We care about privacy.
We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their users, who are often students. We take the obligations that are attached to this information very seriously. We, therefore, have a dedicated data privacy program with privacy by design at heart. You can learn more about our data privacy program by visiting our privacy center.
Our business model is different from that of companies that collect your personal information to monetize such data. We collect and use personal information to allow us to provide our products and services to our clients and end-users. In most cases, we do this at the direction of our clients. We do not and will not sell or rent your data to third parties unless this is required in the context of changes to our business structure such as a merger or acquisition.
Who we are . When we refer to “us,” “we,” “our,” or “Sabina” in this Statement, we mean Sabina Ltd. and its affiliates.
This Statement governs all the services that we provide directly to you . Whether you are browsing our websites, receive our newsletters, or use an online trial version of our products, this Statement governs the use of personal information for all our products and services that we provide directly to you as a so-called ‘data controller.’
When your institution’s privacy statement/policy governs . If you are an end-user of our client and we are providing our products and services to you on our client’s (your institution’s) behalf, we are considered a ‘data processor.’ In this case, your institution’s privacy statement governs the use of personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your institution (or any other client or a third party), nor does it affect the terms of any agreement between you and your institution.
Changes to this Statement . From time to time we will need to update this Statement to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements.
Payments . Where you use our products and services to make a purchase or transaction, we will share your payment and transaction data with banks and other organizations to process the transactions and for fraud detection and prevention or anti-money laundering purposes.
Changes to our business structure . Where permitted by applicable law and by the contracts with our clients, we may disclose your information in the following cases. We will always aim to continue to apply to the commitments we make in this Statement in such a case. If this is not possible, we will notify our clients and we will not provide personal information about end-users of our clients (including Student Data) without the required agreement of our clients, to a successor entity in the situations described below:
Corporate transactions such as a merger, acquisition, sale of assets, and financing
Bankruptcy, dissolution or reorganization, or in similar transactions or proceedings
Steps related to the previous bullet points (for example, due diligence)
Comply with law . We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. We will always aim to limit the information we provide as much as possible. Where such disclosures relate to the personal information we hold on behalf of our clients, we will defer such requests to our clients where permissible.
Enforce our rights, prevent fraud, and for safety . We may need to disclose your information to protect and defend the rights, property, or safety of us, our clients, or third parties, including enforcing contracts or policies or in connection with investigating and preventing fraud.
De-identified information . We may disclose aggregate or de-identified information that is no longer associated with an identifiable individual for research or to enhance and promote our products and services. For example, we may share aggregated or de-identified information with our partners or others for business or research purposes like partnering with a research firm or academics to explore how our products are being used and how such data can be used to enhance our functionalities and further help our clients and other educational institutions. We will implement appropriate safeguards before sharing information, which may include removing or hashing direct identifiers (e.g., your name, email address, and device ID).
Client engagement & marketing
Managing the client relationship . We are collecting and storing limited personal information about the relevant contacts at our clients for invoicing, notification of product updates and maintenance, and similar purposes.
No behavioral advertising to students in our products and services. We do not use or disclose information (whether personal information or otherwise) about students that we collect through the educational products and services we provide on behalf of educational institutions for behavioral targeting of advertisements to students. We may place contextual advertising were permitted by our agreement with your institution.
Promotion of products and services. We conduct marketing to promote our products and services. This marketing is generally aimed at the staff of our current and potential clients and partners. However, we do not restrict activities and events to those audiences when such activities and events benefit instructors and other end users of systems, such as webinars that explain how our products can be used effectively.
Events and webinars . When we conduct or sponsor events and webinars, we will collect information about attendees, such as the session they attend and their contact details, provide them with relevant product information and other Sabina-related information.
Sharing within Sabina . We may share personal information related to marketing with the relevant Sabina affiliates and departments. For example, information from a local Sales team may be provided to the global Field Marketing and Marketing Operations teams to update the relevant systems and send products and other promotional communications to you.
Sharing with partners . In some countries and regions, our products and services are offered through channel (or reselling) partners. We will share the information that is necessary for our partners to promote our products and services to their clients and potential clients. We also work with technology and content partners with whom we may share information such as event attendance if we have permission to do so.
Sharing with vendors . We may use vendors to help us organize and conduct campaigns, events, and other aspects of marketing. We will share with them only the personal information that is necessary and ensure that they are following our strict requirements for vendors.
Marketing preferences and opt-out . Our marketing emails will include a link so that you can change your preferences and opt-out of receiving marketing communications from us. You can do this by clicking on the "Unsubscribe" link in the email footer which will direct you to our Marketing Preference Center. While it doesn’t give you the same detailed controls as our Marketing Preference Center, you can also send us an email at email@example.com to unsubscribe.
Online and interest-based advertising on our websites . At times, we use third-party advertising tools to collect information about your visits to our websites to serve you targeted advertisements based on your browsing history and interests on other websites and online services or on other devices you may use. We only use these tools on our own websites and not for our products and services. When we are providing our services on behalf of a client, our products and services do not use interest-based advertising tools except as instructed by our clients.
In some instances, we may share a common account identifier related to your use of our websites (such as an email address or user ID) with our third-party advertising partners to help identify and contact you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
These tools will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each browser or device you use.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Google Analytics and Advertising on our websites . We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting on our own websites. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our websites. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site.
We employ a variety of physical, administrative, and technological safeguards designed to protect personal information against loss, misuse, and unauthorized access or disclosure. We have dedicated information security programs and work hard to continuously enhance our technical and operational security measures.
Our measures consider the sensitivity of the information we collect, use, and store, and the current state of technology. Our security measures include data encryption, firewalls, data use, and access limitations for our personnel and vendors and physical access controls to our facilities.
All products and services that use payment data maintain the applicable Payment Card Industry (PCI) compliance levels. Our compliance with the PCI standards is validated during annual audits that are conducted by external auditors (so-called ‘Qualified Security Assessors’).
You have the right to control how your personal information is used. You may have the right to request access to, the rectification of, or erasure of personal information we hold about you. In Egypt, you also may have the right to object to or restrict certain types of use of your personal information and request to receive a machine-readable copy of the personal information you have provided to us.
In many of our products, you will be able to access your information as well as change and delete some of the information yourself by logging into your account. If you cannot access, correct, or delete the required information yourself, please follow these steps:
If you are a user of our products and services that we provide on behalf of your institution, contact your institution to exercise your rights . They need to manage your request even if it relates to the information that we store on behalf of your institution. We will support your institution with your request.
Please remember that many of these rights are not absolute. In some circumstances, we (or your institution) are not legally required to comply with your request because of relevant legal exemptions.
In many jurisdictions, you also have the right to lodge a complaint with the local data protection authority. But please contact us first, so we can address your concern.
End-users of institutions and technical issues: If you are a user of our products and services we provide on behalf of your institution, contact your institution first as your institution's privacy statement and data privacy practices will determine how Sabina uses personal information on your institution's behalf. If you have a technical or support issue, please contact the helpdesk of your institution. They will be able to assist.