1. Definitions

The term “Personal Data” refers to any information which identifies you or can be used to identify a data subject when used in conjunction with other information. Common examples of personal data could include name, identification number and contact information. 

The term “Data Subject” describes the person about whom the personal data is about.   

The term “PDPA” describes Personal Data Protection Act B.E. 2562 of Thailand.

The term “Process” describes the how we collect, use, store or disclose personal data directly from the data subject concerned (or often in the case of students, from their parents). In some cases, we collect data from third parties (e.g. referees/references, previous schools) or from publicly available resources.  

2. Purpose of use

Your privacy is important to us. Julia Gabriel Bangkok (JGBKK) and/or Boundless Enrichment Co., Ltd hope that the policy outlined below shall help you understand what data is collected, how it is used, how the data is safe guarded and with whom it may be shared. 

Generally, JGBKK collects personal data in order to fulfil the following purposes:

• To respond and process enquiries on courses, registration and admission matters and activities.
• To facilitate provision of education and enrichment to our students, including the administration of our curriculum; monitoring and reporting student progress and wellbeing.
• To provide a safe and secure environment for students, staff, and visitors to the school.
• To assess and improve the quality of our educational services.
• To meet the school’s operational management, including the compilation of student records and the administration of invoices, fees and accounts.
• To relate promotional offers relating to the programmes and events at our centres.
• To analyse website traffic, demographic, and behaviour using analytical tools and cookies.
• Any updates relating to Julia Gabriel Bangkok (JGBKK) and/or Boundless Enrichment Co., Ltd which may be relevant in maintaining or managing our ongoing relationship with you.

JGBKK 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.

On a regular basis we take photographs, video, and audio recordings (digital media) of our students’ learning. Our lawful basis for processing this information is consent and/or legitimate interests. Our legitimate interest in using this digital media is for classroom displays, to celebrate student achievement and to promote the school through our school publications and media channels. We follow our Safeguarding Policy regarding media comprising students that is shared on school media channels.  

3. Scope

This data privacy notice applies to:

• Staff (Academic and Business) or individuals employed by JGBKK and/or Boundless Enrichment Co., Ltd in any capacity, including full-time and part-time employees.
• Students that are current, prospective, or prior students enrolled at the school.
• Parents that are current, prospective, or prior parents, and/or legal guardians, of a student(s) at JGBKK and/or Boundless Enrichment Co., Ltd.
• Third parties that are referred as individuals or organisations that are not affiliated with or employed by the school.

4. Data Collected

The type of personal data, namely personal data, and sensitive personal data, in which we collect, use, or disclose, varies on the scope of products and/or services that you may have used or had an interest in. The type of personal data shall include but is not limited to:

• Personal details (Given name, Middle name, Surname, Nickname (if any), Gender, Date of birth). 
• Contact details (Mailing address, E-mail addresses, Phone numbers and Fax numbers).
• Identification and authentication details (ID card photo, ID number, Passport information, Birth Certificate/Alien ID information, Driving license and Signatures).
• Financial details and information about your relationship with us (Bank accounts, Payment details and Transaction History).
• Assessment details (Assessment results and Reports).
• Biodata (Behaviour, Gender, Marital status, Ethnic group and Special educational needs).
• Medical information (Any relevant medical information).
• Photographs/video materials (CCTV images, Video or Audio recordings, Visual images, Personal appearance and Body Temperature Sensor with Face capture).

5. Sharing Data with Third Parties

Normally, we will collect your personal data directly from you, but sometimes we may get it from other sources, in such case we will ensure compliance with the PDPA. Additionally, we may disclose your personal data to the Third Parties under the provisions of the PDPA.

All authorised Third Parties shall sign a contract or a letter of undertaking with JGBKK 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

Generally, JGBKK 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 Thailand
• 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 JGBKK’s websites or services with the permission of their parent or guardian. Except where required by local law, JGBKK will not knowingly collect personal information provided by children and minors.

7. Data Retention & Removal 

All personal data is securely stored in accordance with the PDPA requirements. We retain your personal data only for legitimate purposes, relying on one or more of the lawful bases as set out above, and only for so long as necessary for those purposes, or as required by law.

8. Accuracy, Access and Correction

JGBKK 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 JGBKK. If you wish to access your personal data with JGBKK, you may send a written request to enquiries.bkk@juliagabriel.co.th.

As part of our security measures, JGBKK 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

You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us unless the nature of consent does not allow such withdrawal. The withdrawal of consent will not affect the lawfulness of the collection, use, or disclosure of your personal data based on your consent before it was withdrawn. You can review and change your consent to use or disclose your personal data for marketing purposes through submitting a written request to us at enquiries.bkk@juliagabriel.co.th.

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 JGBKK information, reminders, invoices or notices pertaining to your child(ren)’s classes and other information that is necessary for JGBKK to communicate with you regards to your child(ren).

10. Data Security

JGBKK 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 enquiries.bkk@juliagabriel.co.th.

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. JGBKK 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 provided 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

JGBKK 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 JGBKK’s Privacy Policy does not cover these other websites.

14. Updates to the Policy

JGBKK 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. 

15. Contact Us

If you have any comments or questions about our Privacy Policy, you may contact JGBKK by email at enquiries.bkk@juliagabriel.co.th.