PDPA (PERSONAL DATA PROTECTION ACT)

JULIA GABRIEL INTERNATIONAL PRIVACY POLICY

1. Introduction
Your privacy is important to us. Julia Gabriel International (“JGI”) has updated our Privacy Policy to comply with the Personal Data Protection Act 2010 (“PDPA”). JGI hopes that the policy outlined below shall help you understand what data is collected, how it is used, how the data is safeguarded and with whom it may be shared.
For the purposes of this consent form, Julia Gabriel Education shall mean EduKate Learning Centre Sdn Bhd and its subsidiaries including Julia Gabriel Centre, Chiltern House Preschool, and Chengzhu.

2. Consent
JGI assures that all personal information collected shall be used or disclosed only for the purposes for which it was collected.

3. Data Collected
JGI collects and holds personal data of customers and staff for various purposes. The data collected includes, but is not limited to, the following:
• full name
• date of birth
• contact details (mobile numbers, landline numbers, addresses, fax numbers and email addresses)
• identity document number eg. NRIC / FIN number, passport number
• bank account and payment details / transaction history
• assessment results / reports
• biodata: behaviour, gender, marital status, ethnic group, special educational need
• any relevant medical information
• photographs / video material

4. Purpose of Use
Generally, JGI collects personal data in order to fulfil the following purposes:
• to respond and process enquiries on courses, registration and admission matters and activities
• to provide and administer support to students, to monitor and report on their progress and wellbeing
• to give information about events, activities, programmes and talks offered at JGI centres and preschools
• to give information on the launch of new products and services introduced by JGI
• to relate promotional offers relating to the programmes and events at our centres and preschools
• Surveys and evaluations
• Any updates relating to Julia Gabriel International which may be relevant in maintaining or managing our ongoing relationship with you

JGI may also collect, use, disclose or process information contained in employment applications or other employment-related forms or documents submitted to us for administrative and management purposes including, but not limited to, recruitment, assessment of a candidate’s suitability, appraisal, performance, promotion, training, career development, remuneration, health and safety, review of human resources policies or for statistical purposes.

5. Sharing Data with Third Parties
JGI shares personal data with authorised third parties for the purposes of the third parties providing relevant service to JGI. All authorised Third Parties shall sign a contract or a letter of undertaking9 with JGE to ensure that the data is used purely for the intended purpose of providing the required service. All authorised Third Parties shall be required to undertake the appropriate measures to safeguard the data and adhere to the PDPA requirements.

6. Limitations
JGI shall not use your personal data for reasons not specified in the Purpose of Use unless:
• it is required by law or governmental or judicial authorities of Malaysia
• it is necessary to establish and safeguard a legal claim or defence
• it is necessary to prepare, negotiate and perform a contract with  you
• it is necessary to prevent illegal activities, e.g. in situations where the safety of a student is concerned

Children and minors should only use JGI’s websites or services with the permission of their parent or guardian. Except where required by local low, JGI will not knowingly collect personal information provided by children and minors.

7. Data Retention & Removal
JGI shall only keep data collected as long as is necessary to provide the services outlined above and in compliance with Malaysia’s financial and legal requirements.

8. Accuracy, Access and Correction
JGI shall make all reasonable efforts to ensure that personal data collected is current, complete and accurate. You may view, edit and correct the data held by JGI. If you wish to access your personal data with JGI, you may send a written request to kualalumpur@juliagabriel.com.my.
As part of our security measures, a JGI staff shall contact you to acknowledge receipt and to carry out the necessary identity verification measures in order to process your request.  Where we are informed that data is out of date, we shall make the amendments and, where necessary, confirm that the data has been updated within 30 working days.

9. Withdrawal of Consent
If you wish to opt out of receiving information or a particular mode of contact regarding news and updates on programmes, events, workshops, talks and other marketing promotional activities organised by us, you may click on the link provided on our website to obtain the PDPA Withdrawal of Consent form.  All forms must be submitted to kualalumpur@juliagabriel.com.my.
We shall require a period of 30 working days to update and process your request.  Within these 30 working days, you may still receive information from us.
Notwithstanding your withdrawal of consent, you shall receive from JGI information, reminders, invoices or notices pertaining to my child(ren)’s classes and other information that is necessary for JGI to communicate with your with regards to your child(ren).

10. Data Security
JGI shall be responsible for:
• implementing relevant security measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure, use or access
• informing affected individuals about any accidental or unauthorised access of their data which may lead to damage or harm
If you are aware of any actual or potential breach of security in relation to personal data, please report the breach to kualalumpur@juliagabriel.com.my

11. IP Address Information & Cookies
When you access our website, we may automatically collect non-personal statistical data about your computer (including your IP address, operating system, browser) for system administration / maintenance purposes to enable us to improve our website, e.g. determine browsing patterns or how visitors use the site. As with most websites, our websites contain “cookies” to improve the online experience. Cookies store some data on your computer to automatically recognise your PC the next time you visit. The data collected does not identify any individual and is entirely anonymous.

12. Information Security
Information provided over the Internet cannot be guaranteed to be 100% secure. JGI takes a very serious view of the protection of our customers’ data collected through our websites and through our mobile services applications. All reasonable steps shall be taken to protect the data, however we cannot fully guarantee the security of data submitted electronically and it is therefore provide via these means at the customer’s own risk Be assured that we shall provide appropriate technical and organisational security measures to protect data that is collected on our servers.

13. Links to other websites
JGI may provide links to websites which we believe share our high standards for data protection. Nevertheless we cannot control the policies of other websites or the use of any data you may share with them. Please note that JGI’s Privacy Policy does not cover these other websites.

14. Updates to the Policy
JGI may amend this Privacy Policy from time to time.  Any modifications and updates shall be stamp-dated and effective immediately once it is posted in our website and portal. Your continued use of our services constitutes acceptance of the privacy policy and its modifications. The prevailing language of the Privacy Policy shall be English. In the event of any inconsistency in interpretation, this Privacy Policy version in English shall prevail.

15. Contact Us
If you have any comments or questions about our Privacy Policy, you may contact us by email at kualalumpur@juliagabriel.com.my.