The Feydey International S.A., owner of the trade mark GSE® (Global Secondary Education) and program GSE® Academy Privacy Policy provides you information on what data we collect, what we use it for and what are your rights.

FEYDEY International S.A. is Swiss registered company CHE-278.360.520, with office at 35 Route de Belvedere, 1854 Leysin, Switzerland

We provide educational services in-person and online.

The FEYDEY International Privacy Policy applies to all FEYDEY International or FEYDEY Online Academy or GSE® Academy related websites www.gse-academy.com, www.feydey.com FEYDEY International follows the following GDPR rules in order to protect your privacy:
- we do not collect more information than is necessary
- we do not use your data for purposes other than those specified
- we do not keep your data if it is no longer needed
- we do not spread/sell your data to third parties
- we collect data on the basis of "legitimate interest" only

Also, FEYDEY International complies with the Family Educational Rights & Privacy Act (FERPA) to protect all student information released by district / school for educational purposes.

Children under the age of 13 years need enhanced safeguards and privacy protection, as set forth in the Children's Online Privacy Protection Act (COPPA). COPPA specifies the consent of parents/guardians for collection or use of any personal information of children under the age of 13. FEYDEY complies with COPPA and receives personal information about children who are under the age of 13 strictly from their parents or guardians at the time those children are enrolled into a school using a FEYDEY School Program. The only information received directly from children are the test answers, emails, and class discussions in the LMS as part of their education in a FEYDEY School Program.

As of January 1, 2016, the Student Online Personal Information Protection Act (SOPIPA) becomes effective in California. The law prohibits the sharing of student data and using that data for advertising. FEYDEY International complies with the law, and does not share information for non-educational purposes.

That anyone may read information provided through message boards, blogs, and chat rooms on our site. All information posted to a message board or chat room will be available to the other users of it, and is no longer private. This information is provided at your own risk, and though we may monitor the message, we cannot guarantee the security of such information.

To reduce unauthorized access and maintain effective data accuracy and use, we use SSL protocol on the accounts to protect any sensitive information, like credit card numbers.

That feydey.ch contains links to websites operated by other organizations and third-party service providers. The privacy policy set by FEYDEY does not apply to these third-party websites. Please take a few minutes to review the privacy policies of the third-party websites that you access.


WHAT IS THIS NOTICE?

In order to provide our Services, we may need to process Personal Data from time to time (that is information about someone who can be identified from the data). This Personal Data may be about you or other people. This notice explains how we will use the Personal Data we hold.

As part of our Services we may transfer Personal Data to other people. We've set out a list of who we might transfer Personal Data to at paragraph 7. This notice only deals with our use of Personal Data. Recipients not bound by this privacy notice.

We might need to change this privacy notice from time to time. If we do, we let you know. So please do keep an eye on our notice before giving us any Personal Data.

All of the defined terms in this notice are explained in paragraph 14 below. If you have any questions about this notice, feel free to send us an email to info@feydey.com


WHO DOES FEYDEY INTERNATIONAL HOLD PERSONAL DATA ABOUT?

We hold Personal Data about the following groups of people (Data Subjects):
Data Subjects: students, parents, guardians, teachers, instructors, partners, staff, agents, representatives.


ARE YOU A CONTROLLER OR A PROCESSOR?

FEYDEY International processes Personal Data both as Processor and as Controller as defined by the GDPR. For some activities FEYDEY International may rely on external processors (as described under "Information security").

You can contact us at any time to request:

• Access the Personal Data Village Camps has about you
• Correct any Personal Data Village Camps has about you
• Delete any Personal Data Village Camps has about you

FEYDEY International S.A.
35 Route de Belvedere
1854 Leysin
Switzerland
+41 (0) 24 477 6000

We are a Controller in respect of the following data: (Name, Last name, DOB, place of birth, address, interest, skills, credentials and knowledge. This means we make decisions about what data to collect (in respect of those groups of Data Subjects) and how to use it.

We are a Processor in respect of payment information, credit cards and bank accounts. This means that we are processing that data on behalf of (and in accordance with the instructions of) our Client.


WHERE DO YOU COLLECT PERSONAL DATA FROM?

We might collect Personal Data in the following ways:

Website usage
You can visit FEYDEY International website without telling us who you are or revealing any personal information about yourself. The only information we gather during general browsing aside from the IP address is mostly anonymous traffic data including browser information, device information, and language.

Collection of personal data
While you can use our website without giving out your personal information, once you sign up into the FEYDEY International website, request information, provide feedback, or subscribe to an electronic mailing list, you will be asked to provide personal information. The information you provide (personal information such as your name, email address, organization, child names, ages, etc.) will be processed and stored so that it is possible for us to contact and respond to your request, and/or allow you access to our services. The information is collected only with your knowledge and permission and is kept in various FEYDEY International databases and mailing lists.

Online bookings
If you book something using the FEYDEY International website, you may be asked to provide your credit card details. These details are transferred to and handled by our online payment service, hosted outside FEYDEY International. Credit card information is not retained by FEYDEY International at any stage of any transaction.

Information from other sources
FEYDEY International might receive information about you from other sources (e.g., face-to-face meeting, introduction from third-parties, events participation, etc.). In addition, you may provide us with your personal data by corresponding with us by mail, live-chat, phone, videoconference or otherwise. Before the information is added into the various FEYDEY International databases and mailing lists you are requested to give your explicit consent.

Job applications
Where an application is made by an individual for employment by FEYDEY International the data will be stored in an electronic database, and this information will be retained according to the data retention policy.

Photography and Video
FEYDEY International reserves the right to use any photographs, art work, other content, etc., of its customers on its website and in any of its future publications, as stipulated in the Terms & Conditions.

Special Categories of Personal Data
It is likely that some of the Personal Data which we collect and store about [Subscribers] may include Special Categories of Personal Data. Special Categories of Personal Data includes details about an individual's race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

Aggregated Data
We may also collect, use and share Aggregated Data such as statistical or demographic data which we collect from interactions with [Subscribers]. Aggregated Data may be derived from Personal Data but since it cannot be used to identify an individual, it is not Personal Data.

Types and sources of Data Collected
Contact and Identity Data, Transaction Data, Preferences, Education place, Job Roles and Business Data, Traffic Data, Usage Data, Technical Data, Reports, Transcripts


HOW DOES FEYDEY INTERNATIONAL USE THE COLLECTED INFORMATION?
FEYDEY International uses Google Analytics and Browser Cookies to improve our service, user experience and analyze how the website is used. The information gathered anonymously during general browsing is used to provide an overview of how people are accessing and using the FEYDEY International website and Village Camps does not use it for any additional purpose (e.g., profiling, marketing, etc.).

FEYDEY International uses your personal data to contact you:

• For our own internal records
• In response to a request or booking from your part
• To inform you by sending a newsletter, documents or any other relevant resource
• To invite you to be involved in FEYDEY International in-person and online classes and activities.
• To update you with reports and feedbacks
• To inform you periodically about changes in FEYDEY International offers

FEYDEY International hold and process [Subscriber's] Data as a Controller, which means we must have a 'lawful basis' for doing so. We have set out how we use [Subscribers] Data along with our lawful basis in the table below.

Anywhere we are relying on legitimate interest we believe that such processing is necessary for the purposes of our legitimate interest, which in this case is to function as a business. We consider such use goes no further than the Data Subject would reasonable expect; is likely to align with the Data Subject's interests (by enabling us to provide a sustainable business model) and is unlikely to be detrimental to the fundamental rights and freedoms of the Data Subject.

To register subscriber, to provide additional information, for marketing, for Administration and Dispute Resolution, to deliver the educational service, FEYDEY International collects following type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Traffic Data under lawful basses: Necessary for the performance of the contract for the provision of our services or taking steps necessary to enter into a contract, Legitimate Interest, Consent.

INFORMATION SECURITY

FEYDEY International cares to ensure the security of your personal data: we do not sell or share any personal data to any third party except when it's necessary to complete FEYDEY International functions.

Personal data is not used in ways other than as set forth in this privacy policy or in ways to which you have explicitly consented.

FEYDEY International staff who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of official business matters, including personal data.

FEYDEY International websites are secure, encrypted, and professionally managed to the highest standards. All necessary measures are taken to protect personal data against theft or compromise according to industry practices.

The FEYDEY International website provides links to other FEYDEY International websites and features plug-ins for FEYDEY International social media pages (i.e., Facebook, Instagram, Twitter, etc.). Once clicked upon, you will be taken to different websites with their own specific privacy policies you are recommended to consult. FEYDEY International is not responsible for the privacy practices or the content of such sites.


INFORMATION SHARING AND DISCLOSURE

We do not disclose your personal data except in the limited circumstances described here:

• User Consent or Direction: we may share or disclose your information upon your request/consent;
• Legal process or enforceable governmental request: we may share or disclose your information to comply with a law, regulation, legal process, or governmental request;
• We may share or disclose your information to detect, prevent, or otherwise address fraud, security or technical issues;
• Non-personal, anonymized, aggregated data: we may share or disclose this information as part of a project, research, collaborative, etc. that serves the Village Camps business.

FEYDEY INTERNATIONAL DISCLOSE PERSONAL DATA TO:

FEYDEY International disclose personal (identity and contact) data only to Village Camps and Grade Results at the reason of joint service delivery.
If you have any questions about who your data might be transferred to please send us an email at info@feydey.com


WHAT SECURITY PROCEDURES DO YOU HAVE IN PLACE?

It is our policy to ensure that all Personal Data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.


WHAT RIGHTS DOES A DATA SUBJECT HAVE ABOUT THE PERSONAL DATA FEYDEY INTERNATIONAL COLLECT AND HOLD?
Data Subjects have the following rights in respect of Personal Data relating to them which can be enforced against whoever is the Controller.

a. Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it's used.

b. Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients to whom the personal data has/will be disclosed;
- for how long it will be stored; and
- if data wasn't collected directly from the Data Subject, information about the source.

c. Right of rectification: the right to require the Controller to correct any Personal Data held about the Data Subject which is inaccurate or incomplete.

d. Right to be forgotten in certain circumstances, the right to have the Personal Data held about the Data Subject erased from the Controller's records. Right to restriction of processing: the right to request the Controller to restrict the processing carried out in respect of Personal Data relating to the Data Subject. You might want to do this, for instance, if you think the data held by the Controller is inaccurate and you would like to restrict processing the data has been reviewed and updated if necessary.

e. Right of portability: the right to have the Personal Data held by the Controller about the Data Subject transferred to another organization, to the extent it was provided in a structured, commonly used and machine-readable format.

f. Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose).

g. Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on the Data Subject.

h. If you want to avail of any of these rights, you should contact us immediately at info@feydey.com If we are not the Controller, we will need to transfer your request to the Controller – but we will only do so with your consent.

If you do contact us with a request, we will also need evidence that you are who you say you are to ensure compliance with data protection legislation.


INFORMATION CORRECTION & DELETION
Providing personal data on the FEYDEY International website is optional. You can choose not to provide personal data; this will allow you to browse and use the FEYDEY International website, but you will not be able to carry out certain actions (e.g., make a booking, access booking history, etc.).

If you are a registered user of the FEYDEY International website, and have a login, we provide you with tools and account settings to access the personal data you provided to us and associated with your account.

If you are not a registered user but FEYDEY International has your personal data, you can contact FEYDEY International and request an electronic version of all the personal data FEYDEY International has about you.

If you do not want to receive e-mail, or to be contacted by us in any way, all marketing emails sent by FEYDEY International contain a link to automatically un-subscribe. You can use this link, or you can also contact us to issue a request by using the Contact Form.

If at any point you wish for FEYDEY International to delete information about you, you can contact us via a similar link to issue a request for secure deletion, or you can also contact us using the Contact Form

Where a commercial transaction has taken place, such as a booking, or where other information has been supplied, such as applying for a job, FEYDEY International reserves the right to retain the information for any of accounting, legal, or safeguarding reasons.


WHO DO I COMPLAIN TO IF I'M NOT HAPPY WITH HOW YOU PROCESS PERSONAL DATA ABOUT ME?

If you have any questions or concerns about how we are using Personal Data about you, please contact our Data Protection Officer immediately at our registered address (see paragraph 1.1 above) or by email to info@feydey.com

If we are processing Personal Data about you on behalf of [Village Camps S.A.], we will need to pass your complaint to [Village Camps S.A.] – we will only do so with your consent.


DATA RETENTION

We retain personal data for as long as the user account is active or otherwise for a limited period of time as long as we need it to fulfil the purpose for which we have initially collected it, and where there is legitimate interest.


WHAT DO ALL OF THE DEFINED TERMS IN THIS PRIVACY NOTICE MEAN?

Throughout this notice you'll see a lot of defined terms (which you can recognize because they're capitalized). Where possible, we've tried to define them as we go, but we thought it might be useful to have a glossary at the end for you. Anywhere in this notice you see the following terms, they'll have the following meanings:

Controller is a legal term set out in the General Data Protection Regulation (GDPR), it means the party responsible for deciding what Personal Data to collect and how to use it;

Data Subject means the individual who can be identified from the Personal Data;

Personal Data means data which can be used to identify a living individual. This could be a name and address, or it could be a number of details which when taken together make it possible to work out who the information is about. It also includes information about the identifiable individual;

Processor is another legal term set out in the GDPR, it means the party who has agreed to process Personal Data on behalf of the Controller; and

Special Categories of Personal Data means details about an individual's race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.


CHANGES
FEYDEY International reserves the right to change this Privacy Policy and all changes will be available in the FEYDEY International website.


Last update December 20, 2020