Privacy Policy and Processing of Personal Data

The purpose of this document is to inform users of the Websitehttps://liceopanamericano.edu.ec/(hereinafter, the "Site" or the "Website") about the privacy policy and processing of personal data shared on this Site. This Site is the property of LICEO PANAMERICANO LPSA S.A. (hereinafter, "LICEO PANAMERICANO LPSA"), educational supporter of Colegio Liceo Panamericano Samborondón.

1. Privacy

LICEO PANAMERICANO LPSA is committed to protecting the personal data of Users, recognizing the importance of being able to make informed decisions regarding the handling of their information. This Policy details the procedures for the collection, use, storage, disclosure and protection of Users' personal data.

The User is responsible for ensuring that the data provided is true, accurate, current and authentic. In no case will LICEO PANAMERICANO LPSA assume responsibility for the information provided by the User. The institution reserves the right to request additional information to verify the accuracy of the data, if necessary.

The User expressly authorizes LICEO PANAMERICANO LPSA to validate the information provided through consultations with public entities, ensuring that all information obtained will be treated confidentially.

The User may, at any time, request the updating of their personal data or exercise the rights provided for in the Organic Law on the Protection of Personal Data. To do so, you must communicate through the email indicated in this policy.

2. Responsible for the Processing of Personal Data

Name of the Data Controller LICEO PANAMERICANO LPSA RUC: 0993192570001

Address: Km 3.5 via Samborondón, Samborondón 092302

Email:dataprivacysa@ispschools.com

3. Definitions

  • LOPDP: Organic Law on the Protection of Personal Data published in the Official Gazette Supplement 459 of May 26, 2021, which aims to guarantee the exercise of the right to personal data protection, which includes access to and decision on information and data of this nature, as well as its corresponding protection.
  • Responsible of Treatment: Natural or legal person, public or private, public authority, or other body, which alone or jointly with others decides on the purpose and processing of personal data.
  • Owner/ User: Any identifiable natural person whose personal data are
  • Treatment Activity: Any operation or set of operations that is carried out on Personal Data or data sets
  • Impact on data protection: violation, violation of personal data that leads to the accidental or unlawful destruction, loss or alteration, unauthorized communication or access to personal data transmitted, stored or processed in another ǫue that affects the confidentiality, availability or integrity of personal data.
  • Manager of the Treatment: Natural or legal person in charge of processing personal data in the name and on behalf of LICEO PANAMERICANO LPSA
  • Personal Data: Data by which a person can be directly or indirectly identified. For example, names, identity number, email, phone number, health data, among others,
  • Sensitive Data: are those related to ethnicity, gender identity, cultural identity, religion, ideology, political affiliation, judicial past, migratory status, sexual orientation, health, biometric data, genetic data and those whose improper treatment may give rise to discrimination, violate or may violate fundamental rights and freedoms.

4. Collection and Processing of Personal Data

The Site may collect data from Users in an automated manner (cookies, activity logs) or voluntarily (contact forms, logs).

a. Use of cookies

LICEO PANAMERICANO LPSA collects data from users who visit the Site through logs of activity and browsing patterns, without the need to identify them personally. The use of the Site may involve cookies, which store small amounts of information in the User's browser to improve their browsing experience. Only if the User voluntarily provides his/her information, it may be stored in a cookie. Users can disable cookies at any time from their browser settings, although this may affect the functionality of the Site.

b. Forms

LICEO PANAMERICANO LPSA collects general information, such as names, surnames, identity card numbers, as well as contact information, including addresses, telephone numbers and emails. In admission processes, identifying information of the minor may be collected, such as names, date of birth and grade to which they wish to apply. This information is obtained through web forms and other service mechanisms enabled on the Website.

Although Users are not required to provide their personal data to access the Website, such data may be required to register or communicate with LICEO PANAMERICANO LPSA. In these cases, the delivery of data is done in a free, specific, informed and unambiguous manner. The information collected will be used exclusively for the purposes set forth in this Policy, strictly complying with the limitations provided by law.

5. Purposes of processing

LICEO PANAMERICANO LPSA will request only the personal data necessary and appropriate for the purposes described in this section. For the processing of such data, the User must grant his/her unequivocal consent, which may be expressed through electronic means, such as clicking on buttons labeled as "accept", "send", "save" or "continue", provided that clear options are offered to cancel or return.

By providing their personal data, Users consent to their incorporation into a database managed by LICEO PANAMERICANO LPSA or by a designated processor, for processing purposes in accordance with the detailed purposes.

LICEO PANAMERICANO LPSA will process the data for the following purposes:

  • Attention to queries submitted by the
  • General requirements management: Process and follow up on requests, requests, or requirements made through the Site's channels
  • General Communication: To provide Users with relevant information about services, activities, news or updates related to LICEO PANAMERICANO LPSA
  • Request for an appointment for admission: receive applications and validate availability for
  • Continuous improvement and optimization of the Website: Analyze the interactions and requirements of Users to improve the experience, functionality and services

For those treatments that require the User's consent, various mechanisms will be implemented to have such express authorization.

6. International Communications or Transfers to Third Parties

LICEO PANAMERICANO LPSA will share information with service providers or institutions with whom LICEO PANAMERICANO LPSA has a collaborative or alliance relationship, which contribute to improving or facilitating operations. LICEO PANAMERICANO LPSA will ensure that the standards of protection are complied with, through the signing of contracts or agreements whose purpose is the privacy and confidentiality of the owner's personal data.

The Owner will have the right to accept or reject that LICEO PANAMERICANO LPSA discloses or shares personal information with third parties that are service providers or institutions that are allies, affiliated or related to LICEO PANAMERICANO LPSA

LICEO PANAMERICANO LPSA will cooperate with the authorities with whom it must act, to guarantee compliance with the Law. LICEO PANAMERICANO LPSA will collaborate with the competent authorities in order to safeguard the integrity and security of the community and that of its Data Subjects. However, by virtue of court orders, when permitted by law, or in the context of the prevention of money laundering and terrorist financing, LICEO PANAMERICANO LPSA may disclose personal information without the consent of the owner.

LICEO PANAMERICANO LPSA, with the authorization of the owner, will be authorized to transfer all or part of personal data to any of the companies controlled, controlling and/or linked to LICEO PANAMERICANO LPSA, under any title and at the time, form and conditions that it deems appropriate. LICEO PANAMERICANO LPSA will guarantee the privacy and security of information at all times.

7. Data of Minors

LICEO PANAMERICANO LPSA will only process personal data of children and adolescents when necessary for the provision of the care required by the User and, if legally required, with the explicit consent of their representatives. Likewise, LICEO PANAMERICANO LPSA in the execution of its work will attend to the principle of the best interests of the minor in accordance with the applicable regulations that regulate the processing of data of minors.

During the use of the Website, information may be requested from minors for the purpose of managing admission processes. In these cases, only identifying data will be collected, such as names, date of birth and grade to which the minor is applying. LICEO PANAMERICANO LPSA will guarantee a diligent handling of this information, strictly complying with the duties of reserve and confidentiality.

In accordance with current regulations, adolescents over fifteen (15) years of age and under eighteen (18) years of age may directly exercise their rights before LICEO PANAMERICANO LPSA on the basis of their data, depending on who manages such personal data, or before the Personal Data Protection Authority.

8. Conservation

The personal information collected will be retained only for the time necessary to fulfill the original purposes of its collection and to determine the possible responsibilities that may arise from the purpose, unless a legal provision requires its retention for a longer period.

G. Procedure for the Exercise of the Rights of the Owner

The Owners of the personal data may at any time request from the Data Controller the information that is kept about them:

  • Right of access: You will be able to consult your personal data that is being processed by LICEO PANAMERICANO LPSA.

  • Right to rectification and updating. – The owner has the right to obtain from the data controller the rectification and updating of their inaccurate or incomplete personal data.

  • Right of deletion.- The owner has the right to have the data controller delete his/her personal data, when:

    1) The processing does not comply with the principles established in the law;
    2) The processing is not necessary or relevant for the fulfillment of the purpose;
    3) The personal data have fulfilled the purpose for which they were collected or processed;
    4) The period of storage of personal data has expired;
    5) The processing affects fundamental rights or individual freedoms; (6) Revokes the consent given or indicates that it has not been given for one or more specific purposes, without the need for any justification; or
    7) There is a legal obligation.

  • Right to object. The owner has the right to oppose or refuse the processing of his/her personal data, in the following cases:
    1) The fundamental rights and freedoms of third parties are not affected, the law allows it and it is not public information, of public interest or whose treatment is ordered by law.
    2) The processing of personal data is for the purpose of direct marketing; the data subject shall have the right to object at any time to the processing of personal data concerning him/her, including profiling; in which case the personal data will no longer be processed for such purposes.
    3) When your consent to the processing is not necessary as a result of the concurrence of a legitimate interest, and it is justified in a specific personal situation of the owner, provided that a law does not provide otherwise.

  • Right to portability. – The owner has the right to receive from the data controller, his/her personal data in a compatible, updated, structured, common, interoperable and machine-readable format, preserving its characteristics; or to transmit them to other responsible parties. The Data Controller may request that the Data Controller transfer or communicate his/her personal data to another Data Controller as soon as technically possible and without the Data Controller being able to claim impediment of any order in order to slow down the access, transmission or reuse of data by the Data Controller or another Data Controller. After the data transfer is completed, the person responsible for doing so will proceed to delete it, unless the owner orders its conservation.

  • Right to suspension of treatment. – The owner will have the right to obtain from the data controller the suspension of the processing of the data, when any of the following conditions are met:
    1) When the owner contests the accuracy of the personal data, while the data controller verifies the accuracy of the same. 2) The processing is unlawful and the data subject objects to the erasure of the personal data and instead requests the restriction of its use;
    3) The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the establishment, exercise or defence of claims;
    4) When the data subject has objected to the processing, while it is verified whether the legitimate reasons of the controller prevail over those of the data subject. When the owner contests the accuracy of the personal data, while the data controller verifies the accuracy of the same, it must be placed in the database, where the contested information is recorded, that it has been the subject of disagreement by the owner.

  • The right not to be subject to a decision based solely or partially on automated valuations. – The holder has the right not to be subjected to a decision based solely or in part on valuations that are the product of automated processes, including profiling, that produce legal effects on him or that infringe his fundamental rights and freedoms.

The holder may do any of the actions described above, through the following email:dataprivacysa@ispschools.com

However, the deletion of the information and the revocation will not proceed if there is a legal or contractual obligation to retain the database.

All requests or requests for the exercise of personal data rights must be addressed to the area in charge of data protection of LICEO PANAMERICANO LPSA with the subject name – Personal Data Protection.

The owner may exercise his/her rights over his/her personal data at any time, and LICEO PANAMERICANO LPSA must respond to the query within a maximum period of fifteen (15) days from the date of receipt of the same. LICEO PANAMERICANO LPSA may request clarification or expansion of the information from the holder, contained in the application, within five (5) days of receipt of the request. Consequently, the holder will have a period of ten (10) days, from the day following the day on which the notification was received, to clarify or complete.

In the event that the holder clarifies or completes within the term granted, the request will be attended by LICEO PANAMERICANO LPSA, within the corresponding period. The requirement that is not met may be archived by duly substantiated notification to the holder. This does not prevent the submission of a new application by the holder.

The Data Controllers may at any time rectify, know and update their data, among others, in the face of partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is expressly prohibited or has not been authorized. Likewise, the Owner or its representative may request the correction or updating of its data.

The communication will be processed by means of a written request that includes the following information:

  1. Identification of the Owner or representative (Full names and surnames, identity card or passport number and home or email address for notifications) The data of the Owner or representative will also be included.
  2. Clear and precise description of personal data with respect to which you seek to exercise any of the rights and any element that facilitates the location of the personal data in the institution, through which you have
  • Clear and precise explanation of your request.

    iv. Identification of the right(s) you wish to exercise
    v. Include documents that prove identity and legal representation.

10. Limits of Liability

LICEO PANAMERICANO LPSA adopts reasonable technical, administrative, and organizational measures to protect the personal data it collects, stores, and processes. However, you do not accept any liability for any damage, loss or injury that may result from unauthorised access, use, disclosure or alteration of personal data that is beyond our reasonable control.

In this sense, LICEO PANAMERICANO LPSA will not be responsible for acts, omissions or privacy policies of third parties that, as a result of links, integrations or services provided through our platform, process personal data on their own terms. Likewise, it does not assume responsibility for the negligent or improper use of our services by users, including the voluntary disclosure of credentials or sensitive information.

While robust technologies and procedures are in place to prevent unauthorized access, there can be no guarantee that the infrastructure will be invulnerable to cyberattacks, such as hacking, malware, or phishing. In the event of incidents of this nature, LICEO PANAMERICANO LPSA will act promptly to mitigate their effects, but will not be responsible for any damages that these may cause as long as it has complied with its legal obligations of data protection.

Finally, LICEO PANAMERICANO LPSA is not responsible for non-compliance derived from force majeure events, such as natural disasters, interruptions in telecommunications services or measures imposed by government authorities. Nor does it guarantee the accuracy, completeness or timeliness of the data provided by users, who are responsible for ensuring that the information provided is correct and up-to-date at all times.

The User acknowledges that the use of the Site is at his/her sole risk.

11. Disclaimer

The User agrees to defend, indemnify and hold harmless LICEO PANAMERICANO LPSA, as well as its employees, agents and affiliates, from any lawsuit, conviction, fine, claim, sanction, seizure or precautionary measure that arises as a result of:

  1. Breaches by the User with respect to applicable intellectual and industrial property laws, or any other legislation related to property rights;
  2. Failure to comply with this policy or any other policy or regulation of LICEO PANAMERICANO LPSA incorporated in this document, as well as the violation of any current legislation related to these issues or the rights of third parties, especially with regard to data processing

The delivery of incorrect, inaccurate, false or outdated information provided by the data subjects or by third parties, including the possible consequences derived from such inconsistencies in the treatment of the information. The use of our services implies acceptance of the risks inherent in the transmission of data over communication networks. Despite our security measures, we cannot guarantee absolute protection against unauthorised access or system failures that may compromise the confidentiality, integrity or availability of personal data. In the event of incidents of this nature, our liability will be limited to compliance with our legal obligations, including reporting incidents and taking corrective action.

Likewise, LICEO PANAMERICANO LPSA will not be responsible for any harm or damage derived from decisions or actions taken by the user based on the information provided in this policy or on our website, nor for the consequences of the use that third parties may make of personal data when this use has not been authorized or supervised by us.

12. Governing Law

This policy conditions shall be interpreted and enforced in accordance with the laws of the Republic of Ecuador. Any conflict will be resolved before the competent courts of Ecuador. With special relevance, this policy will be subject to the following regulations:

  • Organic Law on the Protection of Personal Data (LOPDP).
  • General Data Protection Regulation (RLOPDP).
  • Law on Electronic Commerce, Signatures and Messages of
  • Other applicable data protection regulations

13. Validity

This policy is effective upon posting on the Site and will remain in effect indefinitely.

LICEO PANAMERICANO LPSA reserves the right to modify this document at any time. Changes will be effective upon posting on the Site, without the need for specific notice. The User shall be responsible for periodically reviewing this document for updates.

Date of Publication: January 23, 2025

Date of the Last Update: January 23, 2025