OUR PRIVACY COMMITMENT
“Baobabooks” is a web platform operated by (BAOBABOOKS, Sàrl) “Baobabooks Sarl” (hereinafter “Baobabooks”). At “Baobabooks” we recognize the importance of and are fully committed to protecting the privacy of personal information related to all individuals with whom we interact – including members of the public, students, children, regulatory authorities’ representatives.
ABOUT THIS PRIVACY STATEMENT
This Privacy Statement (the ‘Statement’) is an overview of how “Baobabooks” and its worldwide Affiliates (to learn more about “Baobabooks” s Affiliates and how to contact them directly please visit our corporate website at: http://www.Baobabooksglobal.com/ – Contact Section) process personal information about individuals, and illustrates “Baobabooks’s” commitment to ensuring that individuals can exercise choice and control over their personal information in accordance with local laws.
SCOPE OF THIS PRIVACY STATEMENT
This Statement is specifically intended to provide information for our website users, members of the public who interact with Baobabooks’s Baobabooks platform and individuals with whom we do business (including, but not limited to, staff at regulatory authorities, personnel of suppliers and partners and visitors to Baobabooks’s offices). This Statement also provides specific information about specific privacy practices towards specific genre of data subjects such as Children – Student. References to “Baobabooks” “Baobabooks”, “Platform” “group”, “affiliates”, “we”, “us” and “our” are references to Baobabooks Platform and its worldwide affiliates. Please read this Statement before using Baobabooks’s Baobabooks Platform www.Baobabooks.com or otherwise providing your personal information to us. By visiting our Website or by providing us your personal information, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Statement.
PERSONAL INFORMATION BAOBABOOKS MAY PROCESS ABOUT YOU
Generally, you can browse the site without disclose your personal information. To become a member, it is required you to provide contact and identity information, as indicated to the various forms of the aforementioned website. You always have the option to not provide information by choosing not to become a Member or by not using the particular feature of the Site for which the information is being collected. Baobabooks may process personal information about you including, but not limited to:
- General information such as name, email address (a parent’s or legal guardian’s email address if the member is under 13), phone number, date of birth, and other information such as photographs and digital imager, payment- related information, agreements, your communications preferences; queries you make to Baobabooks;
- Professional information, such as your job title, educational information, professional qualifications, work experience, professional networks, programs and activities in which you participated; Specifically, educators may provide school name, a class grade level and class name.
- Digital information generated from your use of Baobabooks’s websites and mobile applications, such as IP address, geo-localization, device ID and data transmitted via Cookies. For further details on the use of Cookies by Baobabooks please read our Cookies Statement available at: Cookies Statement.
SOURCES OF INFORMATION
In most cases, Baobabooks will collect information directly from you, although sometimes we will obtain information about you from public or third-party information sources including (but not limited to):
- Baobabooks may collect information about you from public or third-party sources for marketing purposes and to verify professional information (including but not limited to access to publicly accessible information, national registries or third-party databases);
- Baobabooks may collect information from your computer or other device you use when visiting Baobabooks’s website such as Internet Protocol (IP), domain name, Internet Service Provider (ISP), information about date and time of your request and other information provided by tracking technologies. Please see our Cookies Statement here.
- Information may be shared within the Baobabooks Group of Companies, which includes our worldwide Affiliates.
WHY BAOBABOOKS PROCESSES YOUR PERSONAL INFORMATION
Baobabooks will only process your personal information for purposes permitted by applicable laws, which may vary depending on where you live, and where Baobabooks operates. The purposes of the data processing activities may include:
- Managing Baobabooks’s relationship with individuals for example, responding to questions and comments, inviting individuals to Baobabooks’s events;
- Managing user account, in order to provide information regarding your (or your Student or child’s) book preferences.
- For collaboration purposes, for example to enable Baobabooks to make more informed and objective decisions when identifying, engaging with professionals and key opinion leaders and managing the collaboration relationship with such professionals;
- Market Research, processing information about individuals for lawful market research purposes. We collect information through surveys and interviews to help us improve our services.
- Direct Marketing, we process personal information to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable local laws (You have choices about this – see “Individual Choices: Rights And Access To Information” section of this Statement).
- Regulatory Reporting, processing information where necessary to comply with regulatory obligations.
- Website functionalities, to ensure that content from our Website is presented in the most effective manner for you and for your device.
- Any other purpose that is relevant to the relationship between Baobabooks and you.
Baobabooks will process personal information for further purposes, where lawful to do so (such as for archiving, scientific or market research purposes) or when legally obliged to do so.
LEGAL BASIS OF PROCESSING
Baobabooks processes personal information under one or more of the following conditions:
- Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
- Where it is necessary to comply with contractual obligations with you;
- Where the processing is necessary for our compliance with a legal obligation; or
- Where the processing is in Baobabooks’s legitimate interest, for example, Baobabooks processes information for statistical and survey purposes, information about Baobabooks’s visitors and supplier personnel, for the improvement of our services, to provide security measures to protect Baobabooks’s employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations).
DATA SHARING AND CROSS-BORDER DATA TRANSFERS
Baobabooks headquarters are in Switzerland, and its operations are in Switzerland. Personal information about you may be accessible to Baobabooks headquarters in Switzerland as well as to some Baobabooks’s Affiliates outside European Union (“EU”)/ European Economic Area (“EEA”), and selected vendors and partners, established in the EU or globally. Any personal data you supply to Baobabooks when using our online platform are processed in accordance with the Swiss Data Protection Act (DSG) and other legal provisions such as GDPR when we interact with EU Citizens and there is the applicable scope of this regulation. We do pass on personal data to third parties or contractors who are not based in Switzerland nor a EU/EEA country. In this case, before passing on the data, we check that the recipient either has an appropriate level of data privacy (e.g. based on a suitability test for the respective country, a self-certification process by the recipient for the Swiss-US Privacy (framework for transmitting personal data from Switzerland to the USA), or by using the European Union’s standard contract clauses or the Swiss Federal Data Protection and Information Commissioner (EDÖB) standard contract) or that the user has given their consent.
Baobabooks will implement reasonable and appropriate legal as well as technical and organizational security measures to ensure the security of the processing and in particular to protect your personal information from unauthorized access, use or disclosure including, but not limited to, maintaining binding contractual arrangements with all third parties processing personal information of individuals, for and on behalf of Baobabooks, as well as executing, where necessary, adequate data transfer mechanisms, in the form of standard contractual clauses, for any cross-border data transfers from Switzerland to controller or processors established in EU and third countries, as adopted and approved by the European Commission, or by the competent supervisory authorities, with the aim to achieve an adequate level of data protection of the personal information of those individuals. For residents of EEA – whenever we transfer your information outside of the EEA, we will either ask for your explicit consent or take any and all necessary steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above.
The confidentiality of Personal Information transmitted over the Internet cannot be guaranteed; Baobabooks urges you to exercise increased caution when transmitting Personal Information over the Internet, as we cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information. Our Website may contain links to other third-party websites which may have their own privacy policies and terms of uses.
Baobabooks has no control over such third-party websites or their content, and this Privacy Statement does not apply to such websites. We do not accept responsibility or liability for the policies or processing of your personal information by websites linked to or from our Website as we do not control the privacy practices of these third parties and we strongly recommend you review the privacy settings they have set up directly with them by visiting their respective privacy related websites and policies.
DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
Baobabooks discloses personal information to third party recipients where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal information will be disclosed only in accordance with local applicable laws, and appropriate safeguards will be established, where possible, to protect your personal information. Baobabooks may disclose personal information to any member of our group of companies.
In order to conduct Baobabooks’s business, Baobabooks may also disclose information to third parties such as public/regulatory authorities/governmental bodies (government, including social and benefits departments), third parties that provide services to Baobabooks platform (such as but not limited to service providers conducting audits, providing IT services, cloud – based web servers hosted by third – party service providers (currently Amazon AWS) etc.), business partners and collaborators (such as external professionals), reviews and assist Baobabooks with its business activities, if Baobabooks or substantially all of our assets are acquired by a third party, in which case personal information held by us about individuals will be included as transferred assets, or if Baobabooks is under a duty to disclose or share individuals’ information in order to comply with any legal or regulatory obligation or request.
Baobabooks may also disclose information to enforce any agreements it has with individuals; or to protect the rights, property or safety of Baobabooks’s employees or others (e.g. visitors to Baobabooks premises).
AUTOMATED DECISION MAKING AND INDIVIDUALS’ RIGHTS
Baobabooks does not undertake decisions based solely on automated processing, including profiling, of individual unless we inform you otherwise.
INDIVIDUAL CHOICES: RIGHTS AND ACCESS TO INFORMATION
ACCESS, REVISION, DELETION
Under applicable privacy laws (e.g. European data protection and privacy laws), you may have a right to request a copy of personal information of you held by Baobabooks. You may also have the right to revise, correct, or delete such information. Your rights to such information may be subject to limited legal and regulatory restrictions.
CHOICES ABOUT MARKETING
If we intend to use your information for marketing purposes or if we intend to disclose your information to any third party for such purposes, we will inform you respectively. You have the right to object to personal information being used for the purposes of direct marketing and sending scientific information and newsletters. Where this right applies, you can exercise this and prevent such processing by checking certain boxes on the forms we use to collect your personal information (please use the “opt-out” or “unsubscribe” functionality in electronic communications to update your preferences). You can also exercise the right at any time by contacting us as set out below.
COOKIES
Information about use of cookies and similar technology implemented by Baobabooks on digital services and Baobabooks’s website can be found at Baobabooks’s Cookie Statement available at: Cookies Statement.
OBJECTION TO PROCESSING AND ADDITIONAL RIGHTS
Under applicable privacy laws (e.g. European data privacy law), where Baobabooks relies on legitimate interests or public interest to process information, and where Baobabooks conducts direct marketing, individuals can formally object to processing of their information for these purposes (in addition to the “Choices about Marketing” set out above). Individuals should clearly state “objection to processing” when contacting Baobabooks to exercise this right to objection.
In certain circumstances, you have the additional rights to restrict aspects of the processing of your information or ask for a copy of your data to be provided to you, or a third party, in a digital format.
EXERCISING YOUR INDIVIDUAL RIGHTS
Your exercise of the above-mentioned rights is subject to certain exemptions to safeguard the public interest and our own legitimate interests. If you decide to exercise any of these rights, we will check your entitlement, we may request to confirm your identity and in any case we shall respond within a calendar month from receipt of such a request, unless there are valid grounds for extending the response periods, essentially due to the need to confirm your identity, to request additional information or to ask you to specify or limit your request, in case your request is too general or too complex to be handled within the initial deadline. Baobabooks may not be able to comply with a request where personal information has been destroyed, erased or made anonymous in accordance with applicable laws and regulations as well as with Baobabooks’s record retention obligations and practices. In the event that we cannot satisfy a request with regards to your personal data, we will endeavor to provide you with an explanation, subject to any legal or regulatory restrictions.
If we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority. Further information and contact details of the competent supervisory authorities can be found here: [email protected]
To exercise your individual data protection rights please contact our Privacy Office by email at [email protected]. Alternatively, you may contact us by post at the address available at Contact Us section below.
HOW LONG BAOBABOOKS RETAINS YOUR PERSONAL INFORMATION
We will retain your personal information for no longer than is necessary for the processing purpose(s) for which your information was collected and any other permitted associated purpose. Information may be retained for a longer duration where applicable laws or regulations require or allow Baobabooks to do so. Your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
SECURITY OF PROCESSING OF PERSONAL INFORMATION
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement, applicable data protection laws and regulations and international industry security standards. All information you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Baobabooks has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal information protected from unauthorized access, disclosure, alteration, and destruction. Such measures may include, but are not limited to: firewalls, access controls, encryption of information while it is in storage, separation of duties, and similar security protocols.
Access to your personal information is limited to a restricted number of Baobabooks employees whose duties reasonably require such information and third parties with whom Baobabooks contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely.
APPLYING TO WORK AT BAOBABOOKS
Baobabooks processes information to identify job applicants and assess job applications and for other human resources processes necessary for evaluating and considering job applications. The information processed may include information such as your job title, education information, professional qualifications, work experience, publications and scientific activities, professional networks, programs and activities in which you participated.
In the course of an application, Baobabooks may process further information, such as government issued identification number, tax status, bank account details, details of any known disability/workplace accessibility needs, background information, travel and expenses, performance management, emergency contact details, compensation, hours of work, holidays and benefits related information.
STUDENTS AND CHILDREN UNDER 13
Baobabooks prioritizes the privacy of its students and have committed to support and comply with, and has signed, the Student Privacy Pledge. The Future of Privacy Forum (FPF) and The Software & Information Industry Association (SIIA) introduced a Student Privacy Pledge to safeguard student privacy regarding the collection, maintenance, and use of student personal information. The commitments are intended to concisely detail existing U.S. federal law and regulatory guidance regarding the collection and handling of student data, and to encourage service providers to more clearly articulate these practices.
In case that the Service is used by individuals under the age of 13, Baobabooks will comply with the Children’s Online Privacy Protection Act (COPPA).
We do not knowingly collect personal information from children under the age of 13 without prior consent of their parent or legal guardian. In order to become a Member, a child under 13 must provide a nickname, password and parent or legal guardian email address. We use that parent or legal guardian email address to request consent from the parent or legal guardian before allowing the child to register, in accordance with the requirements set forth in the Children’s Online Privacy Protection Act (“COPPA”). If we do not receive consent or if we do not receive a response, we delete the child’s and parent’s or legal guardian’s information.
CHANGES TO THIS PRIVACY STATEMENT
Baobabooks reserves the right to amend this Privacy Statement from time to time to reflect technological advancements, legal and regulatory changes, and Baobabooks’s business practices, subject to applicable laws. If Baobabooks changes its privacy practices, an updated version of this Privacy Notice will reflect those changes by posting any revisions on Website Privacy Notice with the respective update date listed on the bottom of this Statement. All changes to this Statement shall become fully effective thirty days (30) after the update date posted below. We therefore encourage you to view any amendments when you visit our Website from time to time to stay informed of how we are using your personal information.
CONTACT US
If you have questions about this Privacy Statement, or to obtain more information about Baobabooks’s privacy practices, please contact our Privacy Office, by email at [email protected]
