LEGAL NOTICE AND PRIVACY POLICY

All interested parties are hereby informed that SCALA HIGHER EDUCATION S.C., a company identified with NIF/RFC. SHE1110145H4 and with address at Calzada de la Naranja No159, Fraccionamiento Industrial Alce Blanco, C.P. 53370 Naucalpan, Estado de Mexico, Piso 4, duly constituted (hereinafter "SCALA"). In accordance with the Federal Law on Protection of Personal Data, (hereinafter "Legislation"), is the owner of the website www.s4learning.com (hereinafter, the "Website").
This Privacy Policy (hereinafter, the "Privacy Policy") is intended to inform you how SCALA defines and uses your Information.
The access and use of the website by you implies your full acceptance of this Privacy Policy (available at www.s4learning.com). Any change will be informed and published in a timely manner on the indicated web page, owned by SCALA.

I. DEFINICIONES
For all purposes, the following terms will be applicable to this Policy:

● Consent of the interested party: Any free, specific, informed and unequivocal manifestation of will by which the interested party accepts, either by means of a declaration or a clear affirmative action, the processing of concerning personal data.
● Privacy Notice: Verbal or written communication generated by the individual in charge, addressed to the Owner for the treatment of personal data, through which they are informed about the existence of the information treatment policies that will be applicable, the form of access to such and the purposes of the treatment that is intended to give personal data.
● File: Any structured set of personal data, accessible according to certain criteria, whether centralized, decentralized or distributed functionally or geographically.
● Personal data: All information about an identified or identifiable individual (the interested party); an identifiable natural individual is any individual whose identity can be determined, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of the identity physical, physiological, genetic, psychic, economic, cultural or social of such individual.
● Public data: It is the data that is not semi-private, private or sensitive. Public data is considered, among others, as data related to the marital status of people, their profession or trade and their quality as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial decisions that are not subject to reservation.
● Sensitive data: Sensitive data is understood to be that which affects the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, union membership, social, human rights organizations or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.
● Individual in charge of the treatment: Individual or legal entity, public or private, who, by itself, performs the processing of personal data on behalf of the individual in charge of the treatment.
● Responsible for the treatment: Individual or legal entity, authority, service or other body that, solely or together with others, determines the purposes and means of the treatment. Based on the Law and criteria established by the Mexican State or the European Union.
● Owner: Individual who owns the personal data that is being processed.
● Transfer: The transfer of data takes place when the individual in charge and/or Individual in Charge of the processing of personal data, located in Mexico, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is within or out of the country.
● Transmission: Processing of personal data that implies the communication of the same within or outside the territory of the Mexican State when its purpose is to perform a treatment by the individual in charge on behalf of the individual in charge.
● Treatment: Any operation or set of operations conducted on personal data or sets of personal data, whether by automated procedures or not, such as collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of authorization of access, collation or interconnection, limitation, suppression or destruction.
● Content: These are the pages that make up the entire website, which contains information and services that SCALA makes available to Users. Such contains messages, texts, photographs, graphics, icons, logos, technology, links, textures, drawings, sound and/or image files, recordings, software, appearance, graphic design and source codes and, in general, any kind of material contained on the Website.
● Web: Technical word that describes the system for accessing information via the Internet, which is configured through pages made with HTML language or similar, and programming mechanisms such as java, javascript, PHP, or others. These pages designed and published under an Internet domain name are the result of the information that the owner makes available to Internet Users.
● Cookies: Technical means for "traceability" and monitoring of navigation on the Website. They are small text files that are written on the User's device. This method has privacy implications, so SCALA will provide timely and reliable notice of its use at the time they are implemented on the website, through a link called "Cookies Policy".

II. WHAT INFORMATION DO WE PROCESS ON THE WEBSITE?
While browsing throughout our website, you can provide us with data in several ways, including:
i) Data that you provide us when using the data forms on the Website or when you communicate with SCALA through means, such as email.
The data will be processed for the specified purpose mentioned in each form. In the event that you send us a message, SCALA will treat it in order to manage the communications that may be established, based on your request.
We can obtain your express consent in order to send you commercial communications through each data collection format, or through a request in an email message.
Likewise, if once consent has been granted, you no longer wish to receive commercial communications, you may revoke your authorization by sending an email to the following address: protecciondatos@s4learning.com. This same procedure must be conducted to exercise any of your rights under current legislation on data protection (access, rectification, deletion, limitation and portability).
ii) Data that the website collects automatically during your browsing, to which you give your consent in the terms specified in this Privacy Policy.
Like most commercial websites, our website uses a technology called "cookies" (small pieces of data that your browser stores on your terminal's hard drive) and web server logs to collect information about how cookies are used in our website.
For more information on how we use cookies, please see our Cookies Policy, which is available at www.s4learning.com

III. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
The Individual Responsible for the Treatment of Personal Data is SCALA HIGHER EDUCATION S.C., a company identified with NIF/RFC. SHE1110145H4 and with address at Calzada de la Naranja No159, Fraccionamiento Industrial Alce Blanco, C.P. 53370 Naucalpan, Estado de Mexico, Piso 4, duly constituted.
The simple and mere use of the Website grants the condition of User of such, whether individual or legal entity, and implies the unconditional, complete, full and unreserved acceptance of each and every one of the clauses and general conditions included in document herein the website. If the User does not agree with the clauses and conditions of use of this policy, it must refrain from using the Website. It is the responsibility of all Users to read these terms and conditions.
The user is obliged and undertakes to use the website and its contents in accordance with the provisions of this document, in current legislation and in any other notice or instructions made known to all by SCALA, either through this clause or through any other place within the contents within the website, as well as with the rules of coexistence, morality and generally accepted good customs.
For the purposes of the foregoing, the User undertakes and agrees not to use any of the Content for illicit purposes or effects, prohibited in this policy or in current legislation, harmful to the rights and interests of third parties, or that in any way may damage, render useless, overload, deteriorate or prevent the normal use of the Contents, computer equipment or documents, files and all kinds of content stored in any computer equipment owned or contracted by SCALA, other Users or any Internet user ( hardware and software).
The user undertakes and undertakes not to transmit, disseminate or make available to third parties any kind of material contained on the website, such as information, texts, data, content, messages, graphics, drawings, sound files and/or image, photographs, recordings, software, logos, trademarks, icons, technology, photographs, software, links, graphic design and source codes, or any other material to which you have access as a User of the website, without this enumeration having limiting character.

IV. DATA PROCESSING

A. Data subject to processing on SCALA services.

● Personal data that you provide us in the information request formats, such as name, surname, telephone number, country, organization or service of interest.
● We will treat the data that appears in the documents that you send us during the process of contracting or providing the product or service, within the contractual framework between the parties.
● Likewise, we will also treat the information you provide us through the use of cookies if you consent to their acceptance, in accordance with SCALA's cookie policy (available at www.s4learning.com).
● In relation to the information that you can provide us by telephone, we inform you that we have a call recording system to guarantee the management of the quality of telephone attention. By accepting this document, you accept both the use of the data provided in our data collection form for the issuance of commercial calls that offer our services, as well as the recording of such for quality purposes and claims of the indicated service.
B. Purposes of data processing:

● Contact you through the necessary means, including electronic means, using your contact details, provided by you, in order to provide you with information related to SCALA's corporate purpose. This information will include commercial information and general information about SCALA.
● Show you advertising and promotion about our products, services and activities object of SCALA, related to your preferences based on your browsing habits (targeted or advertising cookies).
● The recording of calls to facilitate the process of information required by you and verify the level of quality of our services (throughout the entire process, from your first contact with us).
● We may also process your data, internally within SCALA, for control, quality and security purposes, for our own regulatory compliance and in compliance with our legal obligations. This includes the processing of your data to perform satisfaction surveys of the services or products provided.
● Comply with the requirements established in the regulations applicable to private companies in Mexico. Whether they are fiscal, accounting, administrative or those that the commercial activity establishes.
● Perform market studies with the basic data that you freely provide us by participating in them. Likewise, to perform studies for statistical, scientific or historical purposes.
● Comply with the obligations contracted with the Holders of the Personal Data in the development of the relationship that exists between the Holder of the Personal Data and SCALA.
● The management of information with third-party companies with which SCALA has a contractual relationship (duly regulated with the appropriate data protection clause) and that is necessary for the fulfillment of the object of your request.
● To comply with the requirements made by the relevant authorities in all matters that affect SCALA, such as, by way of example and not excluding: collection of taxes, fees and contributions at the local and/or national level. As well as the competent authorities in data protection.
INTELLECTUAL PROPERTY: All trademarks, trade names or distinctive signs of any kind that appear on the website are the property of SCALA or, where appropriate, of third parties who have authorized their use, without it being understood that the use or access to it Website and/or the Contents attribute to the User any right over the aforementioned trademarks, trade names and/or distinctive signs, and none of the exploitation rights that exist or may exist over said Contents can be understood to be transferred to the User.
In the same way, the Contents are the intellectual property of SCALA, or of third parties, as the case may be, therefore, the Intellectual Property rights are owned by SCALA or of third parties that have authorized their use, to whom the exclusive exercise of exploitation rights corresponds. of this in any form and, especially, the rights of reproduction, distribution, public communication and transformation.
The unauthorized use of the information contained on the website, as well as the infringement of the Intellectual Property rights of SCALA or of third parties included on the website that have transferred content, will give rise to the legally established responsibilities.

C. How long will we keep your data?

● The contact data that you provide us requesting information will be treated indefinitely, until you revoke your authorization for us to contact you for the purposes indicated in this Privacy Policy. Being eliminated when they are no longer necessary or relevant for the purpose for which they were collected or registered.
● The information obtained through cookies and similar devices will be treated for the periods of time indicated in SCALA's Cookies Policy (available at www.s4learning.com).
D. Obligation to provide the data and consequences of not providing it: the different information collection forms will indicate what data is required to complete the different requests. Without the provision of these, the execution of your request will not be possible.
E. Recipients of the data:
SCALA relies on the collaboration of service and information technology providers that process the data in the name and on behalf of our entity. In these cases, after conducting a strict supplier selection control based on the guarantees of compliance with the data protection regulations, we will sign the relevant data processing contract with these entities. These providers grant adequate guarantees and can only use your data for what is strictly necessary in relation to the purposes described above. These entities will have access to the data as data processors and will only process the information following specific instructions on behalf of SCALA. We inform you that in such events SCALA will adopt all necessary measures so that the people who have access to Personal Data comply with SCALA's Policy for the Treatment and Protection of Personal Data and the applicable legislation.
F. Rights of the Holders of the data: The Holders of the Personal Data are assisted by the rights of access, rectification, deletion, limitation, portability, opposition, as well as to be able to present a claim before the competent data protection authority that in law will assists you.
G. Requests, petitions, complaints or claims: The Owners of the Personal Data may submit any request, petition, complaint or claim, at the following addresses:
● Physical Address: Calzada de la Naranja No159, Fraccionamiento Industrial Alce Blanco, C.P. 53370 Naucalpan, Estado de Mexico, Piso 4
● Email address: protecciondatos@s4learning.com
● Accompany with a simple copy of the official documents that prove the identity of the owner and, if applicable, the legal representation of the same.
● Include a clear and precise description of the personal data with respect to which the aforementioned rights conferred by the Law will be exercised.
H. Security Measures: SCALA has adopted all necessary technical, human and administrative measures to provide security to all Personal Data collected, preventing its adulteration, loss, consultation, use or unauthorized or fraudulent access. Such measures have been adopted in accordance with the requirements established in the applicable Legislation and in the Personal Data Treatment and Protection Policy of SCALA.
I. Policies for the Treatment of Personal Data: SCALA is subject to the legislation in force in the Federal Mexican State, complying with all its requirements.

V. MODIFICATIONS
SCALA se reserva el derecho de efectuar cualquier tipo de modificación al presente documento, en cualquier momento, siempre dentro del marco de lo establecido en la Legislación aplicable. Cualquier modificación será informada y publicada oportunamente en el sitio web www.s4learning.com de SCALA.

VI. APPLICABLE LAW AND DISPUTE RESOLUTION
This Privacy Policy will be governed and interpreted in accordance with the Federal Law of the Estado de Mexico. Any dispute, controversy or claim that arises with respect to the interpretation, application and/or compliance with this Privacy Policy must be submitted in the first instance to alternative conflict resolution mechanisms such as mediation, conciliation or friendly composition. In the event that the parties fail to resolve the dispute within a maximum period of one (1) month from the date of notification by either party to its counterpart of the existence of the dispute, the parties will submit the resolution of said controversy to the ordinary justice.

VII. LIMITATION OF LIABILITY
SCALA excludes all responsibility for the decisions that the User may take based on this information, as well as for possible typographical errors that may be contained in the documents and graphics on the website. The information is subject to possible periodic modifications without prior notice of its content due to expansion, improvement, correction or updating of the Contents.

VIII. NOTIFICATIONS
All notifications and communications by SCALA to the User made by any means will be considered effective for all purposes.

IX. AVAILABILITY OF CONTENT
The provision of the service of the Website and the Contents has, in principle, an indefinite duration. SCALA, however, is authorized to terminate or suspend the provision of the website service and/or any of the Contents at any time. When such is reasonably possible, SCALA will give prior notice of termination or suspension of the website.