Privacy Policy

1. Introduction

This document is about how personal information is collected about you and your child or children’s study with us and how we use and look after it. It sets out the detail about how the personal information provided will be used and looked after and explains your rights in relation to it.

2. Our commitment to you

Our commitment is to:

Keep personal information about you and your child or children safe and private;
Not use personal information for any purpose other than in connection with your children’s studies, keeping you informed of information about the Kumon business, to continue to develop the Kumon business to deliver the most effective and rewarding student experience possible and in accordance with the other purposes set out in this notice;
Make it easy for you to approach us if you have any concerns or questions relating to the holding of personal information;
Not provide personal information to others save where legally required to do so or to assist us with our tasks.

3. Who we are and how we operate

Kumon is a leading supplementary education provider in Europe and worldwide, and offers Maths and English study programmes for children of all ages and abilities.
Kumon Deutschland GmbH (Kumon Deutschland) has 140 Learning Centres operated by Instructors across Germany, Greece, France, Poland, Romania, Belgium, Bulgaria, Czech, Luxembourg, Netherlands, Austria, Hungary, Croatia, Cyprus, Slovakia and Switzerland.
Kumon Deutschland’s head office is located in Düsseldorf, Germany. The structure works through a system of franchise agreements such that each Learning Centre is operated by a separate franchise holder known as the Instructor.
The Instructor is responsible for and motivated to provide the Kumon study programme at the highest level possible at his or her Learning Centre supported at all times by Kumon Deutschland. Kumon Deutschland supplies each Instructor with the study programmes and material together with such other support as the Instructor requires to run his or her Learning Centre.
Kumon Deutschland interacts closely with each Learning Centre and often visits them in a continuing process of seeking to refine and improve the effectiveness of the study programmes and the student experience. Learning is offered in person at the Learning Centre, Kumon Connect (a web application) and online, for example by Zoom (or via other video communications technology).
There is currently one Learning Centre located in Düsseldorf, Germany, (Düsseldorf Learning Centre) and one other located in Ilioupoli, Greece, (Ilioupoli Learning Centre) which are each owned and run by Kumon Deutschland. For the purposes of this Privacy Notice the Education Centre Manager at the Kumon run Learning Centres are also included in the phrase Instructor.
To operate effectively the Instructor and Kumon Deutschland require personal information concerning parents and legal guardians (parents) and the students. We set out in this Privacy Notice what personal information is collected and how it is used.
The term Data Controller is applied to a business which determines how personal information about yourself and your child or children is used.
Your study programme Instructor is known as a Data Controller.
Kumon Deutschland also requires personal information for similar, but slightly different purposes. As such Kumon Deutschland is also a Data Controller, but a separate one. The contact details of the individual with overall responsibility for personal information held by Kumon Deutschland are set out in the Schedule to this Privacy Notice.

4. How information is collected from you

Information in relation to parents and students will be collected by the Instructor or by the Instructor’s assistants on the Instructor’s behalf and/or by Kumon Deutschland. This might be achieved by providing information verbally, whether face to face or by telephone, completion of paper documents or by electronic means such as through email or interaction with our websites or use of an on-line platform for enrolling or making enquiries known as E-Enrolment. Please ensure that all personal information is accurately provided as the information which is held is only as accurate as the information provided in the first place.
If any of the personal information provided changes please notify the Instructor or as appropriate Kumon Deutschland as soon as possible in order that the personal information can be updated.

5. The Instructor

5.1. What personal information will the Instructor collect from you?

The Instructor will require the following information about the student:

Name;
Address;
Contact details;
Date of birth;
Schooling related information;
Gender;
Health related information and other information relevant to being able to teach the student most effectively;
As the student’s studies progress the Instructor will accumulate information in relation to the student’s work and its progression.

Information which will be required from parents/legal guardians:

Name;
Contact details;
Payment details;
Relationship to student;
Details of others who are authorised points of contact in the event that primary contact is not available;
Any other information which may be provided, and which is relevant to the education of your children.

The Instructor may also ask for or receive contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and which language is most suitable for communication.
The Instructor will not seek any further personal information in relation to parents or students without gaining specific authority.
The Instructor will not take or publish photographs of students or publish student names without your consent as the parent/legal guardian.

5.2. Who will the Instructor provide personal information to?

The Instructor will provide the personal information referred to above to Kumon Deutschland for it to use for the purposes set out in this Privacy Notice.
The Instructor will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators or unless it is otherwise provided for in this Privacy Notice.

5.3. What about outsourcing by the Instructor?

It is possible that the Instructor will pass personal information to other organisations to assist him or her. This is not for other organisations to use on their behalf but rather to process information on the Instructor’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, training and printing.

5.4. What will the Instructor use personal information for?

To fulfil his or her contractual obligations towards the parents/guardians and to respond to enquiries (the processing of personal data of the parents/guardians is based on Art. 6 (1) (b) GDPR; the processing of personal data of students is based on Art. 6 (1) (f) GDPR, the Instructor’s legitimate interest is to fulfil the contractual obligations towards the parents/guardians):

to provide the course of study;
administer the course of study;
ensure the quality of the programmes;
to respond to enquiries about the study offered;
to seek feedback about study experiences;
to address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;
to record and/or report upon the progress of the student;
to consider, record and communicate other issues which may be impacting upon or related to the progress of the student;
to respond to complaints.

To ensure vital interests (Art. 6 (1) (d) GDPR):
This relates to the health and safety of a student. For example, if there was a medical emergency the Instructor may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.

To comply with Legal Duties (Art. 6 (1) (c) GDPR):
The Instructor may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

When legitimate interests apply (Art. 6 (1) (f) GDPR):
It is possible that from time to time the Instructor may wish to communicate with parents concerning other matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:

to communicate about potential career opportunities with the Instructor;
providing news updates about developments at the Learning Centre or within Kumon Deutschland. This might for example be in relation to changes to the Kumon programme, information relating to it, educational meetings, progress review meetings and reports;
to communicate about particular study opportunities and useful information about Kumon study, for example particular trials, promotions and campaigns.

Any communication under this heading will be of the nature referred to above. The Instructor will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.
If you do not wish to receive communications under this heading please let the Instructor know which type of communications you would not wish to receive.

When you consent (Art. 6 (1) (a) GDPR):
There are certain uses to which the Instructor will not put personal information without your specific consent. Where such consent is requested it will be sought separately. This will apply to taking photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies.
If consent is given it can be withdrawn at any time by providing notification to the Instructor in writing or by email.
Other:

Based on its legitimate interests, the Instructor also processes personal data:
for management and statistical purposes to enable better running of our Learning Centres;
to ensure the quality of the programmes;
to seek feedback about study experiences; and
for document retention for evidence purposes for the establishment, exercise and defence of legal claims.

6. Kumon Deutschland

6.1. What personal information may Kumon Deutschland collect from you directly?

We have already indicated what information the Instructor may collect from you and provide to Kumon Deutschland. At any Kumon Deutschland Learning Centre it will use the information for the same purposes as the Instructor as described above.
Sometimes early exchanges of information will be with Kumon Deutschland rather than with the Instructor. This section deals with those and other circumstances.
In such circumstances Kumon Deutschland is likely to require the following information about the student:

Name;
Address;
Contact details;
Date of birth;
Schooling related information;
Gender.

Also, Kumon Deutschland is likely to require the following information from parents/legal guardians:

Name;
Contact details;
Relationship to student;
Details of others who are authorised points of contact if primary contact is not available;
Any other information which may be provided and which is relevant to the education of your children.

When undertaking visits to Learning Centres Kumon Deutschland may also require or obtain contextual information about students and/or their parents. This might, for example, relate to the student’s lifestyle, interests and skills, be about the student’s family including the structure of it and the occupation of the parent(s), any background issues that may be impacting upon the student’s study and which language is most suitable for communication.

6.2. Who will Kumon Deutschland provide personal information to?

Kumon Deutschland will provide the personal information referred to in the preceding paragraph to the Instructor to use for the purposes set out above.
Kumon provides learning opportunities in various countries and regions around the world. As a part of our operations as a global organisation, personal data may be shared from time to time between Kumon Group companies.
Due to the importance of personal data protection, and the fact that data protection regulations differ by country and region, the Kumon Group has established Binding Corporate Rules (“BCRs”) as one of the ways we ensure personal data is handled safely and in compliance with international privacy laws.
The BCRs establish principles for protecting personal data originating in the European Economic Area and the rules we follow for sharing that personal data with Kumon Group companies outside the European Economic Area. In particular, to Kumon Europe & Africa Limited based in the UK and Kumon Institute of Education Co., Ltd. based in Japan.
More information can be found in the Binding Corporate Rules Controller & Processor Policies: https://www.kumongroup.com/eng/bcr/
On occasion, Kumon Deutschland’s parent company, Kumon Institute of Education Co. Limited which is based in Japan may seek student data for statistical purposes and to assist it in refining and further developing (i) Instructor and employee training and (ii) the materials and instruction techniques. Kumon Institute of Education Co. processes the data in a statistical manner and no personally identifiable data is retained any longer than 24 months after your child or children have ceased to attend a Learning Centre without a legitimate reason to do so. We will ensure that appropriate technical and organisation measures are in place such that this data is shared with Kumon Institute of Education Co. in a secure way and that it is stored in a secure way.
Please note that on 23rd of January 2019 came into effect an Adequacy decision of the European Commission, allowing European Economic Area originating personal data to flow freely between European Economic Area countries and Japan. Hence, any data transfers to Kumon Institute of Education Co. will be conducted in accordance with this Adequacy Decision.
You can obtain this adequacy decision under: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.076.01.0001.01.ENG&toc=OJ:L:2019:076:TOC
Kumon Deutschland will not provide personal information for use by anyone else without your specific consent or unless this is necessary for health and safety reasons, to comply with child protection policies and procedures, or otherwise in relation to child welfare and child protection, for example in cooperating with local and public authorities to comply with legal requirements and those of regulators or unless it is otherwise provided for in this Privacy Notice.

6.3. What about outsourcing by Kumon Deutschland?

It is possible that Kumon Deutschland will pass personal information to other organisations to assist it. This is not for the other organisations to use on their behalf but rather to process information on Kumon Deutschland’s behalf. This will be for the efficient and effective administration and running of the business and provision of the study programme for example for IT needs including for the purposes of establishing, developing and maintaining relevant databases including the data collection system and customer relationship management, but also for purposes such as book-keeping and accounting, printing and training. This might include the transfer of personal information outside of the European Union and if this is the case security measures will be taken to protect the integrity and security of the data.

6.4. What will Kumon Deutschland use personal information for?

The Instructor has day-to-day responsibility for the operation of the Learning Centre and interaction with parents and students. However, there will be times when for one reason or another an Instructor is not able to undertake a task when Kumon Deutschland may step in to aid and in so doing will make use of the personal information. Kumon Deutschland will also use personal information to seek to refine and improve the effectiveness of the study programme and the student experience.
Kumon Deutschland may therefore use personal information for the following purposes:

For its legitimate interest to help the Instructor fulfil contractual obligations and to respond to enquiries (Art. 6 (1) (f) GDPR):

to provide the course of study;
administer the course of study;
ensure the quality of the programmes;
to provide support to Instructors;
to respond to enquiries about the study offered;
to seek feedback about study experiences;
to address and communicate about operational issues such as the need to close a class suddenly, for example because of illness or bad weather or the need to address and make parents aware of changes to classes, for example new venues, dates and times;
to record and/or report upon the progress of the student;
to record and communicate other issues which may be impacting upon the progress of the student;
to notify of changes to the Centre, for example a change in Instructor;
providing continuity in the Learning Centre, for example in the event of the Instructor no longer being available for one reason or another and whether on a temporary or permanent basis;
to respond to complaints.

To ensure vital interests (Art. 6 (1) (d) GDPR):
This relates to the health and safety of a student. For example, if there was a medical emergency Kumon Deutschland may need to provide relevant medical information about a student to the emergency services. Similarly, information may be provided to local or public authorities where welfare and child protection issues arise.
To comply with Legal Duties (Art. 6 (1) (c) GDPR):
Kumon Deutschland may in very rare circumstances be required by child welfare and child protection issues to provide information to local or public authorities including the police.

When legitimate interests apply (Art. 6 (1) (f) GDPR):

This falls into two broad categories:

Work undertaken in refining and improving the effectiveness of the study programme and improving the student experience; and
Communicating news including news in relation to Kumon Deutschland’s operation, study and franchise opportunities.

The first category includes:

research and development purposes;
market research for establishing new Learning Centres and/or helping existing Learning Centres;
training of prospective, new and experienced Instructors and employees;
performance analysis;
support for students who wish to transfer between Learning Centres;
to facilitate the transfer of students (including their information) in the course of a Learning Centre takeover.

Any processing of personal information under this category will be of the nature referred to above. Kumon Deutschland will not process personal information under this category where there is any perceived detriment to you or your children in undertaking the processing.
Kumon Deutschland may need to process some personal information of this nature for measurement and statistical purposes as referred to under the ‘Other’ heading but if you do not wish Kumon Deutschland to process personal information for the above purposes please contact Kumon Deutschland using the contact details set out in the Schedule.

The second category:
It is possible that from time to time Kumon Deutschland may wish to communicate with parents concerning matters which may be of interest to them or where they may know of others who may have an interest. The nature of such contact will be:

to communicate about potential career opportunities with the Instructor;
providing news updates about developments at the Learning Centre or within Kumon Deutschland;
to communicate about particular study opportunities and useful information about Kumon study, for example particular trials, promotions and campaigns;
in relation to franchise or other career opportunities;
provision of information and consultation in relation to Learning Centres which may be of relevance to your child or children.

Any communication under this category will be of the nature referred to above. Kumon Deutschland will not communicate to you under this heading where there is any perceived detriment to you in receiving the communication.
If you do not wish Kumon Deutschland to process personal information for the above purposes please contact Kumon Deutschland using the contact details set out in the Schedule.

When you consent (Art. 6 (1) (a) GDPR):
There are certain uses to which Kumon Deutschland will not put personal information without your specific consent. Where such consent is requested it will be sought separately. For example; in taking photographs of the children and using children’s names and/or photographs in publicity material and/or publication of children’s names in relation to results and award ceremonies and using your children in case studies for training purposes.

If consent is given it can be withdrawn at any time by providing notification to Kumon Deutschland in writing or by email.

Other:
Based on its legitimate Interests, Kumon Deutschland also processes personal data:
for management and statistical purposes to enable better running of our Learning Centres;
to ensure the quality of the programmes;
to seek feedback about study experiences; and
for document retention for evidence purposes for the establishment, exercise and defence of legal claims.

6.5. What happens if I do not wish to provide personal information to the Instructor and Kumon Deutschland?

The Instructor and Kumon Deutschland require the personal information set out in this privacy notice in order to ensure that the Kumon programme can be safely and effectively delivered to your children and continually developed and improved for the benefit of your children. Without this information it will not be possible to deliver the services for the benefit of your children or at least not as well as we would like. We have though set out above some purposes for which either the Instructor or Kumon Deutschland wish to use personal information under the heading of “Legitimate interests”. If you do have an objection to any personal information being used under this heading you may object to either the Instructor, Kumon Deutschland or both. If either the Instructor or Kumon Deutschland wish to gather personal information for which consent is required they will obtain that specific consent before gathering that information and you have the right not to provide such information.

7. How long will you keep personal information for?

The Instructor and Kumon Deutschland will only retain personal information:

For as long as necessary to fulfil the purposes it was collected for as set out in this Privacy Notice;
In relation to those that enquire about the services which we can provide but don’t go on to use them we would not normally keep that information for longer than 12 months after the last communication from the enquirer;
Whilst your children are studying at the Learning Centre it is necessary for us to retain the personal information. Thereafter we will not normally keep it for longer than 24 months after your children have ceased to attend a Learning Centre unless we have legitimate reasons, including child protection reasons for doing otherwise;
In some circumstances you have the right to request erasure of personal information held. This will be addressed below.

8. Your rights in relation to the information held in respect to you or your children

Access — the right to make what is known as a Subject Access Request for a copy of the personal information which we hold about you or your child and the information listed in Art. 15 GDPR. If you make such a request we are required, in most circumstances, to provide a copy of the personal information without charge and without undue delay and in any event within one month of receipt of the request.
Correction — it is important that you keep the Instructor up to date with any changes to the personal information provided. Subject to that you have the right to ask the Instructor or Kumon Deutschland, as appropriate, to correct or complete any inaccurate or incomplete data held about you or your children. It is possible that evidence will be required of the new information provided.
Erasure — you are entitled to ask either the Instructor or Kumon Deutschland to delete or remove personal information held where there is no good reason for the Instructor or Kumon Deutschland to continue to hold it. It may not always be possible to comply with your request due to ongoing obligations in relation to the personal information. However, where this is the case you will be informed and be told of the reasons why it is not possible to comply with the request.
Objection to processing — you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point Art. 6 (1) (e) or (f) GDPR, including profiling based on those provisions. In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.
Restriction of processing — you may ask us to restrict processing of personal information in the following situations:

If you want the data accuracy to be established;
Where the use of the personal information is unlawful, but you do not want it to be erased;
Where we do no longer need the data, but you may need it to establish, exercise, or defend legal claims; or
You have objected to the use of the data by us, but we need time to determine whether it has overriding legitimate grounds to process it.

Request the transfer of information (data portability) — you have the right to request a transfer of personal information held to you or to other organisations in a structured, commonly used and machine-readable format. This right only applies to personal information which is processed by automated means and is held either because it was necessary for the performance of the contract with you and/or is processed based upon your specific consent.
Right to lodge a complaint with a supervisory authority — you have the right to lodge a complaint with a supervisory authority in case you consider that the processing of personal data relating to you infringes the GDPR.
Information (including contact details) for each European Union (including the European Economic Area states) national data protection authorities, and the corresponding European Data Protection Supervisor can be found further within this Privacy Notice.

9. Keeping personal information safe

The Instructor and Kumon Deutschland have put in place appropriate security measures to prevent the personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal information is limited to those employees and contractors who have a business need to know the personal information and will only be processed upon instructions from either the Instructor or Kumon Deutschland (as appropriate) and procedures have been put in place to deal with any suspected breach of the requirements under the Data Protection laws and you and/or the Regulator referred to below will be notified of any potentially significant breach.

10. What happens if you want to complain?

It is hoped that you will not have cause to complain. If you do, complaints relating to the Instructor should be referred to the Instructor where possible and any complaints in relation to Kumon Deutschland should be referred to the person named in the Schedule where possible. If it is not possible or appropriate to refer a complaint to the Instructor or Kumon Deutschland it may be referred to the Regulator. This will vary depending on where you are based in Europe.
Information (including contact details) for each European Union (including the European Economic Area states) national data protection authorities, and the corresponding European Data Protection Supervisor can be found in the provided link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

11. Miscellaneous

It is not anticipated that any personal information will be transferred outside of the European Union save where specifically set out in this Notice. We will notify you if this position changes.
Neither the Instructor nor Kumon Deutschland anticipate using automated decision making in relation to the personal information provided.
This Privacy Notice may be updated from time to time. The latest Privacy Notice will be displayed on corresponding Instructor and Kumon websites.

12. Google Analytics Demographics and Interest Reporting

Kumon uses Google Analytics's 1st party cookies with Google's 3rd party advertising cookies together to provide additional information on Remarketing with Google Analytics, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. Opt-Out: https://tools.google.com/dlpage/gaoptout

13. If I have any questions, who do I ask?

Please ask your Instructor or contact Kumon Deutschland using the details in the Schedule.

Schedule
Contact information

KUMON Deutschland:
Data Protection Manager

KUMON Deutschland GmbH
Wiesenstraße 21
40549 Düsseldorf
Germany

Telephone: +49 211 522858-0
Email: info@kumon.de

Updated: December 2024

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