Personal Data Protection Policy (Privacy Policy)

This policy applies to the EngPath website and platform, including the English learning management system for primary education and services related to using the system.

People covered by this policy are:

• Primary school students or learners
• Teachers
• School administrators and executives
• System administrators
• School staff who are granted access to the system
• Parents or guardians of students, where relevant

EngPath may collect personal data necessary to provide the service, in the following categories:

EngPath collects and uses personal data for the following purposes:

1. 1To create and manage user accounts
2. 2To manage data on students, teachers, classes and schools
3. 3To provide English lessons for primary education
4. 4To support the management of learning plans and teaching materials
5. 5To provide Digital Teaching Slides and Worksheets
6. 6To run pre-tests and post-tests
7. 7To record, review and assess student scores
8. 8To produce dashboards and learning reports
9. 9To enable teachers and schools to track student progress
10. 10To produce learning statistics and performance reports
11. 11To keep the system secure and monitor its use
12. 12To provide technical support and resolve usage problems
13. 13To comply with applicable laws and requirements

EngPath will not use personal data beyond the stated purposes unless there is a legal basis for doing so or consent has been obtained as required by law.

EngPath collects, uses or discloses personal data under appropriate legal bases, such as:

• Necessity for performing a contract or providing the service to the data subject
• Necessity for complying with the law
• Necessity for legitimate interests, without unduly affecting the rights and freedoms of the data subject
• Consent of the data subject, where the law requires consent

EngPath determines the appropriate legal basis according to the type of data, the purpose and the nature of each processing activity.

EngPath gives special attention to protecting the personal data of primary school students, who are children and minors.

Students' personal data is collected, used or disclosed with the rights, privacy and best interests of the child as the primary consideration.

Where the law requires consent from a parent or guardian, EngPath will provide a consent procedure in line with the legal requirements.

EngPath will not use students' personal data for inappropriate marketing purposes, and will restrict access to student data to authorised people who need it for their work.

EngPath may disclose personal data to relevant people or organisations only as necessary to provide the service and under an appropriate legal basis, namely:

EngPath will not sell the personal data of students or users to outside parties for commercial purposes.

EngPath stores data on a cloud system to support use by many students, teachers and schools at the same time.

Personal data is kept only as long as necessary to provide the service, assess and monitor learning, and comply with applicable laws or requirements.

Usage history and logs needed to monitor and assess learning are kept for the specified period; the project TOR requires that learning can be monitored and assessed for at least 3 years.

When the retention period ends or the data is no longer needed, EngPath will delete or destroy it, or make it non-identifiable, as appropriate and in line with legal requirements.

EngPath has security measures for personal data to prevent unauthorised access, use, alteration, loss or disclosure.

These measures include:

• Assigning data access rights by role and duty
• Restricting access to student data and scores
• Securing user accounts
• Preventing unauthorised access to the system
• Logging usage history and important activities (Log)
• Data backup and recovery
• Securing data transmitted over the network
• Reviewing and improving security measures as appropriate

Data subjects have the rights provided by law, namely:

1. 1The right to access and obtain a copy of their personal data
2. 2The right to have their personal data corrected so it is accurate and up to date
3. 3The right to request deletion or destruction of their personal data, or to make it non-identifiable, subject to legal conditions
4. 4The right to request restriction of the use of their personal data
5. 5The right to object to the processing of their personal data
6. 6The right to receive their personal data, or have it transferred, in the form required by law
7. 7The right to withdraw consent where processing is based on consent
8. 8The right to lodge a complaint with the authority empowered by law

Exercising these rights may be subject to conditions, exceptions and limitations under the law.

If a personal data breach occurs, EngPath will investigate, assess the risk, contain or remedy the incident, and notify the relevant authority or data subjects in accordance with the conditions and time limits set by law.

EngPath will maintain an approach for responding to such incidents to limit their impact and prevent them from happening again.

EngPath may update or amend this policy to reflect changes in its services, technology, laws or operating practices.

When there is a material change, EngPath will publish the updated policy on the website or platform and inform users as appropriate.

If data subjects have questions, would like details about how data is processed, or wish to exercise their legal rights, they can contact us through the following channels:

Platform service provider

บริษัท เกียรติเกษม จำกัด (Kiatkasem Co., Ltd.)

Address

1651/1 Moo 6, U Thong Subdistrict, U Thong District, Suphan Buri 72160, Thailand

Email

somkiat1607@hotmail.com

Website

www.engpathlearning.com

Data Protection Officer (DPO)

สมเกียรติ มงคลไพบูลย์ (Somkiat Mongkolpaiboon) · Tel. +66 81 868 0398

EngPath will consider and act on requests concerning personal data within the time limits and conditions set by law.