Within the scope of the website hosted at www.redbridgeschool.com (“Site”) including the provision of information about their services and communications made available, RDBRDG School, Lda. (“Redbridge School”), with the corporate taxpayer number 510 566 316, with its registered office at Avenida da Liberdade, no. 240, 5th floor, 1250 Lisboa, may require the User to provide personal data, that means any information that allows Redbridge School to identified and contact the User (“Personal Data”).

The Personal Data collected and processed consists of information regarding the name, address, profession, marital status, nationality, date of birth, country of birth, mobile number, email address, academic information, taxpayer number, ID number or passport number and other personal information provided by the User.

Redbridge School also collects and processes information about the characteristics of the user’s hardware device and browser/software features, as well as information about the pages visited by the User within the Site. This information may include browser type, domain name, access times and links by which the User has accessed the Site (“Usability Information”). We only use this information to improve the quality of the user’s visit to our Site.

Usability Information and Personal Data are designated in this Privacy Policy by “User Data”.

Redbridge School may collect data directly (i.e., directly from the User) or indirectly (i.e., by partners or third parties). Such collection may be done through the following channels:

• Direct collection: in person, by telephone, via e-mail and through the site;
• Indirect collection: through partners or group companies and official entities.

The User Data collected by Redbridge School is not shared with third parties without the User’s consent, except in the situations mentioned in the following paragraph. However, in the event of the User contracting services with Redbridge School that are provided by other entities responsible for the processing of personal data, User Data may be consulted or accessed by such entities, to the extent that it is necessary for the provision of such services.

Redbridge School, in the applicable legal terms, may transmit or communicate the User Data to other entities in the event of such transmission or communication are necessary for the implementation of the contract established between the User and Redbridge School or to take steps to entering into a contract procedures at the request of the User, if necessary for the fulfillment of a legal obligation to which Redbridge School is subject or, if it is required, to obtain them in the legitimate interests of Redbridge School or of a third party.

3.1 PROCESSORS

As part of the processing of User Data, Redbridge School uses or may have recourse to third parties, subcontracted by it, for, on behalf of Redbridge School, and in accordance with the instructions given by Redbridge School, under the law and this Privacy Policy.

These Processors may not transmit the User Data to other entities without Redbridge School have given prior written authorization to do so, and are also prevented from contracting other entities without Redbridge School prior approval.

Redbridge School undertakes to only subcontract to entities that offer the maximum security in the implementation of the appropriate technical and organizational measures to guarantee the defense of the User’s rights. All entities sub-contracted by Redbridge School shall be bound by the means of a written agreement which covers: the object and duration of the processing, the nature, and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties provided by Article 28 of General Data Protection Regulation.

3.2 OTHER RECIPIENTS

Redbridge School can further communicate to other third parties not qualified as processors pursuant to Article 4 (8) of General Data Protection Regulation. These entities are subject to confidentiality and may not transmit the User’s Data to other entities without prior written authorization, ensuring that they process personal data following the obligations of General Data Protection Regulation.

Redbridge School undertakes to ensure the principles relating to the processing of personal data, such as:

• Subject to a lawfully, fairly and in a transparent manner in relation to the User;
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

Processing of personal data carried out by Redbridge School is lawful only if and to the extent that at least one of following applies:

• The User has given consent to the processing of his or her personal data for one or more specific purposes;
• The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• The processing is necessary for compliance with a legal obligation to which Redbridge School is subject;
• The processing is necessary in order to protect the vital interests of the User or of another natural person;
• The processing is necessary for the purposes of the legitimate interests pursued by Redbridge School or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data).

Redbridge School undertakes to ensure that User Data is only processed under the conditions cited above and respecting the principles mentioned.

When processing of the User Data is based on the User’s consent, the User has the right to withdraw his/her consent at any time. Such withdrawal of the consent does not compromise the lawfulness of processing carried out by Redbridge School, based on the consent previously given by the User.

The retention period, which the data is stored, differs according to the purpose for which the information is being processed. There are legal requirements that require the data to be preserved for a minimum period of time. Thus, and where there is no specific legal obligation, the data will be stored and kept only for the minimum period necessary for the purposes that lead to their collection or subsequent processing, which at the end of the period will be deleted.

Redbridge School processes the User Data for the following purposes:

• Recruitment and selection, through the disclosure of job opportunities;
• Admission process;
• Scheduling visits to Redbridge School;
• Ensuring that the Site meets the User’s needs;
• Improvement of search capabilities and functionalities of the site and obtaining associated or statistical information regarding to the user’s profile (analysis of consumption profiles).

To guarantee the security of the User Data and the maximum confidentiality, Redbridge School follows internal security and confidentiality policies and procedures, which are duly updated as required, as well as the terms and conditions legally set out.

Based in the nature, scope, context, and purpose of data processing, as well as the risks arising from the processing of the rights and freedoms of the User, Redbridge School undertakes to apply, when defining the method and timing of handling the data, the appropriate technical and organizational measures necessary for the protection of User Data and compliance with legal requirements.

It also undertakes to ensure that, by default, only data that are necessary for each specific purpose are processed and that such data are not made available without human intervention to an indeterminate number of people.

Redbridge School adopts the following security measures:

• Regular audits to identify the effectiveness of the technical and organizational measures implemented;
• Awareness and training of personnel involved in data processing operations;
• The pseudonymisation and encryption of personal data;
• Mechanisms capable of ensuring the to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• Mechanisms capable to ensure the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

User Data collected by Redbridge School is not made available to third parties established outside the European Union. If, in the future, such a transfer takes place for the reasons mentioned above, Redbridge School undertakes to ensure that the transfer complies with the applicable legal provisions regarding the country’s adequacy decision concerning data protection and the requirements applicable to such transfers.

The User can exercise the right of access, rectification, erasure, restriction of processing, object and data portability through the e-mail [email protected].

Redbridge School will respond in writing (including by electronic means) to the User’s request within a maximum period of one month from the receipt of the request, except in particularly complex cases, for which this period may be extended up to two months.

Where requests are manifestly unfounded or excessive, in particular, because of their repetitive character, Redbridge School may charge a reasonable fee based on administrative costs, or refuse to act on the request.

The User can always submit a complaint to the Portuguese Supervisory Authority – Comissão Nacional de Proteção de Dados, located at Av. D. Carlos I, 134 – 1.º 1200-651 Lisbon, by phone +351 213 928 400 and e-mail address: [email protected].

When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Redbridge School shall communicate the personal data breach to the User, not later than 72 hours after having become aware of it.

In legal terms, the communication to the User shall not be required if any of the following conditions are met:

• Redbridge School has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular, those that render the personal data unintelligible to any person who is not authorized to access it, such as encryption;
• Redbridge School has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialize; or
• It would involve a disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the User is informed in an equally effective manner.

Redbridge School reserves the right to make changes to this Privacy Policy at any time. In the case of adjustment to the Privacy Policy, the date of the most recent change will be available at the top of this page. If the change is substantial, a notice will be placed on the Site.

The Privacy Policy, as well as the collection, processing or transmission of User Data are all governed by the provisions of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, and Data Protection Portuguese Act (Law no. 58/2019, 8^th august).

Any litigation arising from the validity, interpretation or implementation of the Privacy Policy, or related to the collection, processing or transmission of User Data, must be submitted exclusively to the jurisdiction of the courts of Redbridge School, without prejudice to mandatory legal rules.