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LEGAL INFORMATION

SAJU Privacy Policy

Effective date: October 27, 2026

At SAJU, protecting the personal information of students and families is an important part of the trust placed in us.

This Privacy Policy explains how we collect, use, disclose, protect and retain personal information when you visit our website, submit an inquiry, use our University Fit Assessment, receive a Fit Report, or participate in our educational counseling services.

It also explains your privacy rights and how to contact us.

SAJU双岸教育 is the commercial brand of:

Dos Nius Consultors I Assessors S.L. NIF/CIF: ES-B26680082 Registered address: Camí del Corb Marí 6, 4ºB, 07015 Palma de Mallorca, Spain Email: info@shuanganjiaoyu.com Telephone: +86 150 2692 9480

Dos Nius Consultors I Assessors S.L. is SAJU's principal contracting and invoicing entity and the contact point for privacy inquiries.

SAJU's authorized team members operate in Europe and China. Relevant student information may be accessed by authorized personnel in these locations as necessary to deliver our services.

When you contact SAJU, we may collect student and parent names, email addresses, telephone numbers, WeChat IDs, school information, curriculum, graduation year, intended majors, university preferences, annual tuition budget, inquiry type, messages and voluntarily uploaded documents.

The assessment collects information about the student's academic background, country of residence, target universities, qualifications, grades, standardized tests, extracurricular activities, leadership, awards, projects, educational preferences, career interests, family education budget and financial aid needs.

Our assessment system produces university compatibility scores, strategic classifications, strengths, areas for improvement, recommended next steps and alternative university suggestions.

A downloaded or emailed Fit Report may contain both these results and the student's original questionnaire responses.

During paid services, we may process academic records, university applications, essays, project materials, uploaded documents, task progress, counselor messages, communications, feedback and other information required to deliver the contracted services.

Our systems and providers may process IP addresses, browser information, authentication identifiers, request logs, error reports and information necessary for security and technical operations.

We process personal information to:

● Respond to inquiries and communicate with students and families.

● Generate personalized University Fit Assessment results.

● Provide report downloads and requested email delivery.

● Deliver purchased educational counseling and student development services.

● Coordinate counselors, tasks, applications and educational resources.

● Arrange authorized introductions to mentors or professional contacts.

● Operate, maintain and secure the website and digital platform.

● Manage payments, contractual records and legal obligations.

● Send educational updates, invitations and marketing communications where users have

provided the required consent.

Marketing subscriptions are optional and independent of the ability to use the assessment or purchase services.

Where the EU General Data Protection Regulation applies, the legal basis depends on the processing activity.

We may rely on contractual necessity, steps requested before entering into a contract, legitimate interests, compliance with legal obligations or consent, as appropriate.

For example, information necessary to respond to a service inquiry or fulfill a purchased service may be processed under the relevant contractual or legitimate-interest basis, depending on the individual and context.

Optional marketing, certain disclosures and promotional uses rely on consent where required.

Where other applicable privacy legislation imposes additional obligations, we will apply the relevant requirements.

SAJU's University Fit Assessment uses a combination of programmed evaluation methods and artificial intelligence.

Our application calculates the principal target-university match score through its own assessment algorithm. OpenAI models accessed through an API assist with written analysis, recommendations, alternative universities and explanatory content.

The information supplied in the questionnaire is transmitted to the OpenAI API as necessary to produce these results.

OpenAI does not use API data to train its models by default unless the customer explicitly opts in. Its standard API configuration may retain abuse-monitoring information for up to 30 days, subject to applicable exceptions and account settings.

SAJU also uses temporary caching through Upstash Redis. Personalized assessment narratives and related analysis outputs may be cached for up to seven days. These cached results may contain identifiable student information.

The assessment is informational and advisory. It does not submit university applications, make official admissions decisions or guarantee admission.

The displayed percentages are heuristic university-fit indicators, not statistically validated admission probabilities.

Users may contact SAJU to request further information about the assessment and their applicable rights concerning automated processing.

SAJU provides services to secondary school students, including minors.

We take account of applicable requirements concerning students' personal information, parental responsibility and appropriate authorization.

Where parental or guardian authorization is legally required for a particular processing activity, that authorization must be obtained.

Contracts for paid counseling services are entered into by a parent or legal guardian.

Users should not submit unnecessary sensitive information in open-ended responses or uploaded documents.

We share information only where there is an appropriate purpose and lawful basis.

Relevant recipients may include:

Authorized SAJU personnel: Team members and counselors who need information to provide or administer services.

External mentors and professionals: Relevant student information may be disclosed with appropriate prior authorization for the specific activity.

Technology providers: SAJU uses service providers for website hosting, authentication, database services, document storage, assessment generation, email delivery and error monitoring.

These include, as applicable:

● Vercel for application hosting and infrastructure.

● OpenAI for AI-assisted assessment generation.

● Upstash for temporary assessment caching and other technical functions.

● Neon and PostgreSQL for student platform records.

● Clerk for authentication.

● Vercel Blob for uploaded document storage.

● Resend for transactional email delivery.

● IONOS for business email.

● Sentry for technical error and performance monitoring.

SAJU does not sell student or parent contact details to third parties for their independent marketing purposes.

We may disclose information where required by law or necessary to exercise or protect legal rights.

SAJU serves families internationally and uses technology providers operating in different jurisdictions.

Authorized team members located in Europe and China may access information necessary for their work.

Information may also be processed in other countries, including the United States, through external technology providers.

Resend's standard email infrastructure stores relevant email data in the United States. Other providers may also process information outside the country in which it was collected.

Where required, SAJU will implement applicable legal safeguards for international data transfers and provide information or obtain authorization required by the relevant law.

Users may contact us to request information about applicable transfer arrangements.

We retain personal information for periods appropriate to the purpose of processing and applicable legal obligations.

Prospective customer inquiries: Normally 12 months after the last meaningful interaction, unless a longer period is justified by an ongoing matter or legal obligation.

Former student and client service records: Normally two years after the relevant service relationship ends, unless a longer period is required by law or justified by a specific lawful purpose.

Accounting, tax and contractual records: Retained for the periods required by applicable law.

University Fit Assessment: SAJU does not maintain a permanent database containing every student's complete original questionnaire and Fit Report solely for this feature. Personalized analysis outputs may be cached in Upstash Redis for up to seven days.

AI processing: Under standard OpenAI API data controls, certain monitoring information may be retained for up to 30 days, subject to configuration and applicable exceptions.

Report email delivery: Resend's standard plans generally retain email and log information for 30 days. Received messages may remain in the recipient's mailbox according to the applicable mailbox and archiving settings.

Promotional case studies: Selected materials may remain in use for the period permitted by the applicable project license or separate promotional authorization, subject to the individual's legal rights and applicable retention limits.

Marketing information: Retained while necessary for an active subscription and any applicable compliance requirements.

Technical logs, backups and provider records may have additional retention periods determined by the relevant systems and agreements.

Users may voluntarily subscribe to SAJU newsletters, educational resources, event invitations and occasional promotional information.

Where required, we collect consent separately from service-related acknowledgments and contractual acceptance.

Users may unsubscribe at any time using the available unsubscribe mechanism or by contacting info@shuanganjiaoyu.com.

Withdrawal of marketing consent does not affect communications necessary to provide a requested service.

SAJU uses authentication and technical monitoring services, including Clerk and Sentry, to support account access, system stability, troubleshooting and security.

Our website may use necessary cookies or similar technologies for these purposes.

We do not currently identify Google Analytics or Meta Pixel as active integrations in the reviewed application code.

If additional non-essential analytics or advertising technologies are deployed, we will provide the relevant disclosures and consent choices where required.

SAJU seeks to protect personal information through appropriate technical and organizational measures, including access restrictions, authentication, secure communication and confidentiality requirements.

We review and improve these measures as our systems develop.

No online platform can guarantee absolute security.

If a security incident occurs, we will assess the circumstances and comply with applicable notification and remedial obligations.

Student-created projects generally remain the intellectual property of the student, subject to applicable third-party rights or specific project agreements.

SAJU and participating mentors may request permission to showcase projects or use selected project materials as case studies.

Publication of identifiable student information, testimonials, photographs or videos is subject to appropriate authorization and applicable legal requirements.

The scope and duration of such uses may be established through a separate written authorization or license.

Refusal to participate in optional promotional activities does not prevent access to ordinary contracted counseling services.

Depending on applicable law, you may have rights to access, correct, delete, restrict or obtain copies of your personal information; object to certain processing; withdraw consent; request data portability; and obtain information about relevant automated processing.

Requests may be submitted to:

info@shuanganjiaoyu.com

We may request information reasonably necessary to verify identity or the authority to act on behalf of another individual.

We will respond in accordance with applicable law.

Where relevant, individuals may also complain to the Spanish Data Protection Agency or another competent supervisory authority.

Our website may contain links to external websites or services. These third parties operate under their own terms and privacy policies.

We encourage users to review those policies before sharing personal information.

We may update this Privacy Policy as our services, technology and legal requirements evolve.

The current version will be published on the website with its effective date.

Where required by law, we will provide additional notice or request renewed consent.

Dos Nius Consultors I Assessors S.L. Trading as SAJU双岸教育

Camí del Corb Marí 6, 4ºB 07015 Palma de Mallorca Spain

NIF/CIF: ES-B26680082 Email: info@shuanganjiaoyu.com Telephone: +86 150 2692 9480