ETHOS Privacy Policy

ETHOS Language School (“ETHOS”, “we”, “us”) is committed to protecting your privacy. We do not sell or rent your personal data. We only disclose it to service providers acting on our instructions, or when required by law.

---

1) Who we are & how to contact us

ETHOS Language School
C.C. Regis Bldg., Corner Cebu South Road & Eucalyptus St., Basak San Nicolas, 6000 Cebu City, Philippines

Data Protection Officer (DPO): BARRY D. MURRELL
Email: dpo@ethos.ph

2) Personal data we collect

Depending on how you interact with us (website inquiry, enrollment, support), we may collect:

• Identity & contact: full name, sex, date of birth (for age verification/placement), address, email, phone.
• Program details: course preferences, schedule, housing option, payment status (amounts/dates—no card numbers stored by ETHOS).
• Technical: basic analytics and cookies set by our providers (see Cookies).

Note: Date of birth reveals age and is treated as sensitive personal information under Philippine law. Access is strictly limited.

3) Why we process your data

• Enrollment & service delivery: create quotations, issue invoices, assign teachers, schedule classes, provide housing, student support.
• Compliance: issue official receipts, maintain tax/corporate records, immigration assistance (e.g., SSP/visa processing at your request).
• Safety & school operations: enforce policies (e.g., conduct rules, curfews), handle incidents.
• Communication: respond to inquiries, send essential service messages.

4) Lawful basis

We process personal information under the Data Privacy Act of 2012 (RA 10173) and its IRR, including:

• Contract necessity (to provide the services you request).
• Consent (e.g., optional services or where required for sensitive personal information).
• Legal obligations (e.g., tax, official receipts, immigration requirements).
• Legitimate interests (e.g., basic analytics, fraud/security), balanced against your rights.

5) Where we store data & who sees it

• ETHOS systems (primary records). Core student records are stored on ETHOS-owned computers in our Cebu office, protected by firewalls, encryption, access controls, and backups.
• Service providers (limited, purpose-bound). We use reputable vendors for specific functions:
  • Form submission: Jotform (transmits your inquiry to us and stores a copy briefly—see Retention).
  • Web analytics: StatCounter (basic traffic metrics; uses cookies).
  • Website translation widget: Google Translate (optional; uses a cookie to remember your language choice).
  These providers act as processors on our behalf and may host data on servers outside the Philippines. We require them to protect your data and use it only as instructed by ETHOS.

We do not sell or rent your personal data. We disclose data outside ETHOS only to our service providers as above, to comply with law, or to protect vital interests.

6) International transfers

If our service providers store or process your data outside the Philippines, we take steps consistent with the Data Privacy Act to ensure a comparable level of protection (e.g., contractual safeguards, provider due diligence).

7) How long we keep your data

• Student records: generally kept for 2 years after your last interaction with ETHOS, then securely deleted, unless we must keep them longer for legal reasons.
• Financial records (e.g., official receipts): retained for as long as required by Philippine tax/corporate laws (currently up to ten years).
• Jotform submissions: we export inquiries into ETHOS systems and aim to remove the copy from Jotform within 30 days of receipt.

8) Security

We apply organizational, physical, and technical measures appropriate to the sensitivity of the data, including role-based access, encryption in transit and at rest (where applicable), authenticated backups, and regular reviews.

9) Your privacy rights

Under the Data Privacy Act, you have the rights to be informed, to object (where applicable), and to request access, correction, or erasure/blocking of your personal data, as well as to lodge a complaint with the National Privacy Commission.

To exercise your rights, email dpo@ethos.ph. We may ask for information to verify your identity. We endeavor to respond within 30 working days where applicable.

10) Children & minors

For students under 18, we obtain consent from a parent or legal guardian. We limit access to student records and treat date of birth/age as sensitive information.

11) Cookies & similar technologies

• Google Translate: sets a cookie (googtrans) to remember your selected language across pages.
• StatCounter: uses cookies to provide basic website analytics (e.g., page views). It may process IP addresses and browser data.

You can control cookies through your browser settings. If you block cookies, some optional features (like remembering your translation choice) may not work.

12) Changes to this policy

We may update this policy to reflect changes in our services or legal requirements. Significant changes will be posted on this page with a new “Last updated” date.

Last updated: 2025-08-30

Translation note: If this policy is translated, the English version governs in case of conflict.

---

Need more information?

← Back