GSA Consulting Inc. and GSA Online International Pte. Ltd. (collectively or individually, the "Company") will acquire and handle a substantial amount of personal information of its clients, teachers and staff members because the Company provides English education and international education to its clients. The Company understands that appropriate management of personal information is the reason its clients feel secure about using the Company’s services, and the Company will appropriately protect all personal information provided to it in the course of its business, in recognition of the importance and highly confidential nature of such information.
1．Acquisition, Use and Provision of Personal Information
In our business of providing online English education/international education the Company will acquire and provide personal information appropriately, use personal information only to the extent necessary to achieve previously defined usage purposes, and take measures to prevent the use of personal information for purposes other than those previously defined. The Company may disclose or provide personal information to a third party for purposes of entrusting the handling of such information or for joint usage of such information, to the extent necessary for the smooth operation of its business. The Company will not provide personal information without the consent of the information principal, except in the cases described above or as required by applicable laws and regulations.
2．Compliance with Laws and Regulations, etc.
The Company will comply with the Act on the Protection of Personal Information and other related laws and regulations, guidelines, etc. in respect of the handling of personal information.
3．Implementation of Security Measures to Protect Personal Information
The Company will use efforts to prevent the loss, destruction, falsification, damage, leakage, etc. of personal information by educating each of its employees, to ensure the security and appropriateness of personal information handling. The Company will also undertake to detect inadequacies in the handling of personal information (if any) at an early stage through daily checks, internal audits, etc., and will endeavor to prevent any recurrence of such inadequacies by investigating the causes of any inadequacy and the taking of remedial measures.
4．Complaints and Questions regarding Handling of Personal Information
The Company will set up a point of contact and respond promptly and in good faith to any complaint, question, etc. regarding its handling of personal information.
5．Continuing Improvement of this Policy
The Company will regularly review this policy and make continuous efforts to improve it in order to achieve such level of personal information protection that corresponds to changes in the social environment, advancements in information technology, etc. as well as the business environment of the Company.
GSA Consulting Inc., GSA Online International Pte. Ltd.
Michio Montgomery, Representative Director
Date of enactment: September 30, 2014
Date of revision: April 1, 2019
Date of revision: January 14, 2020
Date of revision: January 28, 2021
Date of revision: February 24, 2021
Date of revision: April 26, 2021
The following is the point of contact for inquiries regarding personal information.
Complaints and inquiries regarding the handling of personal information should be directed to:
GSA Consulting Inc., GSA Online International Pte. Ltd.
The following table shows the purposes of the use of personal information the Company will acquire through its client or transactions, etc.
The Company’s clients (the "Users"), who use its online English education/international education, can confirm or change their registered personal information through the "Account Information" section, which will be displayed after logging in.
When Users register their membership by using the accounts of external service providers, we receive the Users' account information from the external service provider with the User's permission. If you register your membership by using an account of an external service provider, please confirm or change your personal information through the external service provider. You cannot confirm or modify this information through the "Account Information" section as detailed above.
GSA Consulting Inc., GSA Online International Pte. Ltd. and Global Educational Partners Inc. (collectively or individually, the "Company"), will manage the personal information concerning its users (the "Users") who utilize the online English education/international education services (the "Services") of the Company in accordance with this guideline (the "Guideline").
1. Personal Information
Personal information means any information (such as name, gender, date of birth and email address) or opinion about an identified or identifiable individual. Personal information also includes information which is not able to identify a person by itself, but can be readily collated with other information and thereby identify a specific individual.
The type of personal information the Company collects and holds may include:
(1) Users' name, address, contact details, date of birth, and documents that verify identity and other personal details;
(2) Users' financial information, such as payment history;
(3) details of the products and services the User has enquired about, or the Company has provided to the User; and
(4) records of our communications with you, including any complaints, requests or queries.
2. Possession of Personal Information
In this Guideline, personal information that the Company holds means the information which is provided by the Users when they register through the Company’s website, or that is provided as a result of other services. Information that is spontaneously provided by the Users during class or through personal contact with the Company's teachers outside class is not deemed to be information the Company possesses (Please refer to Section 11).
3. Purpose of Use of Personal Information
The Company will use the personal information to:
(1) plan, and notify students of, class schedules, etc.;
(2) deliver textbooks and other goods;
(3) distribute information regarding services (newsletter, campaigns and questionnaires, etc.);
(4) distribute information regarding services that the Company provides;
(5) grade examinations and analyze results;
(6) correctly understand opinions and inquiries about the Services, and to respond to them;
(7) educate operators on handling inquiries from users, in order to improve the quality of customer support services;
(8) research and analyze customer trends and product development;
(9) confirm the identity of the Users when disclosure of personal information is requested;
(10) contact Users and respond in emergency situations such as disasters; and
(11) settle fees for the use of services and collecting delayed payments, etc.
The Company will not use personal information for any purpose not described in this Guideline unless it obtains prior consent from the Users.
4. Protection and Management of Personal Information
The Company recognizes the importance of handling personal information and, to guarantee the right of the Users concerning their personal information, the Company will:
(1) comply with the Act on the Protection of Personal Information and related laws and regulations, which may include foreign privacy and data protection laws applicable the processing of personal information;
(2) take reasonable safety measures both from a technical and organizational perspective to prevent risks such as leakage, loss, defamation or falsification of personal information;
(3) set up a point of contact to respond to and settle any questions regarding its handling of personal information promptly and in good faith; and
(4) regularly review and continuously revise its information security system to ensure its appropriate handling of the personal information.
5. Outsourcing, Provision and Sharing of Personal Information to a Third Party
In principle, the Company will not outsource, provide or share personal information of the Users to a third party without obtaining the User's prior consent, except:
(1) in cases of joint usage as set forth in Section 6;
(2) where the Company provides personal information as part of its outsourcing of personal information handling, whether entirely or in part, to the extent necessary to achieve the purpose for which the personal information will be used;
(3) as set forth in Article 23, paragraph 1 of the Act on the Protection of Personal Information;
(4) where it is necessary to take measures, including legislative measures, in response to violations of the terms and conditions by the Users;
(5) where the Company receives a court warrant or effective order by a public institution such as the police to disclose information pursuant to applicable laws and regulations; and
(6) in any other case which fulfills the other requirements of applicable laws and regulations.
6. Joint Usage of Personal Information with Business Partners
The Company collaborates with business partners in order to provide each User with a more effective education. Therefore, the Company will use the Users’ information jointly with its business partners within the scope set forth below. The Company appreciates your understanding about joint usage as the Company continues its efforts to strictly manage joint use of personal information.
(1) Scope of personal data to be jointly used
Name, gender, date of birth, address, telephone number, email address, and records kept by the teachers in using our services.
[However, sensitive information is excluded.]
(2) Scope of joint users Educational business operators who are business partners of the Company whose services are to be used by the Users.
(Please see here and the following table for the list of business partners.)
[*The Company will not provide information to business partners who do not have a connection with the Users.]
(3) Purposes of use
(a)Creating curriculums, providing prior information to teachers, providing services such as analysis of the results of examinations.
(b)Distributing information in relation to services (newsletters, campaigns, surveys, etc.).
(c)Researching and analyzing customer trends and product development, etc.
(4) Entity responsible for managing personal data
Global Educational Partners Inc.
The Company will also jointly use the records made by its business partners when providing its service, in order to provide better services.
7. Accuracy of Personal Information
The Users are responsible for providing accurate and up-to-date personal information.
8. Modification and Deletion of Personal Information
The Users can confirm or modify their registered personal information through the "Edit Profile" section, which is on the right icon next to the Global Step Academy after logging in.
The Company will not modify any User's personal information without their permission.
Upon a User's request to end their membership, the Company will suspend use of the User's personal information. Please contact the Company by email (email@example.com) to request deletion of your personal information.
9. Requests for Disclosure
(1) When the Company receives a request for the disclosure of its retained personal data (under Article 2, Paragraph 7 of the Act on the Personal Information Protection or other applicable law), the Company will disclose the data to the User, except where there is a possibility of causing serious damage to the Company's proper business implementation or as permitted by applicable law.
(2) When the Company receives a request for the modification, addition or deletion of the contents of its retained personal data, the Company will conduct a necessary investigation to ensure that the purposes of its use of the date is being complied with, and modify the data based on the results of the investigation.
(3) When the Company receives a request for the suspension of use, deletion or suspension of provision to third parties of its retained personal data, the Company will suspend the use of such data if the request proves to be legitimate.
(4) For requests for disclosure set out in items (1) to (3) above, please contact the point of contact listed in Article 14.
(1) The Company uses behavioral targeting advertising (a means of distributing advertisements tailored to the needs and interests of the Users) to make its services known to more people.
(3) To display its advertisements on other Websites, the Company provides behavioral targeting advertising service providers ("Third-party Distributor(s)") with information obtained from Cookies on the Company’s Website.
11. Exclusion of Liabilities
(1) As set forth in Article 2, the information provided personally from the Users to teachers is not personal information collected by the Company and such information shall not be personal information to be protected and managed under this Guideline, unless required by applicable local law. To the extent permissible under applicable local law, the Company is not liable for any leak or loss of such information.
(2) The Company’s Website may contain links to other Websites, and the Users are responsible for confirming how personal information is being handled on the linked Websites. The Users shall use the Company’s Website at their own responsibility. The Company is not liable for any damage that may arise from the use of various information obtained from the Company’s Website and from any other Website linked to the Company’s Website.
12. Compliance with COPPA
The Company is in compliance with the Children's Online Privacy Protection Act of 1998 (COPPA), a United States federal law.
13. Revision of this Guideline
Except where required by laws and regulations, the Company may revise this Guideline from time to time by announcing the revision on its website, without obtaining the prior consent of the Users.
14. The point of contact for complaints, inquiries regarding the handling of personal information and requests for access or correction is:
Global Educational Partners Inc.
602 Azabudai Hinoki Bldg.
3-1-5 Azabudai, Minato-ku
106-0041 Tokyo, Japan