EU–U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss–U.S. DPF

ManageBac LLC (“ManageBac”) respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others.

ManageBac strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices. This EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and Swiss–U.S. Data Privacy Framework (“Swiss-U.S. DPF”) Policy (the “Policy”) sets forth the privacy principles that ManageBac follows with respect to personal information transferred from the European Union (EU), the United Kingdom (UK) and / or Switzerland to the United States.

Data Privacy Framework (DPF)

The United States Department of Commerce and the European Commission and the Swiss Administration, respectively, have agreed on a set of data protection principles and frequently asked questions (the “Data Privacy Framework”) to enable U.S. Companies to satisfy the requirement under European Union and Swiss law that adequate protection be given to personal information transferred from the EU and Switzerland to the United States. Consistent with its commitment to protect personal privacy, ManageBac adheres to the DPF Principles.

ManageBac LLC, ManageBac Inc., Dynamic Internet Solutions LLC, and Rubicon West LLC (“we”, “us” or “our”) comply with the EU–U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss–U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and United Kingdom, and Switzerland to the United States, respectively. We have certified to the Department of Commerce that we adhere to the DPF Principles. If there is any conflict between the terms in our privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF Program, and to view our certification, please visit https://www.dataprivacyframework.gov/list

Scope

This Policy applies to all personal information received by ManageBac in the United States from the European Economic Area and the United Kingdom, and Switzerland, respectively, in any format including electronic, paper or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply:

“ManageBac” is owned and operated by ManageBac LLC, a Delaware limited liability company in the USA.

“Personal information” means any information or set of information that identifies or is used by or on behalf of ManageBac to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, ManageBac will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Notice and Choice

ManageBac enters into Service Agreements with its Clients in the European Union and the United Kingdom, and Switzerland which may include the processing and/or storage of information relating to their Clients’ customers (students, parents and staff). In these agreements, the Client agrees and recognizes that it is the ‘data controller’ for the purposes of data protection legislation. This means that our EU, UK and Swiss Clients are responsible for complying with the data protection legislation in the relevant Member State, UK and Switzerland national law before it sends its customer data to ManageBac for processing and/or storage. This includes informing individuals about the choices and means they offer individuals for limiting the use and disclosure of their personal data. In order to exercise their rights under this principle, the individual must reach out to their School (our Client), as data controller. Any data processed or stored by ManageBac is only disclosed to third parties at the request and direction of its European, UK and Swiss Client as the data controller, in accordance with the choices made by the individuals to whom such personal information relates, or when required by law. Any information that our EU, UK and Swiss Clients identify as sensitive will be treated as such.

ManageBac has a Compliance Manager who is responsible for the internal supervision of ManageBac privacy policies. ManageBac also has technicians to handle data security. ManageBac continuously educates its employees about compliance with the Data Protection Act 2018, the DPF Principles and has self-assessment procedures in place to ensure its compliance. ManageBac participates in the EU–U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss–U.S. DPF as set forth by the United States Department of Commerce.

Information Gathering and Usage:

ManageBac will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We use the information provided and that we collect to improve the content and quality of the Service, error correction, improving our marketing, and for administrative purposes.

Your use of the Service results in collection of audit log records, which are collected through third party solutions. These facilitate providing the Service, through web hosting companies or by using analytics providers. This allows us to monitor system and application performance, to track usage activity and to enable our support team to provide you with a professional standard of service when you have any issue.

In the course of providing the Service, we use and disclose to Subprocessors the information provided in order to:

1. Process account registration and enrolment;
2. Organise curriculum, activity and assessment information;
3. Compile academic histories and formal academic records;
4. Aggregate, collect and input details of your academics into our system for central management;
5. Compile your profile and the foregoing for your School or as a User.
6. Present information entered to other logged in users provided Parental Consent is provided when applicable;
7. Monitor system performance and collect aggregate analytics;
8. You as a User, or your School may make such information available to the International Baccalaureate, which in turn may make information available to qualified Higher Education Institutions.

The list of Subprocessors and proposed Subprocessors for ManageBac is available here: https://www.minipd.com/terms/privacy-policy/subprocessors.

If it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service or Terms of Use, or to comply with any legal requirement such as, but not limited to, complying with a subpoena or cooperating with law enforcement agencies.

Access Personal Data

If your personal information changes, you are able to login to keep it up to date by changing your profile. If you no longer wish to receive the Service or if you find that information on the Website is not accurate and you cannot update it, please inform your School in the first instance. You may email us at legal@fariaedu.com if you continue to have concerns. If you do not receive a response to your email to us within 7 days please call us or write to

ManageBac LLC
Privacy Department
Email: dpo@fariaedu.com
Postal Mail: 548 Market St. #40438, San Francisco, CA 94104

Onward Transfer

ManageBac shall bear liability in cases of onward transfer.

Enforcement:

ManageBac will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that ManageBac determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. Under certain limited conditions, individuals may invoke binding arbitration as a last resort. ManageBac’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Dispute Resolution:

If you feel that this company is not abiding by its posted privacy policy or is not in compliance with the DPF Principles, you should first contact ManageBac’s Compliance Manager by email at privacy@fariaedu.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then invoke a binding arbitration process. Please refer to Annex I of the DPF Principles available here: https://www.dataprivacyframework.gov.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ManageBac commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Contact information for the DPAs in your member state is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Contact information for the ICO is available here: https://ico.org.uk

Contact information for the FDPIC is available here: https://www.edoeb.admin.ch/edoeb/en/home.html

Client Data Storage:

ManageBac complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss–U.S. DPF as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union, United Kingdom, and Switzerland.

If you have any questions, comments, or concerns or wish to update, delete or change any personal information submitted on this Site, or have any questions about our Privacy Policy, please notify us through email or postal mail at:

ManageBac LLC
Privacy Department
Email: privacy@managebac.com
Postal Mail: 548 Market St. #40438, San Francisco, CA 94104

Changes To This Policy

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. A notice will be posted on ManageBac’s web page: https://www.minipd.com/terms/dataprivacyframework

Effective Date: June 27, 2017

Updated at February 28 2024

Reference:

To learn more about the EU–U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss–U.S. DPF, and to view the certification of ManageBac LLC, ManageBac Inc. and Rubicon West LLC, please visit: https://www.dataprivacyframework.gov/list