The American School Foundation

PRIVACY NOTICE

STUDENTS AND PARENTS

1.     Identity and address of the Responsible:

The American School Foundation, A.C. (hereinafter “ASF” or the “School”), with address at 215 Bondojito St., Las Americas, Alvaro Obregón, 01120, Mexico City, Mexico.

2.     Data to be processed by the School:

As part of the admission and/or reenrollment process of students, and, if applicable, to provide you our educational services, as well as the registration of the student and their parents, guardians, legal representatives, and third parties related to the School, ASF will collect and process the following information:

a)    From the student: identification data (including his/her image whether in photo, video or any other similar format), contact information, academic, sensitive data (medical records and, if applicable, disabilities or special needs), and geolocation (for the school transportation service).

b)    From the parents and/or guardians: identification data (including their image whether in photo, video or any other similar format), contact information, labor data, financial, assets information, and sensitive data (medical records).

c)    From his/her sibling(s): identification data and the school they belong.

The data mentioned above are collected during the admission and/or reenrollment process of the student and the course of the academic life of the student and added in the academic record of the student.

Also, we inform you that in order to comply with the purposes mentioned in this Privacy Notice, the School will collect and process sensitive data, as those which may reveal aspects such as present and future health, psychological and developmental status. This information allows us to understand the behavior of your child, which can reflect factors that occurred during pregnancy, birth and the family situation where the student develops.

Additionally, ASF informs you that may take images (photo, video or any other similar) of i) interviews with the student and/or parents or guardians, ii) virtual and/or in-person meetings and/or tours, iii) academic activities, and iv) psych-pedagogy assistance in which parents or guardians may or may not participate, in order to ensure the safety and the student’s best interest, which only may be consulted only by the persons with the legal custody of the student, by the School staff and, if applicable, by third parties with the prior written approval of the parents or guardians of the student. Such records will be deleted at the end of the corresponding school year. If you have any questions regarding this data treatment, please contact the Shool’s Data Privacy Office at privacy@asf.edu.mx

3.     Purpose of data processing:

ASF will process your and/or the student’s data for the following purposes necessary to comply with the obligations arising from our legal relationship:

a) Primary purposes:

i) To validate the information and/or documentation of the student and/or his/her parents or guardians

ii) To carry out the necessary steps for the student’s enrollment and/or re-enrollment process to the School, to register him/her in our system and to complete the medical and academic records and, in case, for academic revalidation and accreditation in Mexico and abroad, as well as to make the necessary arrangement with the corresponding school/educational authorities.

iii) To provide you and/or the student the academic services of the School and make all activities needed to contribute to the personal development of the student, including academic test.

iv) Participation of the student in academic, school, sports, cultural and social events, extracurricular activities, activity clubs and other events and/or activities organized by the School and/or third parties.

v) To issue an ID credential that identifies you as a student, parent, or guardian, authorized adult and/or caretaker.

vi) To borrow your didactic materials for academic and/or extra-curricular activities.

vii) To contact and share with you information on academic, conduct, school, medical and administrative affairs regarding the student, as well as to contact you in case of emergency.

viii) To investigate a possible commission of conducts by the student and/or his/her parents or guardians or authorized adults contrary to the School’s Family Handbook, its core values or the Ethics Code or any fact that jeopardizes to the best interest of the student and, if applicable, to inform the corresponding authorities about the events occurred.

ix) Use of technological tools and/or applications (property of ASF and/or third parties) with academic, school, extra-curricular, and administrative purposes for the benefit of the student and/or parents or guardians.

x) Keep an updated our database of the students and/or parents and/or guardians.

xi) To provide transportation services to the student from his/her home to the School’s facilities and vice versa and, in case, transportation services to academic and extra-curricular activities and/or sports events.

xii) Receive payments, issue voucher payments, billing statements, as well as to document and conduct collection activities in case of debit.

xiii) Grant you with financial aid, financial support, scholarship, and/or loans, in case of compliance with the corresponding requirements and, if applicable follow up of such financial supports.

xiv) Take out, manage, and/or cancel the corresponding insurance (including medical insurance).

xv) To have a medical control and record of the student, including special medical needs of the student, detect the existence of any illness or medical condition that we should know, or medical prescription to be considered for the care of the student, as well as to know if the student is on physical conditions to doing sports and/or any other extra-curricular activities.

xvi) If necessary, consider the student in special education programs provided by the School and carry out all activities necessary to provide the student with special educational services, as well as to promote his/her full development.

xvii) To arrange the participation of the student in academic and/or school events, camping, and any other events related organized by the School.

xviii) Take images from you and/or student, whether in photographic, video or any other similar format, of academic, school, sports, cultural, social, extracurricular activities and other events and/or activities organized by the School, as well as psycho/pedagogical support, including such sessions in which parents and/or guardians do not participate, with the purpose to ensure the safety and the student’s best interest.

b) Secondary purposes:

In case you do not express the contrary, the School may process your and/or the student’s data for the following secondary purposes:

i) Keep you informed regarding the dates of birthdays and extracurricular events of the student’s classmates, as well as to share your contact information with the parents and/or guardians of the student’s classmates so that they can be in direct contact with you and may arrange extracurricular events with the students and/or theirs parents and/or guardians.

ii) Keep you in our database to notify you of future opportunities to be part of ASF in case not be admitted.

iii) Contact you and/or share with you information regarding all kind of extracurricular, sporting, social and other events organized by the School.

iv) Invite you to participate in activities related to fundraising purposes and, if applicable, register you as donor and issue a tax receipt according with current legislation.

v) Register you as participant and/or speaker at an event, issue your certificate of participation and, if applicable, give you the corresponding credit for your participation.

vi) To send you and/or your child all kind of gifts, prizes and/or presents to your home.

vii) So that parents or guardians of the student may participate and/or be part of academic and/or extracurricular clubs organized by the School.

viii) Send you advertising and communications form the School with marketing and telemarketing purposes.

ix) Invite you to participate in our own and/or third parties surveys to improve our services, and with market research and contest purposes, as well as for tasks, homework and research carried out by students, ASF and/or third parties.

x) In case of request of the student and/or parents or guardians, to provide support during your inclusion and adaptation to the community and the School activities.

xi) Take images from you and/or student, whether photographic, video or any other similar format, to make internal and/or external publications, whether in print and/or digital media, on the School’s website, ASF social media, TV screens inside the School, and the yearbook, regarding the student’s personal and academic history, his/her participation in academic, school, extracurricular, social and sports events and any other kind of events organized by the School and/or in which the  as well as to promote the School.

xii) Video surveillance inside and around the School’s facilities for the safety of all ASF community, including images taken inside the school transportation units.

xiii) One the student has finished is studies at the School, register him/her as alumni of the School in our systems and maintain a communication channel with him/her to announce births, marriages, deaths and other important events related to the alumni of the School, invite him/her to all kind of social, academic, sports, extracurricular, conferences and fundraising events organized by the School or third parties, send gifts, prizes and/or presents to his/her home, promote services and/or products offered by members of the ASF community, send benefits, promotions and news according to the his/her needs, including job offers from our job bank, as well as provide academic references to companies, organizations or third parties that request them.

In case you don’t want your data and/or the student’s data to be processed for the secondary purposes mentioned above, you have the right to refuse the process for such purposes through the procedure established in this Privacy Notice, specifying the secondary purpose(s) for which you do not want us to use your and/or the student’s data. Your refusal will not be a cause to stop providing you with the educational services offered by the School.

In case you don’t refuse the process of your images/pictures and/or the student (either photographs, video recording, or other similar means) for the secondary purposes mentioned, the School understood that you have granted your consent for the use of your images/pictures and/or the student, according to the Data Protection Law (Ley de Protección de Datos Personales en Posesión de los Particulares) (“Law”) and articles 17 and 19 of the Civil Responsibility for the Protection of the Right to a Privet Live, Honor and Self Image Law for the Mexico City (Ley de Responsabilidad Civil para la Protección del Derecho a la Vida Privada, el Honor y la Propia Imagen en el Distrito Federal). You have the right to revoke your consent for the use of your image/picture and/or the student at any time.

4.     Transfer of the data:

With the purpose to comply with the primary purposes, ASF may transfer without requiring your consent due to being an exception mentioned on article 37 of the Law, the necessary data to the following (natural persons and/or legal entities):

a) To insurance companies which ASF has taken out the medical insurance mandatory for all students, as well as for school accident coverage, either by the School or through an insurance broker.

b) To companies that provide services to the School, such as transportation, cafeteria, courier and parcel services and companies that organized all kind of academic, school, sporting, cultural and social events, extracurricular activities, activity clubs and other events.

c) To other schools, educational institutions, commissions, associations, or leagues which participate in academic and/or extracurricular activities like sports tournaments, leagues, academic competitions, and/or contests.

d) To authorities and/or academic entities to make the necessary arrangements for the academic revalidation and accreditation in Mexico and abroad, as well as administrative arrangements with such institutions.

Likewise, in case we have your consent, ASF may transfer your necessary data to the following (natural person or legal entities), in which we require your consent:

a) To other academic institutions in case, the students have applied to a different school, with the purpose to provide reference regarding the student.

b) To other parents which participate in the “Ambassadors” program to support your inclusion and adaptation to the community and the School activities and/or “Homeroom Parents” programs for being a liaison with the parents, professor, and the classroom with the purpose to keep you informed regarding the activities of the student classroom and/or the School, inform you about camping and other activities and keep a calendar of special dates.

c) To academic institutions in case of participating in scholarship programs and similar projects with the purpose that students could be contacted and participate in such programs.

d) To include your contact information, as well as the student’s birthday and group/class in the “Booklet” that is shared with the parents and/or guardians of the student’s classmates, to keep you informed regarding the birthdays and extracurricular events of the student’s classmate’s, as well as so that the parents and/or guardians of the student’s classmates can be in direct contact with you and can arrange extracurricular events with the students and/or you.

Except to comply with the purposes above mentioned or such required by the law or corresponding authorities, ASF will not transfer your data and/or the student to third parties outside the School and only transfer your data in the situations provided by the law

At any time, you have the right to refuse the transfer of your data and/or the student whose ASF needs your consent according to the procedure established in this Privacy Notice. In case you do not refuse the transfer, the School understood that you have granted your consent for the transfer of the data in which we need your consent.

5.     Procedure to refuse the processing of your and/or the student’s data:

You may refuse the processing of your and/or the student’s data for those purposes which are not necessary for the legal relationship with ASF and/or the transfer of the data in which we need your consent, by sending an email to privacy@asf.edu.mx which must include the following information/documentation:

a) Name of the holder of the data and address or any other means to receive communications;

b) Official ID of the holder of the data and, if applicable, the official ID of his/her legal representative and/or parents or guardians.

c) A clear and precise description of the data of which you want to refuse the treatment; and

d) Your express refusal to the processing of your and/or the student’s data.

If you do not express your refusal for the processing of your and/or the student’s data within the 5 (five) business days after the acceptance and/or updating of this Privacy Notice, it will be understood that you grant your consent for the processing of your and/or student’s data as mentioned in the secondary purposes, as well as the transfer of your and/or student’s data for which we need your consent.

If you do not express your refusal within the aforementioned period, you may exercise your right to revoke your consent or refuse to the processing of your and/or the student’s data at any time by following the procedure described above.

6.     Means and procedures to exercise the ARCO rights and/or revoke your consent:

You have the right to exercise your rights of access, rectification, cancellation or opposition (“ARCO rights”), as well as to revoke your consent for the processing of your and/or the student’s data in our possession, by sending a letter to our Data Privacy Office at privay@asf.edu.mx which must include the information/documentation indicated in the preceding Section 5 of this Privacy Notice.

Your request should be made in writing or through the ARCO Right Application drafted by the School, which is available at the following link and contains all the elements required in Section 5 above. In order for the School’s Data Privacy Office to be able to attend and process your request, you must duly prove your identity and the legal custody of the student, so it is necessary to fulfill all the required boxes in the ARCO Right Application and attached copy of the corresponding documents indicated in such application form.

In the event that the information/documentation is wrong or insufficient, ASF may request you the missing elements to process your request, within 5 (five) business days following the receipt of your request. You shall have 10 (ten) business days to comply with such request, after the day you’ve received the communication. In case of not responding within such term, your request will be considered as not submitted.

In case your request is correct and contains all the necessary information/documentation to process your ARCO rights solicitation, ASF will provide you with a response within 20 (twenty) business days following the date of receipt of your request. If your request is granted, it will be effective within 15 (fifteen) business days following the date on which the response is communicated to you.

When you exercise your ARCO rights to access your ad/or the student’s data, these will be sent to the email you have indicated in your ARCO request or provided by writing at the ASF address.

7.     Options and means to restrict the use or disclosure of your and/or the student’s data:

You have the right to restrict the use or disclosure of your and/or the student’s data (other than your ARCO rights or to revoke your consent), by sending an email to privay@asf.edu.mx The requirement to validate your identity, as well as the procedure and response time to respond to your request will be governed in accordance with the provisions of Section 6 above. If the event that your request is accepted, the School will register you in the exclusion list for the purpose(s) for which the exclusion is applicable.

8.      Use of cookies, web beacons, and any other similar technologies:

ASF inform you that it uses “cookies” and other similar technologies with the purpose to improve the experience of the users on its website and social media, whose allow us to collect and store information of when you access to our website and/or social media, which allow us to analyze the traffic of our website and/or social media, identify and save your languages preferences, identify your IP address, time and time of navigation into our website and/or social media, sections visited and website visited before access to our website.

These cookies and similar technologies may be disabled by consulting the help menu of your browser and following the procedure indicated in such a browser.

9.     Privacy notice updates:

ASF reserves the right to modify or update this Privacy Notice at any time. Such modifications will be available to the public through the website www.asf.edu.mx/privacy-policy We encourage you periodically visit out website to stay informed about such updates or modifications.

 10.   Governing language:

In the event of any dispute arising from this Privacy Notice, the Spanish language version must govern this Privacy Notice.

Last update: October 7, 2022.