KOMUM ONLINE TUTORS PH
DATA PRIVACY NOTICE
Protecting your personal data privacy is of paramount importance to KOMUM.
We, at KOMUM, are committed to protect and respect your personal data privacy, and we are dedicated to comply with and fully implement the provisions of the law which protects primarily safeguard the personal information of persons particularly known as the Data Privacy Act of 2012.
1. Definition of Material Terms
a. “Account” as used in this notice refers to the user profile created by the User and/or Client, in order to avail of any of KOMUM’s services.
b. “Client” a User who registered and created in account by providing information, including your name, email address, residence, phone number, and creates/submits a username and password.
c. “Cookies” as are data files that are placed on your device or computer and often include an anonymous unique identifier.
d. “Data Subject” means an individual whose personal, sensitive personal, or privileged information is processed.
e. “Log files” track actions occurring on the Service, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
f. “Mobile App” refers to any of KOMUM’s online applications which may be downloaded through Google Play, or through the Apple App Store.
g. “Personal Information” or “Personal Data” refers to any information, whether recorded in material form or not, from which the identity of an individual is apparent or can be reasonably ascertained by the entity holding information, or when put together with other information would directly and certainly identify the individual.
h. “Personal Information Controller” refers to natural or juridical persons, or any other body who controls the processing of personal data, or instructs another to process personal data on its behalf. The terms exclude:
i. “Personal Information Processor” refers to any natural or juridical person or any other body whom a personal information controller may outsource or instruct the processing of personal data pertaining to a data subject;
j. “Sensitive Personal Information” refers to personal information pertaining to:
k. “User” as used in this notice, refers to a person who accesses the Website and registers as a User.
l. “Visitor” refers to any person who uses KOMUM’s website, other than as a User or account holder.
2. About KOMUM ONLINE TUTORS PH
KOMUM provides online tutorial services worldwide.
3. How KOMUM Collects Personal Data
Whenever Users and/or Clients access or register to our mobile app or website, you necessarily share with us your personal data which we may use in providing you with our services.
As a User
If you are a User we collect from you the following Personal Data when you use or register on our website, or use and register through any of our mobile apps, or avail of our services:
c. Email address;
d. Mobile Number;
e. Date of Birth;
f. Civil Status
g. Address, current location;
h. Payment Information, including credit card numbers;
i. Image of ID for verification;
j. Personal photo for verification.
k. Social Media account (Facebook, Messenger, Viber)
When you register on our website or through any of our mobile apps, you may be required to fill up online forms which will ask you to provide information marked as “Required Fields,” in which case, you must provide the information and agree to the processing of such personal data by KOMUM. If you do not agree to provide the information in the “Required Fields,” KOMUM will not be able to provide its services to you, and your registration, and subsequent use of the website or any of our mobile apps may be denied.
From Users and/or Client
By Downloading the App, or Registering thru our Website - When a User or a Client registers in our website, we collect the following Personal Data which are necessary and reasonable for the performance of our services, which may necessarily include:
c. Email address;
d. Mobile Number;
e. Date of Birth;
f. Address, current location, including ZIP Code;
g. Payment Information, including credit card numbers;
h. Image of ID for verification;
i. Personal photo for Verification.
j. Social Media account (Facebook, Messenger, Viber)
4. KOMUM’s Services
KOMUM provides online tutorial services worldwide. KOMUM helps students from Kindergarten to Adults by providing tutorial services that aims to improve their grades, assist in school lessons and homework, provide enrichment classes on a specific subject, learn a foreign language, and engage in online extra-curricular activities.
5. Use and Utilization of Information
KOMUM only uses your Personal Data and other information for legitimate purposes and transactions which are necessarily involved in managing and developing its website or any of its mobile apps, and providing you with its services, and conducting its business, which includes but not limited to:
a. Enrolling a student
b. Providing payment confirmations
d. Providing feedbacks
We use information for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Service, these third parties include the teacher/s assigned to the student. We may use and retain any data we collect to provide and improve our services.
When you share your Personal Data with KOMUM, we may use the same to send you marketing and/or promotional materials, and corporate giveaways/gifts from time to time. You may opt to stop receiving our messages by informing us through sending an email, or messaging us through our website or through any of our mobile apps.
Location Information – KOMUM collects information from your devices (computers, mobile phones, tablets, etc.), including information about how you interact with our services and information that allows us to recognize and associate your activity across devices and services. This information includes device specific identifiers and information such as location, IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data. We may recognize your devices to provide you with personalized experiences and advertising across the devices you use. In addition, the information may also include your location.
Transaction Information - We likewise collect transaction details related to your use of our Services, including the, date and time the service was provided, amount charged, type of service requested and other related transaction details.
Device Information - We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and various, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
Log Information - When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
Information from Cookies and Other Tracking Methods – KOMUM employs cookies, web beacons and other tracking technologies to speed your navigation of the Platform, recognize you and your access privileges, and track your Platform usage. These help us in Platform analytics to give you a better experience. The same may be used to evaluate the success of our advertising campaigns. This includes information, but is not limited to, tracking how frequently you visit our Platform and use our services, time spent on the Platform, pages visited, links clicked, among others.
We may use third-party advertising companies to help us tailor site content to users or to serve ads on our behalf. These companies may employ cookies and web beacons to measure advertising effectiveness (such as which web pages are visited or what products are purchased and in what amount). Any information that these third parties collect via cookies and web beacons is not linked to any personal information collected by us. We may transfer and store the information described in this section for processing to our third party partners. In the said event, we commit to do the appropriate measures as sanctioned by law to protect your personal information accordingly.
6. Information Sharing
We may disclose and market aggregated information about users of our Services, and aggregated information collected via our Services, that does not relate to an identified or identifiable natural person, consumer or household without restriction, except if other prohibited by applicable law.
Through Our Services We may share your information:
• Between Teacher/s assigned to the student;
• KOMUM staff charged with research and development;
• Organizations or groups partnered with KOMUM for purposes of career improvement and related service enhancements;
• For the purpose of studying and sharing trends, we may share aggregated or pseudonymous information (including demographic information), that is limited to non-personally identifiable information, with partners, measurement analytics, apps, third party ad networks, or media.
• To contractors, service providers, aggregators and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of KOMUM’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by KOMUM about our users is among the assets transferred.
• With the general public if such information were made public such as in social media posts, comments on articles or other features of our Services that are of the public domain;
• With third parties with whom you choose to let us share information.
Other Important Sharing we may share your information:
• With KOMUM subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
• With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of KOMUM or others; • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• If we otherwise notify you and you consent to the sharing; and
• In an aggregated and/or anonymized form which cannot reasonably be used to identify you.
Social Sharing Features
We may integrate a social sharing features and similar tools which may allow you to share the information you provided us to a third person or the public, such as the information as to the class, class picture, student outputs, etc., through the use of other apps, sites, or media. For this purpose, the rules, terms and conditions, and privacy notice that will govern will solely depend on the settings you establish with the said social sharing service. You understand that KOMUM should not be made liable for any event that damage or liability to a user arises by virtue of the use of the third party tool or app.
7. Cookies and other Tracking Technologies
8. Storage and Security of Personal Information
All information gathered from the website is stored on a secured database server based in the Philippines. KOMUM has undertaken appropriate technological, organizational, and physical security measures to protect any and all information shared with it, from unauthorized access, unauthorized alteration, and unauthorized disclosure.
9. Retention Period
KOMUM shall not store and retain Personal Data and other information gathered for a period longer than necessary, and without the consent of Its users. KOMUM shall only keep any personal information, and store and use the same for so long as the User or Users has active transactions with KOMUM.
10. Updating Personal Information
Users may update their information by accessing their account through the website, or through any of their respective mobile apps.
Users may also ask KOMUM to delete or modify their personal information, which have been stored in the Database servers. Should a User wish to ask for a copy of their information stored with KOMUM, they may communicate with KOMUM through the contact information provided in its website or mobile app.
11. Your Rights Under the Data Privacy Act
KOMUM respects the rights of Data Subjects which primarily includes its Users.
As a Data Subject, you have the following rights in connection with the Processing of your Personal Information:
A. The right to be informed
B. The right to object
C. The right to access
D. The right to rectification
E. The right to erasure or blocking
F. The right to damages
G. The right to data portability
A. Right to be Informed
You have the right to be informed, as to whether the Personal Information pertaining to you, shall be, are being, or have been processed.
As a Data Subject, you shall be notified and furnished with information indicated hereunder before the entry of your Personal Information into the records of KOMUM:
a. Description of the Personal Data or information to be entered into the system;
b. Purposes for which they are being or will be processed, including Processing for direct marketing, profiling or historical, statistical or scientific purpose;
c. Basis of Processing, when Processing is not based on your consent;
d. Scope and method of the Personal Data Processing;
e. The recipients or classes of recipients to whom the Personal Data are or may be disclosed or shared;
f. Methods utilized for automated access, if the same is allowed by the Data Subject, and the extent to which such access is authorized, including meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for the Data Subject;
g. The identity and contact details of the DPO;
h. The period for which the Personal Data will be stored; and
i. The existence of your rights as Data Subjects, including the right to access, correction, and to object to the Processing, as well as the right to lodge a complaint before the National Privacy Commission.
B. Right to Object
You have the right to object to the Processing of your Personal Information, including Processing for direct marketing, automated Processing or profiling.
You also have the right to be given notice, and opportunity to withhold your consent to the processing of your Personal Information, in case there are changes to the information which have been supplied to you by KOMUM relating to direct marketing, automated processing or profiling.
Should you withhold consent, KOMUM shall no longer process your Personal Information or Personal Data, unless:
The Personal Data is needed pursuant to a subpoena;
1. The Processing is for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which the Data Subject is a party, or when necessary or desirable in the context of an employer-employee relationship between KOMUM and the Data Subject; or
2. The Personal Data is being collected and processed to comply with a legal obligation.
C. Right to Access
You have the right to reasonable access to, upon demand, the following:
1. Contents of your Personal Data that were processed;
2. Sources from which Personal Data were obtained;
3. Names and addresses of recipients of the Personal Data;
4. Manner by which your Personal Data were processed;
5. Reasons for the disclosure of the Personal Data to recipients, if any;
6. Information on automated processes where the Personal Data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you;
7. Date when Personal Data concerning you were last accessed and modified; and 8. The designation, name or identity, and address of the DPO.
D. Right to Rectification
You have the right to dispute the inaccuracy or rectify the error in your Personal Data, and KOMUM shall correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the Personal Data has been corrected, KOMUM shall ensure the accessibility of both the new and the retracted Personal Data and the simultaneous receipt of the new and the retracted Personal Data by the intended recipients thereof: Provided, That recipients or third parties who have previously received such processed Personal Data shall be informed of its inaccuracy and its rectification, upon your reasonable request.
E. Right to Erasure or Blocking
You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Data from KOMUM’s filing system.
1. This right may be exercised upon discovery and substantial proof of any of the following:
(a) The Personal Data is incomplete, outdated, false, or unlawfully obtained;
(b) The Personal Data is being used for purpose not authorized by the Data Subject;
(c) The Personal Data is no longer necessary for the purposes for which they were collected;
(d) You withdraw your consent or you object to the Processing, and there is no other legal ground or overriding legitimate interest for the Processing by the Company;
(e) The Personal Data concerns private information that is prejudicial to you, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
(f) The Processing is unlawful; or
(g) Your rights have been violated.
2. The DPO may notify third parties who have previously received such processed Personal Data that you have withdrawn your consent to the Processing thereof upon your reasonable request.
F. Right to Damages
You have the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
G. Right to Data Portability
Where personal information is processed by electronic means, and in a structured and commonly used format, you have the right to obtain from the personal information controller a copy of data undergoing processing in an electronic or structure format, which is commonly used and allows for further use.
Participation of Data Subjects
KOMUM encourages its Users take an active role in the protection of their Personal Data, and the Users are welcome to any further suggestions that they may make in order to protect their Personal Information when they avail of KOMUM’s services.
Users may freely opt not to disclose some of their Personal data, however, there are personal information which, by the nature of the services being offered by KOMUM, are required to be disclosed to KOMUM in order for the User to avail of the said service. Should the User refuse to disclose such necessary information, KOMUM may not be able to fully provide the User with its services, and its application or registration may be rejected.
If you do not agree with the collection, and processing of your personal information, as discussed in this Notice, you must stop using KOMUM’s website or any of its platforms.
12. External Links
There may be instances where the website would show or post hyperlinks leading to other external websites on the Internet.
These hyperlinks may lead to other websites and webpages which are published, and operated by third parties which are not connected to KOMUM, but are included in our website to enhance your user experience, and presented for information purposes.
KOMUM endeavors to select only reputable websites and sources of information for the convenience of its Users or Shippers.
Unless clearly stated by KOMUM, by providing the hyperlinks to other websites, KOMUM shall not be deemed to have endorsed, approved, recommended, advertised, approved, or guaranteed, these third party websites as well as their products or services posted or advertised in their websites.
KOMUM does not also have any partnership, cooperation, or agreement with these third party publishers, unless otherwise stated.
KOMUM is not responsible for any content of the websites where the hyperlinks are linked to.
Should you choose to click and follow any of these links, KOMUM shall not be responsible for any risks, damages, or losses which you may incur or suffer, arising out of or in connection with your use of their link.
Any information which you may divulge with the websites in the said links is the liability of the said website publisher or owner, and shall in no case be the liability of KOMUM.
KOMUM’s Privacy Notice is effective as of May 2020 and until such time that the same is updated.
14. Acceptance of this Data Privacy Notice
This Data Privacy Notice applies to all Personal Data which we may collect from you. By accessing our website, or by using any of our mobile applications, or by providing us with your personal data, you warrant that you have read and understood the contents of this Data Privacy Notice and accept its contents, fully knowledgeable of the effects and consequences of using our website.
You also agree that by using and registering with our website or by using any of our mobile apps, or availing any of our services, that your Personal Data may be collected, used, stored, and shared to accredited third parties, and that you have given your consent to the said collection, use, storing, and sharing of your Personal Data.
If you do not agree with this Privacy Notice, please do not use our website or any of our mobile apps, or provide us with any Personal Data.
KOMUM reserves the right to amend this Privacy Statement to remain compliant with any changes in law and regulations, and to reflect how our business processes personal data.
Should you have any questions, clarification, and inquiries about your Privacy Notice, you may contact us through our Data Protection Officer:
Contact Number : 0917-1132905
Email Address : firstname.lastname@example.org
We are happy to announce that
KOMuM now cultivates minds across the world! We have students in the U.S, Australia, Indonesia, Thailand and the Philippines.
KOMuM has also launched the 'Find My Tutor' App, the first of its kind in the Philippines.