUR WEBSITE

1. Information You Give to Us Voluntarily

If you choose certain services provided on our website, we will collect your Personal Information. We will collect Personal Information in the following circumstances:

Online Application. The type of Personal Information the School collects about students and parents and/or guardians ('Parents') before, during, and after the course of a student's enrollment at the School as well as other individuals/visitors who come into contact with the School include but is as follows:

  • Contact Details (Student name, Parent e-mail address, phone number)
  • Content Data (Current school, current grade, program to enroll, year to enroll)
  • Identity Verification (Student gender, date of birth, ID number)
  • Usage Data (Interest in Website’s contents, access time)

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

Please note that the ID number of student is Sensitive Personal Information. The other Personal Information of student is defaulted to the Personal Information of Data Subjects over 14 years old, and the Personal Information of children under 14 years old is Sensitive Personal Information. If you refuse to provide certain Sensitive Personal Information, it may affect your ability to submit the online application but will not affect other functions.

Contact Us

On occasions, the Website’s visitors/prospective parents provide the Personal Information by using the "Contact us" form. Mandatory details are necessary to make contact with you and process your enquiry.

  • Mandatory Contact Details (Name, e-mail address)
  • Other Contact Details (Home address, Parent e-mail address)
  • Content Data (Message)

Please be aware that we have prepared a privacy policy which provides detailed information on how we handle the Personal Information of our Students, Prospective Students, Parents and/or Legal Guardians, within the scope of our activities. Please refer to the special privacy policy we provide. Before we process your Personal Information as mentioned thereof, we will obtain your consent and fulfill the relevant obligations under PIPL to fully protect the information security.

2. Information We Collect Automatically About You

To improve the way our Website functions for visitors, to monitor, investigate, and report any security breach attempts of our Website, we automatically collect some statistical data about your use and browsing of the website, but will not identify you personally.

This Policy also applies to Personal Information we collect from you via the use of cookies and related technologies to maintain an anonymized users’ session, and to 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."

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 Cloudflare Captcha

We use Cloudflare CAPTCHA to protect the web forms on our website from spam emails and to defend against automated attacks and malicious bots. Additionally, this system enhances user experience by employing invisible challenges and behavioral analysis.

CHILDREN USE OF THE WEBSITE

The School places a lot of importance on protecting the privacy of young children who may use the Website. The School does not knowingly solicit or collect the Personal Data of children under the age of 18 on this Website. Children under the age of 18 are not permitted to submit an application or interest form to the School. Parents or legal guardians of a child under the age of 18 must complete the form and consent to the submission of an application to the School.

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

  • Personal Information will be collected and stored about the prospective student and his/her family for the purpose of evaluating him/her. The School will also use the information to communicate with the family during the admission process.
  • For the student’s registration, Personal Information will be collected and stored about the student and his/her family to manage the admission process. Certain types of Personal Information are more sensitive than others; this includes information about health or religion. If and when applicable and in case we collect and receive these types of information about your child, we will use it for your child’s legitimate interest in being able to provide him/her with the appropriate dietary/medical assistance, to reply to legal obligations, to respond to your inquiries when you contact us, and where you have consented to be contacted for such purpose. Please rest assured that we have developed a special notification letter and obtained consent before processing their relevant personal information.

2. Information We Collect Automatically About You

  • To ensure that content from our site is presented in the most effective manner for you, to administer our Website, and to perform internal statistical and trend analysis to improve the user experience and performance of our Website. However, the data we collect and analyze are merely statistical data and cannot directly identify you personally.

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 info@sabisulink.sabis.net or by clicking on the "unsubscribe" button when applicable.

DATA SECURITY

We will process (collect, store, and use) your Personal Information in a secure manner.

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 make reasonable efforts to restrict access to information to only employees and agents who need access to such information in order to operate, develop, improve, or deliver our programs, products, and services.

The security of your Personal Information, collected for the above-mentioned purposes, is important to us and we confirm to apply acceptable security measures and procedures to ensure the confidentiality, integrity, and availability of the data.

PERSONAL INFORMATION 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.

Information you submit under the “Contact us” form will be stored in our databases for one year only in an anonymized format and would be automatically deleted afterwards. Also, the information we collect from you for our newsletter subscription would be deleted once you unsubscribe.

Information you submit under the “Application Form” will be stored in the Website’s database in an anonymized format for three years.

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 social network operators’ privacy policies.

PERSONAL INFORMATION TRANSFER AND SHARING

The Website is hosted on a virtual machine from Alibaba Cloud in Hangzhou, Zhejiang, China. Your use of the Services does not transfer personal information outside of China.

DISCLOSURE TO THIRD PARTIES WITHOUT PREJUDICE TO THE PREVIOUS CLAUSE

We do not pass on your Personal Information to third parties without first obtaining your consent.

However, we may be required to disclose your Personal Information if we receive a valid request from the police or other law enforcement agency, regulatory or government authority in your country of origin or elsewhere.

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL INFORMATION

Our legal basis for processing your Personal Information is dependent 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 Information under the following legal bases:

Your Consent

We process your Personal Information if you have consented to the processing activity. You may revoke your consent at any time by sending an E-mail to info@sabisulink.sabis.net. Doing so will bar us from further processing of your Personal Information 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 Information as needed to comply with laws and regulations.

Legitimate Interests

We process your Personal Information for our legitimate interests, to provide you with the Services, such as connection with 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 Information, and in any event will be subject to the restrictions provided in this Policy.

DATA SUBJECT RIGHTS

According to PIPL provisions, the Data Subjects have rights in relation to their Personal Information, among them:

  • The right to know and the right to decide relating to their Personal Information, and have the right to limit or refuse the handling of their Personal Information by others, unless laws or administrative regulations stipulate otherwise (art.44 and 48 PIPL).
  • The right to consult and copy their Personal Information from personal information handlers, except in some circumstances as per the Law provisions. (art 45) – Data Subjects have the right to request from the School a copy of the Personal Information the School holds about them and know the origin and purpose.
  • The right to withdraw the prior consent concerning the retention or handling of their Personal Information – Data Subjects are allowed to refuse to provide their Personal Information or to have it subject to a certain treatment and revoke their consent.
  • The right to correct, rectify, edit, complete, or update their Personal Information (art 46) – Data Subjects have the right to cause the School to correct incorrect, irrelevant, incomplete, out-of-date, false, or impertinent data the School holds about them.
  • The right to deletion in some circumstances (art 47) – Data Subjects have the right to have the inaccurate, irrelevant, incomplete, out-of-date, false, or impertinent data the School holds about them be erased from the School records, in case the handling purpose has been achieved, is impossible to achieve, or the Personal Information is no longer necessary to achieve the purpose; in case the individual rescinds consent; and other circumstances according to the China PIPL.
  • The right to refuse or limit the processing – Data Subjects have the right to restrict the School’s processing of their Personal Information to a specified purpose.
  • The right to data portability.
  • The right to know and be informed about automated decision-making activities, if any, and right not to be subject to automated decision-making for significant activities.
  • The right to refuse targeted ads done by automation.
  • The right to object and restrict the processing of Personal Information or its results whenever the same contradicts the Data Subject’s fundamental rights and freedom – Data Subjects have the right to object to types of processing, such as direct marketing.
  • The right to lodge a complaint with the departments fulfilling Personal Information protection duties and responsibilities – If the Data Subjects have a legal basis to object to the handling of their Personal Information by the School, they have the right to complain to the local authorities for any alleged infringement of Data Protection Laws that have taken place.

If the Data Subjects choose to exercise any of the rights described above, or if they have any questions about how the handling of their Personal Information flows, they may contact the School.

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@sabisulink.sabis.net
  3. Writing us at: SABIS®ULINK at the following address: No.559, Laiting South Road, Jiuting, Songjiang District, Shanghai, China.

ACCEPTANCE AND CHANGES TO THE POLICY

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