This summary highlights the key points of this Privacy Notice. The full Privacy Notice below governs.
1.1 This Privacy Notice explains how Yayasan Pendidikan Green Montessori, acting through Green Montessori School (“GMS”, “we”, “us” or “our”), collects, uses, discloses, stores and otherwise processes Personal Data, and the rights you have under Applicable Law.
1.2 It applies to Personal Data we process when you:
(a) visit or use the Website;
(b) send us an enquiry, register for a school visit or an Open House, or register your Child for a trial day;
(c) submit an admission application or upload documents in support of one;
(d) contact us by email, telephone or our instant messaging channel; or
(e) otherwise interact with us through the Channels about a possible enrolment.
1.3 It does not apply to:
(a) Third-Party Services, including any linked from the Website, on which we advertise, or through which you choose to contact us. Their operators process Personal Data for their own purposes under their own privacy terms, which we do not control and encourage you to read. A link from the Website is not an endorsement of a Third-Party Service or its privacy practices; or
(b) Personal Data of enrolled students and their families after enrolment, which is governed by the enrolment agreement, our student records policy and the privacy information GMS provides on enrolment.
1.4 Messages you send us through a third-party instant messaging platform are also subject to that platform’s privacy terms. We are responsible for our own processing of the messages we receive.
1.5 The version of this Privacy Notice published on the Website is the version in force. A printed copy, or an extract reproduced in a form or an email, is for convenience.
1.6 Please read this Privacy Notice before providing Personal Data to us, and review it from time to time.
1.7 We sometimes give additional privacy information at the point of collection, for example in a form, a registration page or a message. Where it is more specific than this Privacy Notice, it applies to that collection.
1.8 The Terms of Use govern your use of the Website and our other online services (see Section 14). This Privacy Notice governs our processing of Personal Data.
This Section explains the capitalised terms used in this Privacy Notice.
2.1 In this Privacy Notice:
(a) “Applicable Law” means the PDP Law and every other law and regulation of the Republic of Indonesia that applies to our processing of Personal Data;
(b) “PDP Law” means Law of the Republic of Indonesia No. 27 of 2022 on Personal Data Protection, together with its implementing regulations;
(c) “Personal Data” means data about an individual who is identified or identifiable, alone or in combination with other information, directly or indirectly, through an electronic or a non-electronic system, as defined in the PDP Law;
(d) “Data Subject” means the individual to whom Personal Data relates;
(e) “Controller” means the party that determines the purposes of, and exercises control over, the processing of Personal Data, as defined in the PDP Law;
(f) “Processor” means a party that processes Personal Data on behalf of the Controller, as defined in the PDP Law;
(g) “Child” means an individual under eighteen (18) years of age, including a prospective student, whose Personal Data is provided to us by a parent or guardian;
(h) “Channels” means the Website, our email addresses, our telephone numbers, our instant messaging channel and any other means by which we invite you to contact us;
(i) “Request” means a request to exercise a right described in Section 8;
(j) “Terms of Use” means the terms of use published on the Website, which govern use of the Website and our other online services;
(k) “Third-Party Services” means websites, applications, platforms, networks and services operated by a person other than GMS, including social media platforms, instant messaging platforms, advertising networks, search engines and payment channels;
(l) “Website” means the GMS website on which this Privacy Notice is published, including its sub-domains and the online admissions portal; and
(m) “you” and “your” refer to the Data Subject, including a parent or guardian who provides Personal Data to us and a visitor to the Website.
2.2 A reference to “processing” includes collecting, recording, organising, storing, using, analysing, disclosing, transferring, deleting and destroying Personal Data.
2.3 The words “include”, “including” and “such as” introduce examples, not an exhaustive list; a reference to a law or document includes it as amended, supplemented or replaced from time to time; and headings are for convenience only.
This Section identifies the organisation responsible for your Personal Data.
3.1 Yayasan Pendidikan Green Montessori (the “Foundation”) is a foundation established under the laws of the Republic of Indonesia. It operates Green Montessori School at Jalan Duren Tiga Raya No. 133, Pancoran, South Jakarta 12760, Indonesia.
3.2 The Foundation is the Controller of the Personal Data described in this Privacy Notice.
3.3 We act through our staff, officers and authorised representatives, and through Processors acting on our instructions.
This Section describes the Personal Data we collect, where it comes from, what we use it for and the legal basis for each use.
4.1 We process Personal Data only where we have a legal basis under Article 20 of the PDP Law. The legal bases we rely on are:
(a) your explicit and valid consent for one or more specific purposes (“consent”);
(b) the performance of an agreement to which you are a party, or steps taken at your request before entering into an agreement (“agreement”);
(c) compliance with a legal obligation to which we are subject (“legal obligation”); and
(d) the pursuit of our legitimate interests, having balanced them against your interests and rights (“legitimate interest”).
4.2 More than one legal basis can apply to the same activity. Where it does, we rely on each of them, and if one ceases to apply we continue on another that remains available, to the extent Applicable Law permits.
4.3 We collect Personal Data:
(a) directly from you, when you complete a form, upload a document, send a message or speak with us;
(b) automatically, when you use the Website, through cookies and similar technologies (see Section 10);
(c) from your Child’s other parent or guardian, or from another person who provides it on your behalf;
(d) from third parties you have asked or authorised to provide it, such as a previous school that sends records at your request; and
(e) from government and regulatory authorities, where Applicable Law permits or requires.
4.4 We process Personal Data for the following activities and purposes:
(a) Visits to the Website.
Personal Data: information about your use of the Website, including the pages you view, the date and time of your visit, your device type, operating system and browser, your Internet Protocol address and the approximate location derived from it, and the website or advertisement that referred you to us, collected through cookies and similar technologies (see Section 10).
Purpose: to operate, maintain, develop and improve the Website; to keep it secure and protect it against automated abuse; to measure how it is used; and to measure and improve the effectiveness of our advertising.
Legal basis: legitimate interest in operating a secure and effective Website and in understanding how it is used and how visitors reach it.
(b) Enquiries, school visits and Open House registrations.
Personal Data: your name, telephone number and email address; your Child’s name and age; the content of your message; and any other information you choose to give us.
Purpose: to respond to your enquiry; to arrange, confirm, reschedule and record your visit; and to send you follow-up information relating to your enquiry (see clause 4.7).
Legal basis: your consent, given when you submit the form or send the message; and legitimate interest in keeping a record of our correspondence with you and following it up.
(c) Trial-day registrations.
Personal Data: your Child’s name, place and date of birth, and sex; the names of both parents; your telephone number and email address; and any information you give us about your Child’s needs for the day.
Purpose: to arrange the trial day, send you confirmation and next steps, supervise your Child safely on the day, and keep a record of the day so that we can advise you on next steps.
Legal basis: steps taken at your request before entering into an agreement; and your consent as parent or guardian to the processing of your Child’s Personal Data.
(d) Admission applications and document uploads.
Personal Data: the information you provide in the application form; your Child’s details; supporting documents, which may include identity documents, family registration documents, previous school records and health information relevant to your Child’s schooling; proof of payment of application fees; and our notes and correspondence about the application.
Purpose: to assess and process the application, including by verifying the information provided where you have authorised us to do so; to communicate with you about it; to administer any waiting list; to collect the applicable fees and issue receipts; and, if your Child is accepted, to prepare the enrolment agreement and create the student record.
Legal basis: steps taken at your request before entering into an agreement, and the performance of the enrolment agreement once it is signed; your consent as parent or guardian to the processing of your Child’s Personal Data, including any health information you choose to provide; and legal obligation, where we are required to collect or keep particular information.
(e) Messages sent to our instant messaging channel, by email or by telephone.
Personal Data: your telephone number or email address, your name and the content of your messages or call, including any Personal Data about your Child that you include.
Purpose: to answer your questions, follow up on your enquiry and keep a record of what was said.
Legal basis: legitimate interest in responding to messages sent to us and keeping a record of them; and, where your message includes your Child’s Personal Data, your consent as parent or guardian.
4.5 We also process Personal Data from any of these activities:
(a) to comply with Applicable Law and with lawful requests from government and regulatory authorities (legal basis: legal obligation);
(b) to establish, exercise or defend legal claims, and to handle complaints and disputes (legal basis: legitimate interest);
(c) to prevent, detect and investigate fraud, misuse of the Channels, breaches of the Terms of Use and threats to the safety of children, families or staff (legal basis: legitimate interest);
(d) to administer, review and improve our admissions process and our communications, to train our staff and to prepare internal records, statistics and reports, using aggregated or anonymised information where reasonably practicable (legal basis: legitimate interest); and
(e) to maintain the security and integrity of our systems, including by keeping access logs and backup copies (legal basis: legitimate interest).
4.6 We may also process Personal Data for another purpose compatible with those in this Section 4. We do not process Personal Data for an incompatible purpose unless Applicable Law permits or requires it, or we have first told you about the new purpose and, where Applicable Law requires, obtained your consent. We do not make admission decisions based solely on automated processing.
4.7 If you have enquired about admission, registered for a visit or a trial day, or submitted an application, we send you information relating to that enquiry from time to time, such as admission timelines, Open House dates and the availability of places. We rely on legitimate interest, and send this information for no longer than the retention period in Section 7. You can ask us to stop at any time (see Section 16), and we will stop within a reasonable period.
4.8 Where we rely on your consent, you can withdraw it at any time (see clause 9.8). Where we rely on legitimate interest, you can ask us to explain the balancing we have carried out (see Section 16).
4.9 If you do not provide Personal Data we reasonably need for a purpose in this Section 4, we may be unable to respond to your enquiry, arrange a visit or trial day, or process an application.
This Section explains how we handle Personal Data about children, and about people other than you.
5.1 The Channels are intended for parents, guardians and other adults. We do not knowingly collect Personal Data directly from a Child through the Website. We collect a Child’s Personal Data from the Child’s parent or guardian, and process it only with that parent’s or guardian’s consent or on another legal basis permitted by the PDP Law.
5.2 If we become aware that we have collected Personal Data directly from a Child without a parent’s or guardian’s consent, we take reasonable steps to delete it or to obtain the required consent.
5.3 When you provide Personal Data about your Child, you confirm that you are the Child’s parent or legal guardian, or are otherwise authorised to provide it and to give consent on the Child’s behalf. We may ask you for reasonable evidence of that authority.
5.4 When you provide Personal Data about another adult, such as the Child’s other parent, you confirm that you are entitled to do so, that you have informed that person of this Privacy Notice and that, where consent is required, you have obtained it.
5.5 Please make sure the Personal Data you give us is accurate and complete, and tell us about any material change while we are still processing it for the purposes in Section 4. We rely on the Personal Data you provide. The consequences of inaccurate, incomplete or out-of-date information are addressed in the Terms of Use.
5.6 Please provide Personal Data, in particular identity documents and health information, only through the Channel we have asked you to use for it. If you send Personal Data through another Channel, or send us more than we asked for, we delete it or ask you to resend it through the appropriate Channel.
This Section describes who we share Personal Data with.
6.1 We share Personal Data with recipients in the following categories:
(a) Processors acting on our behalf, by category, including information technology, hosting and infrastructure service providers; email, telephony and communication service providers; providers of services that protect the Website against automated abuse; analytics and advertising service providers; and banks and payment service providers through which fees are paid;
(b) Government and regulatory authorities, including the ministry responsible for education, accreditation bodies, the institution responsible for personal data protection, law enforcement agencies and courts, where Applicable Law requires or permits;
(c) Our professional advisers, including lawyers, auditors, accountants and insurers, who are bound by duties of confidentiality, where necessary to obtain their advice or services or to establish, exercise or defend legal claims;
(d) The Foundation’s organs and management, including its board of trustees, supervisors and management, and GMS staff, in each case on a need-to-know basis;
(e) A successor operator of the school, in connection with a reorganisation or a transfer of all or part of the school’s operations, to the extent Applicable Law permits and on terms that give Personal Data protection at least equivalent to this Privacy Notice;
(f) Emergency services and medical practitioners, where disclosure is necessary to protect the health, safety or vital interests of a Child or another person, to the extent Applicable Law permits; and
(g) Other persons with your consent, or at your request.
6.2 We require each Processor, by contract or under Applicable Law, to protect Personal Data, to process it only on our documented instructions and to comply with the PDP Law. The Processors we use change from time to time, within the categories in clause 6.1(a).
6.3 We do not sell Personal Data. We do not disclose Personal Data to third parties for their own marketing purposes.
6.4 We also share information that has been aggregated or anonymised so that it no longer identifies you, for any purpose and with any person, to the extent Applicable Law permits.
This Section explains how long we keep Personal Data.
7.1 We keep Personal Data for no longer than is necessary for the purposes for which it was collected, in accordance with our data retention policy as amended from time to time. The retention period depends on, among other things, the category of Personal Data, the purpose for which it is processed, the Channel through which it was collected, and our legal, regulatory, accounting and reporting obligations. Personal Data relating to applications that proceed to enrolment becomes part of the student record and is kept in accordance with our student records policy.
7.2 We keep particular Personal Data for longer than the periods in our data retention policy, including after you have asked us to delete it, where and for as long as:
(a) Applicable Law requires or permits us to retain it;
(b) it is needed to establish, exercise or defend legal claims, or to handle a complaint, dispute, investigation or regulatory inquiry, until the matter is concluded and any period for appeal or further action has expired;
(c) it is needed for audit, accounting, tax or regulatory reporting purposes;
(d) it is subject to a request, order or hold from a court or a government or regulatory authority; or
(e) you have asked us to retain it.
7.3 Where we keep Personal Data under clause 7.2, we limit our processing of it to storage and to the purpose that justifies keeping it, and only for as long as that reason applies.
7.4 Personal Data deleted from our active systems may remain in routine backup and archive copies for a limited further period, until those copies are overwritten or expire in the ordinary course. While it remains in a backup copy, we use it only to restore our systems, and it remains protected by this Privacy Notice.
7.5 When the retention period ends, we delete or destroy the Personal Data, or anonymise it so that it no longer identifies you, in accordance with the PDP Law and by a method appropriate to the data.
This Section lists the rights you have over your Personal Data under the PDP Law.
8.1 Subject to Applicable Law, and in the circumstances and on the conditions set out in the PDP Law, you have the following rights as a Data Subject:
(a) to obtain information about the identity of the Controller, the legal basis and purpose of the processing, and how we are accountable for your Personal Data;
(b) to complete, update or correct Personal Data that is inaccurate or incomplete;
(c) to access and obtain a copy of your Personal Data;
(d) to end the processing of, delete or destroy your Personal Data;
(e) to withdraw your consent to processing, without affecting the lawfulness of processing carried out before the withdrawal;
(f) to object to a decision based solely on automated processing, including profiling, that has legal consequences for you or significantly affects you;
(g) to delay or limit the processing of your Personal Data, in proportion to the purpose of the processing;
(h) to bring a claim and obtain compensation for a breach of the PDP Law in the processing of your Personal Data, in accordance with the PDP Law; and
(i) to obtain and use your Personal Data in a structured, commonly used format, and to have it transmitted to another controller, where technically feasible (data portability).
8.2 A parent or legal guardian may exercise these rights on behalf of his or her Child. When a right is exercised on behalf of a Child, we also consider the interests of the Child and of the Child’s other parent or guardian in deciding how to respond.
8.3 The rights in clause 8.1(d), (e), (f) and (g) are subject to the exceptions in the PDP Law and other Applicable Law, including for national defence and security, law enforcement, the public interest in state administration, and statistical and scientific research.
8.4 Nothing in this Privacy Notice removes or reduces any right the PDP Law gives you. Where this Privacy Notice describes a right in narrower terms than the PDP Law, the PDP Law applies.
This Section explains how to make a Request and what happens when you do.
9.1 To exercise any of the rights in Section 8, send us a written Request using the contact details in Section 16, stating which right you wish to exercise, the Personal Data concerned and, where you are acting for your Child, your relationship to the Child. We also accept a Request made in another form where appropriate.
9.2 Before we act on a Request, we verify your identity and, where relevant, your relationship to the Child, usually by asking you to send the Request from the email address or telephone number we hold for you, or for reasonable supporting information. This protects Personal Data from being disclosed to, or changed by, someone who is not entitled to it.
9.3 We do not act on a Request we cannot verify. The period for responding begins when we have received the information we reasonably need to verify the Request and to understand what is being asked.
9.4 We respond to your Request within the period prescribed by Applicable Law. Where Applicable Law permits a longer period, for example for a Request that is complex or one of several made together, we may take that longer period and will tell you that we are doing so.
9.5 We may refuse a Request, or comply with it only in part, where and to the extent Applicable Law permits or requires, including where:
(a) Applicable Law requires us to retain or continue processing the Personal Data;
(b) the Personal Data is needed to establish, exercise or defend legal claims;
(c) complying would adversely affect the rights of another person, including the Child or the Child’s other parent or guardian;
(d) the Request is manifestly unfounded, excessive or repetitive, including because it repeats a Request we have recently answered;
(e) complying would require us to disclose information that is confidential, legally privileged or commercially sensitive, to the extent Applicable Law permits us to withhold it; or
(f) we are unable to verify your identity or your authority to make the Request.
9.6 Where a Request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee reflecting our administrative cost of complying with it, or decline to act on it, to the extent Applicable Law permits. We will tell you before any fee applies, and you can then withdraw the Request.
9.7 If we refuse a Request in whole or in part, we tell you the reason, unless Applicable Law prohibits us from doing so.
9.8 Consequences of withdrawing consent. If you withdraw your consent, we stop the processing that relied on it. Depending on the stage reached, this may mean that we cannot respond to your enquiry, that a school visit, Open House place or trial day cannot be arranged or must be cancelled, or that an admission application cannot proceed and will be closed. Withdrawing consent does not affect processing we carry out on another legal basis, such as keeping records the law requires us to keep.
9.9 We respond to a Request through the Channel you used or another contact detail we hold for you. Where we provide a copy of Personal Data, we provide it electronically in a suitable format, where reasonably practicable.
9.10 If you are not satisfied with our response, you have the right to lodge a complaint with the institution responsible for personal data protection under the PDP Law. We would welcome the opportunity to resolve your concern first, although you are not required to give us one.
This Section explains the cookies and similar technologies the Website uses, and how you can control them.
10.1 Cookies are small text files that a website stores in your browser. Similar technologies include pixels, tags, local storage and scripts that perform a similar function. The Website uses cookies and similar technologies in the following categories:
(a) Strictly necessary cookies, which the Website needs to function and remain secure, for example to keep you signed in to the admissions portal, to make forms work and to protect the Website against automated abuse. These cookies are always active and typically expire at the end of your browsing session or shortly afterwards;
(b) Functional or preference cookies, which remember choices you have made, such as your preferred language, until they expire or you clear them;
(c) Analytics cookies, set by us or by our analytics service providers, which help us understand how visitors use the Website, such as the number of visits and the pages viewed; and
(d) Advertising cookies, set by us or by our advertising service providers, which help us measure whether visitors reach the Website from our advertising and improve its effectiveness.
Analytics and advertising cookies remain in your browser for the period set by the relevant service provider, unless you delete them earlier.
10.2 We rely on legitimate interest, as described in Section 4, for strictly necessary, analytics and advertising cookies. You can block or delete cookies at any time through your browser settings; your browser’s help pages explain how. Blocking or deleting cookies in your browser is the means available to you to control analytics and advertising cookies on the Website.
10.3 The Website continues to function if you block or delete analytics and advertising cookies. If you block strictly necessary cookies, parts of the Website, such as forms and the admissions portal, may not work.
10.4 We add, change and remove individual cookies and similar technologies within the categories in clause 10.1 from time to time without separate notice. If we begin to use a new category of cookies, we will update this Section 10.
10.5 Third-Party Services on which we advertise, or from which you follow a link to the Website, set their own cookies on their own sites. Those cookies are governed by the privacy terms of the Third-Party Service concerned, not by this Privacy Notice.
This Section describes how we protect Personal Data.
11.1 We use reasonable technical and organisational measures, appropriate to the nature of the Personal Data and the risks of the processing, to protect Personal Data against unauthorised or unlawful access, disclosure, alteration, loss and destruction. These include encryption, access controls and activity logging, and we review them from time to time. Access to Personal Data is limited to personnel and Processors who need it to perform their duties.
11.2 No method of transmitting information over the internet or by other electronic means, and no method of storing information, is completely secure. While we take the steps described in clause 11.1, we cannot guarantee the absolute security of Personal Data, and you provide Personal Data to us through electronic means in the knowledge of this risk.
11.3 The security of Personal Data held in the admissions portal also depends on you. Please keep your sign-in details confidential and tell us promptly, using the details in Section 16, if you believe they have been compromised. Your responsibilities for your account and sign-in details, and the circumstances in which we suspend or restrict access to the admissions portal or another Channel, are set out in the Terms of Use.
This Section explains what we do if the protection of your Personal Data fails.
12.1 GMS processes Personal Data in accordance with Applicable Law, and requires every Processor that processes Personal Data on its behalf to do the same.
12.2 In the event of a failure of Personal Data protection that affects your Personal Data, we will notify you and the relevant authorities in accordance with, and within the period prescribed by, applicable laws and regulations of the Republic of Indonesia.
12.3 Any such notice will contain the information required by applicable laws and regulations.
12.4 We give notice under clause 12.2 using the contact details we hold for you, so please keep those details up to date (see clause 5.5).
12.5 We give notice by any reasonable means, including email, a message to the telephone number we hold for you or, where Applicable Law requires or permits, a notice published on the Website.
12.6 We take the steps needed to contain, investigate and remedy a failure of Personal Data protection. These can include temporarily suspending access to a Channel, resetting sign-in details and asking you to take protective steps of your own.
12.7 Nothing in this Privacy Notice excludes or limits our liability under the PDP Law for unlawful processing of Personal Data, or your right to bring a claim and obtain compensation under the PDP Law.
This Section explains how we update this Privacy Notice.
13.1 We update this Privacy Notice from time to time, including to reflect changes in our activities, in the Channels, in the Processors we use or in Applicable Law. When we do, we publish the updated Privacy Notice on the Website and update the “Last updated” date at the top.
13.2 Editorial or clarifying changes, and changes required by Applicable Law, take effect on publication on the Website.
13.3 Where a change affects information we gave you when you gave your consent, we will notify you before it takes effect, in the manner required by the PDP Law. Where the PDP Law requires fresh consent for the changed processing, we will seek it before applying the change to Personal Data you have already provided.
This Section explains how this Privacy Notice relates to our other documents.
14.1 Terms of Use. Your use of the Website and our other online services, including the admissions portal, is governed by the Terms of Use. The Terms of Use address matters that are not about the protection of Personal Data, including accounts and sign-in details, acceptable use, the accuracy of information you submit, intellectual property, availability of the services, suspension and termination, Third-Party Services, disclaimers, limitation of liability, and governing law and disputes. In the event of any inconsistency between this Privacy Notice and the Terms of Use concerning the processing of Personal Data, this Privacy Notice prevails.
14.2 Point-of-collection statements. Where this Privacy Notice is inconsistent with a more specific privacy statement we give you under clause 1.7, the more specific statement applies to the collection it relates to. Nothing in any such statement reduces a right that Applicable Law gives you.
14.3 Enrolment documents. This Privacy Notice does not form part of the enrolment agreement unless that agreement expressly says so. The processing of Personal Data after enrolment is governed as described in clause 1.3(b).
This Section states the language and the law that govern this Privacy Notice.
15.1 This Privacy Notice is issued in English. We may, from time to time, make a translation available in another language for convenience. In the event of any inconsistency or difference in interpretation between the English version and a translation, the English version prevails, save to the extent that Applicable Law requires otherwise.
15.2 This Privacy Notice, and any dispute or claim arising out of or in connection with it, is governed by the laws of the Republic of Indonesia.
15.3 Nothing in this Privacy Notice limits any right you have under the PDP Law or other Applicable Law that cannot be limited by agreement.
This Section tells you how to reach us.
16.1 If you have any questions about this Privacy Notice or our processing of Personal Data, or wish to exercise any of your rights, please contact us:
Green Montessori School
Yayasan Pendidikan Green Montessori
Jalan Duren Tiga Raya No. 133, Pancoran, South Jakarta 12760, Indonesia
Email: legal@greenmontessori.sch.id
16.2 We keep a record of your Request and of our response for as long as is reasonably necessary to demonstrate our compliance with Applicable Law.
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