Privacy Policy
PRIVACY POLICY OF JWAHER AL-ARABIYAH ACADEMY SDN.BHD.
This Privacy Policy (the “Policy”), an integral part of the JWAHER AL-ARABIYAH ACADEMY SDN.BHD General Terms and
Conditions, explains how JWAHER AL-ARABIYAH ACADEMY SDN.BHD.
hereinafter: “JWAHER AL-ARABIYAH ACADEMY SDN.BHD”, “Company”, “we”, or “us”)
collects, stores, uses, and discloses personal information from its users and their students
(“you”, “user”) in connection with our online learning service (“Online Classes”) and
website located at jwaher-edu.com and it’s subdomains (the “Website”), as well as in
JWAHER AL-ARABIYAH ACADEMY SDN.BHD’s mobile application (“Application”) operated by the Company including registering an account for your child on the Website (“Registration”) and virtual chatting
with JWAHER AL-ARABIYAH ACADEMY SDN.BHD (“Chatting”). This Policy also contains information about the collecting of the
personal data regarding the natural persons who apply as teachers to JWAHER AL-ARABIYAH ACADEMY SDN.BHD (“Applying
as a Teacher”).
The processing and collecting of personal data by JWAHER AL-ARABIYAH ACADEMY SDN.BHD shall be in harmony with the
directly applicable data protection laws in effect:
(i) In case of personal data processing, the Regulation (EU) 2016/679 of the
European Parliament and of the Council (hereinafter: “GDPR”), furthermore the
recommendations of the Article 29 Data Protection Working Party (hereinafter:
“WP29”) and of the European Data Protection Board (hereinafter: “EDPB”) shall
apply.
(ii) For the collection and processing of personal data of Brazilian individuals, Brazil’s
Law No. 13,709, of August 14, 2018 on the Brazilian General Data Protection Act (in
Portuguese: Lei Geral de Proteção de Dados, hereinafter: “LGPD”) shall apply.
(iii) Furthermore, in respect of Californian individuals JWAHER AL-ARABIYAH ACADEMY SDN.BHD complies with the
Senate Bill No. 1121 California Consumer Privacy Act of 2018 (hereinafter:
“CCPA”).
(iv) For the collection and processing of personal data of individuals residing in other
countries, where the personal data regulations are in place and apply to the foreign
entities, JWAHER AL-ARABIYAH ACADEMY SDN.BHD is in compliance with those regulations as well.
The Company is the data controller of any data which constitutes personal data, and which
is uploaded when using our services.
The Company bound in honor to protect personal data, especially children’s personal data;
therefore, the Company will keep confidential the personal data received and take all
necessary steps to secure data processing.
Before you or your child starts using JWAHER AL-ARABIYAH ACADEMY SDN.BHD, we want to make sure you understand how JWAHER AL-ARABIYAH ACADEMY SDN.BHD
collects and uses your personal information and what rights are available for you and your
child in relation your personal data. Please make sure that you read JWAHER AL-ARABIYAH ACADEMY SDN.BHD Children’s
privacy policy, an integral part of the JWAHER AL-ARABIYAH ACADEMY SDN.BHD General Terms and Conditions, (hereinafter:
“Children’s Policy”) for your child before he or she starts the online classes.
Please read and make sure you understand this Policy. If you do not agree with this Policy
or our practices, you may not use our Website or our services.
1. DEFINITIONS
The following definitions are determined according to the GDPR:
‘personal data’: shall mean any information relating to an identified or identifiable natural
person (‘data subject’); an identifiable natural person is one who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘consent’: shall mean any freely given, specific, informed and unambiguous indication of
the will of the Data Subject by which he or she, by a statement or by a clear affirmative
action, signifies agreement to the processing of personal data relating to him or her;
‘data controller’: shall mean the natural or legal person, public authority, agency or other
body which, alone or jointly with others, determines the purposes and means of the
processing of personal data; where the purposes and means of such processing are
determined by European Union or Member State law, the controller or the specific criteria
for its nomination may be provided for by Union or Member State law;
‘data processing’: shall mean any operation or set of operations which is performed on
personal data or on sets of personal data, whether or not by automated means, such as
collection, recording, organization, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction;
‘data processor’: shall mean a natural or legal person, public authority, agency or other
body which processes personal data on behalf of the controller;
‘third party’: shall mean a natural or legal person, public authority, agency or body other
than the data subject, controller, processor and persons who, under the direct authority of
the controller or processor, are authorized to process personal data;
‘personal data breach’: shall mean a breach of security leading to the accidental or
unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data
transmitted, stored or otherwise processed;
‘recipient’: shall mean a natural or legal person, public authority, agency or another body,
to which the personal data are disclosed, whether a third party or not. However, public
authorities which may receive personal data in the framework of a particular inquiry in
accordance with European Union or Member State law shall not be regarded as recipients;
the processing of those data by those public authorities shall be in compliance with the
applicable data protection rules according to the purposes of the processing;
‘supervisory authority’: shall mean one or more independent public authorities provided
by each Member State which is responsible for monitoring the application of the GDPR in
order to protect the fundamental rights and freedoms of natural persons in relation to
processing and to facilitate the free flow of personal data within the European Union;
‘supervisory authority concerned’: shall mean a supervisory authority which is concerned
by the processing of personal data because: (a) the controller or processor is established
on the territory of the Member State of that supervisory authority; (b) data subjects residing
in the Member State of that supervisory authority are substantially affected or likely to be
substantially affected by the processing; or (c) a complaint has been lodged with that
supervisory authority.
2. WHAT INFORMATION DOES JWAHER AL-ARABIYAH ACADEMY SDN.BHD COLLECT?
The information we gather from users enables JWAHER AL-ARABIYAH ACADEMY SDN.BHD to personalize and improve the
services, to allow the users to set up accounts on the Website or get information about our
services. We collect the following types of information from our Teachers and Users:
2.1 Information you provide to us:
2.1.1 At Registration:
We collect the following personal data uploaded during the registration on the Website:
● Full name,
● Birthdate
● Gender,
● E-mail address,
● Phone number.
● personal photo
Please note that the e-mail address provided does not require the inclusion of personal
data, such as your name. You are free to choose an e-mail address that contains
information about your identity.
After the Registration you must add the following personal data to your JWAHER AL-ARABIYAH ACADEMY SDN.BHD Account in
order to use our services:
● Your our your children’s data (name, age, gender).
2.1.2 While Chatting:
We collect the following personal data uploaded during the Chatting on the Website:
● E-mail address,
● Any other personal information provided by you during Chatting.
2.1.3 When participating in Online Classes:
We collect the following personal data uploaded during Online Classes:
● Video (including audio) of the participants of Online Classes,
● Parental, sibling and extended family details,
● Homework or any educational progress submitted via the Website,
● Attendance,
● Level of proficiency in Arabic language,
● Any other personal data shared directly or indirectly during Online Classes (including
but not limited to personal information of third parties, racial or ethnic origin, religion
or beliefs).
2.1.4 When Applying as a Teacher:
We collect the following personal data uploaded during Applying as a Teacher:
● Full name
● Teaching experience
● Photo and video about the data subject,
● Birthday (age),
● Languages spoken,
● Gender,
● E-mail address,
● Nationality,
● Social media pages,
● Phone number
● Previous work experience,
● Educational information,
● Residency information,
● Information on other teaching certificates.
2.2 Information Collected Automatically:
We receive and store certain types of information whenever you interact with our Website,
services or Application.
2.2.1 When using the Website
JWAHER AL-ARABIYAH ACADEMY SDN.BHD automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain
and other system settings, search queries, device characteristics, operating system type,
language preferences, referring URLs, actions taken on our Website, page requested,
content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits,
gender, age range, approximate location and other information associated with other files
stored on your device.
2.2.2 When using the Application
JWAHER AL-ARABIYAH ACADEMY SDN.BHD automatically receives and records information on our server logs from your phone you installed the Application on, including usage information related to it: the date and time you access the Application, activities in the Application, time spent in the Application and its
regularity, visited content, search terms used, links clicked/tapped on.
3. WHAT ABOUT COOKIES?
The Company processes anonymous data in order to improve the Website, to bring it to
perfection. During this procedure JWAHER AL-ARABIYAH ACADEMY SDN.BHD can incorporate “cookies”, which collect the
visitor’s first level domain name, the date and the exact time of access and other
informations. The “cookie” alone can’t be used to reveal the identity of the visitor. The
“cookie” is a small text file, which is sent to the browser of the visitor and stored on the hard
drive of visitor. Cookies don’t damage the computer of the visitor. The browser can be set to
indicate when a cookie is received, so the visitor can decide to accept the so-called cookie
or not. The Company does not use cookies to collect or manage any information that would
allow the identification of the user. For further information, please read our Cookie Policy, an
integral part of the JWAHER AL-ARABIYAH ACADEMY SDN.BHD General Terms and Conditions.
4. HOW DOES JWAHER AL-ARABIYAH ACADEMY SDN.BHD USE THE COLLECTED INFORMATION?
We may use the information we collected, including your and/or your children’s personal
information - based on diverse purposes as well as the legal basis of the processing - as
follows:
4.1. We process the following personal data for the purpose and on the legal basis of the
performance of the contract, product and service fulfillment:
● Full name,
● Children’s name,
● Children’s age,
● Children’s gender,
● E-mail address,
● Phone number.
The above obligatory or optional personal data you provide is used for purposes such as
fulfilling the obligations defined in the Terms of Use and providing the service, responding to
your questions, requests relating to the service, customizing the visualized content,
communicating with you about sales offers relating to special services and new features,
and responding to problems relating to our services.
4.2. We process the following personal information based on the legitimate interest of the
Company (as the legal basis of this processing) for marketing purposes and to deliver
e-mails:
● Full name,
● Email address.
● Phone number,
● Any other personal data provided to the data processors of JWAHER AL-ARABIYAH ACADEMY SDN.BHD.
Whenever JWAHER AL-ARABIYAH ACADEMY SDN.BHD processes data for its legitimate interest, JWAHER AL-ARABIYAH ACADEMY SDN.BHD always keeps your
personal data rights in high regard and will take them in account. The users always have
the right to object to this processing. However, objecting against such data processing might
affect JWAHER AL-ARABIYAH ACADEMY SDN.BHD’s ability to carry out tasks above for the benefit of the user.
4.3. We process personal data for the purpose and on the legal basis of compliance with
legal obligations to prevent fraudulent transactions, monitor against theft and otherwise
protect our customers and our business. We also process personal data for the purpose
and on the legal basis of legal compliance and to assist law enforcement and respond to
subpoenas.
This means that in some cases the data processing is stipulated by the applicable laws and
we have an obligation to process and keep this data for the required time. This includes
employment data, billing data, data which is necessary to assist law enforcement etc.
4.4. We process the following personal data for the purpose and on the legal basis of the
legitimate interests of the Company, to improve the effectiveness of the Website, our
services, and marketing efforts, to conduct research and analysis, including focus groups
and surveys and to perform other business activities as needed, or as described elsewhere
in this Policy:
● IP address,
● Browser information,
● Contact information,
● Content consumed on the Website,
● Unique device identifier,
● Browser characteristics,
● Domain and other system settings,
● Search queries,
● Device characteristics,
● Operating system type,
● Language preferences,
● Referring URLs,
● Actions taken on our Website,
● Page requested,
● Content consumed (e.g., viewed, uploaded, and shared),
● Dates and times of Website visits,
● The link that you have been redirected to our Website from,
● Gender,
● Age range,
● Approximate Location,
● The type of web browser used,
● Actions taken in the Application,
● Dates and times of using the Application,
● Time spent in the Application and the regularity of your visits,
● Other software and hardware information
● Other information associated with other files stored on your device
Where it is feasible, we anonymize personal data or use non-identifiable statistical data. We
do not collect personal data in advance and store it for potential future purposes unless
required or permitted by the applicable laws.
For collecting anonymously, the above-mentioned data and making statistics and analysis
we may use the following software and programs:
Name Registered seat Country
Google Analytics
and Google
AdWords (Google
LLC.)
4.5. Data integrity and purpose limitation: JWAHER AL-ARABIYAH ACADEMY SDN.BHD will only collect and retain personal
data which is relevant to the purposes for which the data is collected, and we will not use it
in a way that is incompatible with such purposes unless such use has been subsequently
authorized by you. We will take reasonable steps to ensure that personal data is reliable for
its intended use, accurate, complete and current. We may occasionally contact you to
determine that your data is still accurate and current. To secure your personal information
processed we save your personal information to backup archives in every 24 hours. The
data stored in our backup archives will be deleted in 3 years.
5. HOW LONG WE RETAIN YOUR PERSONAL DATA?
We will retain your personal data for so long as it is needed to fulfill the purposes outlined in
this Policy or until you withdraw your consent, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements, further for the
establishment, exercise or defense of legal claims). When we have no longer or no legal
basis to process your personal information, we will either delete or anonymize it, or, if this is
not possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from any
further processing until deletion is possible.
6. WILL JWAHER AL-ARABIYAH ACADEMY SDN.BHD SHARE ANY OF THE INFORMATION IT RECEIVES?
Information about our users is an integral part of our business, and we may share such
information with our affiliated entities. Except as expressly described below, we neither rent
nor sell your information to other people or nonaffiliated companies unless we have your
permission.
6.1. JWAHER AL-ARABIYAH ACADEMY SDN.BHD shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when data transfer is necessary for the
performance of the contract or for enforcing of JWAHER AL-ARABIYAH ACADEMY SDN.BHD’s legitimate interest or prescribed by
law.
6.2. Every teacher working for JWAHER AL-ARABIYAH ACADEMY SDN.BHD is considered as a data processor according to the regulations of the GDPR. The teachers have access only to the personal data of the
children they are teaching in order to minimize the processing of personal data.
6.3. JWAHER AL-ARABIYAH ACADEMY SDN.BHD may share certain personal information with third party vendors in the EU or in
third countries, who supply software applications, web hosting and other technologies or
services for the Website and our services (hereinafter: “Data Processor”). The Company will
only provide these third parties with access to information that is reasonably necessary to
perform their work or comply with the law. Those third parties will never use such
information for any other purpose except to provide services in connection with the Website
and our services. During the service of data process, the Data Processor shall abide under
the present Policy, relevant legislations in force, furthermore the provisions of the existing
contracts between him and JWAHER AL-ARABIYAH ACADEMY SDN.BHD.
6.4. Stripe Inc., Intercom Inc. and Google LLC comply with the EU-US and the EU-Swiss
Privacy Shield Frameworks, therefore transfer of your personal data to the aforementioned
service providers was deemed safe until July 16, 2020. Please note that according to the
judgement no. C-311/18 of the Court of Justice of the European Union, these companies no
longer considered to provide appropriate safeguards for the personal data of European
citizens. For more information, you can read the judgement here.
6.5. We only transfer personal data collected from individuals located within the EU only
with the consent of the individuals to a third-party having a registered seat outside the EU /
in the USA acting as a data processor without the appropriate safeguards set out in the
GDPR, or when it is necessary for the performance of the contract. JWAHER AL-ARABIYAH ACADEMY SDN.BHD will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.
7. IS INFORMATION ABOUT ME SECURE?
We take commercially reasonable measures to protect all collected information from loss,
theft, misuse and unauthorized access, disclosure, alteration and destruction. Please
understand that you can help keep your information secure by choosing and protecting your
password appropriately, not sharing your password and preventing others from using your
computer. Please understand that no security system is perfect and, as such, we cannot
guarantee the security of the Website, or that your information won’t be intercepted while
being transmitted to us. If we learn of a security systems breach, then we may either post a
notice, or attempt to notify you by email and will take reasonable steps to remedy the
breach.
8. CHILDREN’S PRIVACY
8.1 JWAHER AL-ARABIYAH ACADEMY SDN.BHD is committed to protecting the privacy of children who use our services including our Website and Application.
This Policy and JWAHER AL-ARABIYAH ACADEMY SDN.BHD’s privacy practices are in accordance with the United State’s
Children's Online Privacy Protection Act of 1998 (“COPPA”) as well as the Council of
Europe’s Recommendation CM/Rec(2018)7 of the Committee of Ministers to member
States on Guidelines to respect, protect and fulfil the rights of the child in the digital
environment (“Guidelines”).
For information on how to protect your child’s privacy online please make sure to read the
following documents before Registering on the Website:
● The Federal Trade Commission’s guidelines on Protecting Your Child’s Privacy
Online,
● UNESCO’s guidance for students, teachers and parents on personal data and
privacy protection in online learning.
8.2. At Registration, JWAHER AL-ARABIYAH ACADEMY SDN.BHD obtains the consent of the statutory representative for collecting the personal data of minors. JWAHER AL-ARABIYAH ACADEMY SDN.BHD asks for the phone number and e-mail of
the statutory representative to make sure that no child Registers on the Website. JWAHER AL-ARABIYAH ACADEMY SDN.BHD does not collect personal information directly from children at Registration. If we learn that we have collected personal information directly from a child under 16 without the consent of their statutory representative, we will take steps to delete such information from our files as
soon as possible. If you are aware of anyone under 16 registered the Website, please
contact us at support@jwaher-edu.com.
8.3. At any time, you can withdraw your consent of JWAHER AL-ARABIYAH ACADEMY SDN.BHD collecting further personal information from your child and can request that we delete the personal information we
have collected in connection with you or your child from our records. You can request the
deletion of your data by connecting JWAHER AL-ARABIYAH ACADEMY SDN.BHD via the chat services after you logged in.
Please keep in mind that a request to delete records may lead to termination of your
Account which disables the accessibility of Online Classes in the future.
8.4. As your and your child’s personal data are processed by the Teachers of JWAHER AL-ARABIYAH ACADEMY SDN.BHD, we concluded a data processing contract with them in order to prevent fraudulent or
inappropriate activities as well as to regulate the Teacher’s data processing activities during
the providing of our Services. If you think that a Teacher steps over legal and/or ethical
limitations during the data processing or he or she processes your data incorrectly or
unlawfully, please contact us at support@jwaher-edu.com.
9. YOU AND YOUR CHILD’S PRIVACY RIGHTS
9.1. Access and Retention:
If you have an account registered on the Website, you can log in to view and update your
account information. You have the right to obtain confirmation of whether or not we are
processing personal data relating to you or your child, have communicated to you such data
so that you could verify its accuracy and the lawfulness of the processing and have the data
corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.
We encourage you to contact us at support@jwaher-edu.com with your questions or
concerns, or to request edits to your and your child’s personal information, or to have it
removed from our database. Requests to access, change or remove to any personal data
you provided to us will be handled within 30 days.
9.2. Additional Rights for EU Territory:
If you are from the territory of the EU, you may have the right to exercise additional rights
available to you under applicable laws, including:
(a) Right of Erasure: In certain circumstances, you may have a broader right to
erasure of personal information that we hold about you – for example, if it is no
longer necessary in relation to the purposes for which it was originally collected.
Please note, however, that we may need to retain certain information for record
keeping purposes, to complete transactions or to comply with our legal obligations.
(b) Right to Object to Processing: You may have the right to request JWAHER AL-ARABIYAH ACADEMY SDN.BHD to stop processing your personal information and/or to stop sending you marketing
communications.
(c) Right to Restrict Processing: You may have the right to request that we restrict
processing of your personal information in certain circumstances (for example,
where you believe that the personal information, we hold about you is inaccurate or
unlawfully held).
(d) Right to Data Portability: In certain circumstances, you may have the right to be
provided with your personal information in a structured, machine readable and
commonly used format and to request that we transfer the personal information to
another data controller without hindrance.
9.3. Additional Rights for Brazilian individuals
If you are a Brazilian individual, you have the following rights in addition to the rights
described in section 9.1 of this Policy:
(a) Right of erasure: If you would exercise this right, we will respond to you
immediately, or if that is not possible, we will send a reply to you to indicate the
reasons of fact or law that prevents the immediate adoption of the measure. If we are
not the data processors of the data you requested the erasure of – whenever
possible – we will indicate who the processing agent is.
(b) Right to be informed: You have the right to obtain information about what types
of processing do we carry out on your personal information.
(c) Right of access: If you request the providing of your personal data processed by
us, we will grant you access to such data in 15 days of your request, if the data
requested is more than the simplified request version.
(d) Nondiscrimination: We do not process your data for unlawful or abusive
discriminatory purposes. In certain circumstances, you have the right to request a
review of our data processing and the supervisory authority (the Brazilian National
Authority for Protection of Data (hereinafter: “ANPD”)) may carry out an audit to
verify discriminatory aspects.
(e) Data portability: Your data might be transferred to another service or product
supplier in accordance with the regulations of the ANPD and as subjects to
commercial and industrial secrets..
10. MODIFICATIONS TO THIS POLICY
We will modify this Policy if our privacy practices change. We will post a modified version at
Jwaher-edu.com and notify you of such changes in a system message or in an e-mail
sent to the e-mail address provided in the User Account.
11. FOR CALIFORNIA USERS
If you are a user in California, the Company's Privacy Notice for California Consumers
applies to you.
We will not share any personal data with third parties for their direct marketing purposes to
the extent prohibited by California Consumer Privacy Act of 2018 (CCPA). If our practices
change, we will do so in accordance with applicable laws and will notify you in advance.
Questions
If you have any questions concerning this Policy or the services, please contact us at
support@jwaher-edu.com. You can also contact us at our contact office at 8954, 24000 kemaman, Terengganu, Malaysia.