PRIVACY POLICY

PURPOSE AND SCOPE

City Educare is committed to protecting the privacy, confidentiality and security of personal information entrusted to
it. This policy explains what information City Educare may collect, why it is collected, how it may be used, when it
may be shared and how it is protected.
This policy applies to information handled in connection with City Educare’s educational, training, administrative,
recruitment, student-support, communication, marketing and online activities.

INFORMATION WE COLLECT

Depending on the service or relationship, City Educare may collect information reasonably required for the relevant
purpose, including:
• Identity Information: Full name, photograph, date of birth, gender where relevant and identification details.
• Contact Information: Mobile number, email address, residential/postal address and emergency contact details.
• Academic & Training Information: Qualifications, certificates, course details, attendance, assessments,
assignments, lesson plans, practical records and completion status.
• Application Information: Information submitted for admission, course registration, internships, employment or
other opportunities.
• Payment Information: Fee records, transaction references, invoices, refunds and accounting information. Full
card or banking credentials should not be unnecessarily stored.
• Employment Information: CV/resume details, qualifications, experience, joining information, attendance,
performance and payroll-related records where applicable.
• Technical Information: IP address, browser/device information, log data, website interactions and cookie
information where applicable.
• Communication Information: Emails, messages, support requests, feedback and complaints.
• Photographs & Media: Photographs, videos or event records where collected for legitimate educational,
administrative or promotional purposes, subject to applicable permissions.

SOURCES OF INFORMATION

City Educare may obtain information:
• Directly from the individual through forms, applications, enrolment or communication.
• From parents/guardians or authorised representatives where appropriate.
• From educational or training records and authorised employees/trainers.
• From payment or service providers where necessary.
• Automatically through authorised websites and digital systems.

HOW WE USE YOUR INFORMATION

City Educare uses personal information for legitimate educational, operational, administrative and business
purposes, including:
• Processing admissions, registrations, enrolments and course applications.
• Maintaining student, trainee, employee and administrative records.
• Delivering classes, training, workshops, internships, assessments and support services.
• Recording attendance, participation, assignments, practical work and assessments.

• Issuing certificates, letters, receipts and other authorised documents.
• Communicating schedules, classes, fees, deadlines, academic updates and events.
• Processing fees, refunds, invoices and accounting records.
• Verifying identity, qualifications and submitted documents where necessary.
• Recruiting, onboarding and managing employees, trainers, interns and contractors.
• Improving educational programmes, customer service, website functionality and internal processes.
• Preventing fraud, misuse, unauthorised access and other security risks.
• Complying with applicable legal, regulatory, tax and accounting requirements.
• Responding to enquiries, complaints, disputes and requests.

LEGAL AND BUSINESS PURPOSES

City Educare will handle information on an appropriate and lawful basis. Depending on the circumstances, this may
include:
• Consent provided by the individual where consent is required.
• Providing a service, course or other agreed activity.
• Complying with a legal or regulatory obligation.
• Protecting legitimate business, security or operational interests.
• Any other lawful basis available under applicable requirements.
Where consent is used, City Educare will aim to clearly explain the purpose and, where applicable, provide a
reasonable way to withdraw consent.

ADMISSIONS, ENROLMENT AND TRAINING RECORDS

City Educare may maintain records relating to registration, course selection, attendance, fees, academic progress,
assessments, assignments, practical work, certificates and communications.
• Access is limited to authorised personnel who reasonably require the information for their role.
• Records may be retained to support certificates, verification, academic administration, dispute resolution and legal
requirements.
• Information should be used only for appropriate educational and administrative purposes

EMPLOYEE AND TRAINER INFORMATION

City Educare may collect information about employees, trainers, interns, consultants and applicants for:
• Recruitment and verification.
• Onboarding and scheduling.
• Attendance and performance management.
• Payroll and statutory requirements.
• Internal administration and professional development.
Employment information will be accessible only to authorised persons with a legitimate business need.

COMMUNICATION AND MARKETING

City Educare may contact individuals regarding classes, course schedules, fee reminders, academic updates,
support matters, events and services connected with an existing relationship.
• Promotional communications will be handled in accordance with applicable consent requirements.
• Individuals may request that promotional communications stop where applicable.
• Essential academic, service and administrative communications may continue when necessary

SHARING AND DISCLOSURE OF INFORMATION

City Educare does not intend to sell personal information as a commercial product. Information may be shared only
for legitimate and appropriate purposes, including:
• Authorised City Educare employees, trainers and administrators.
• Parents or guardians where appropriate and legally permitted.
• Payment, accounting, technology, hosting and other authorised service providers.
• Government, regulatory, tax or law-enforcement authorities where required or permitted by law.
• Professional advisers, auditors or legal representatives where reasonably necessary.
• Where required to establish, exercise or defend legal rights.
• In connection with a business restructuring, merger, acquisition or transfer, subject to appropriate safeguards

SERVICE PROVIDERS AND THIRD PARTIES

City Educare may use third-party providers for hosting, cloud storage, communication, payment processing,
accounting, website services, analytics, learning tools and other operational functions.
• Service providers should be required, where appropriate, to handle information only for authorised purposes.
• Reasonable contractual and organisational safeguards should be used where applicable.
• Independent third-party websites and applications may have their own privacy policies.

PAYMENT AND TRANSACTION INFORMATION

City Educare may maintain records of fees, invoices, payment status, transaction references and refunds.
• Where online payments are processed through a third-party payment provider, payment credentials may be
handled directly by that provider.
• Financial records may be retained for accounting, audit, tax, dispute-resolution and legal purposes

WEBSITE, COOKIES AND ONLINE SERVICES

City Educare’s website or online services may use cookies or similar technologies to support essential functions,
remember preferences, understand website usage and improve user experience.
• Technical information may include IP address, browser type, device information, pages visited and approximate
usage patterns.
• Individuals may manage non-essential cookies through browser settings, although some website features may be
affected.
• Where additional tracking technologies are used, appropriate notice or consent should be provided where required.

DATA SECURITY

City Educare takes reasonable technical, administrative and organisational measures to protect personal
information against unauthorised access, loss, misuse, alteration, disclosure or destruction.
• Access Control: Access should be limited according to role and responsibility.
• Account Security: Password protection and secure account practices should be followed.
• Device & Network Security: Reasonable security measures should be maintained.
• Physical Records: Documents should be stored securely and accessed only when required.
• Backups & Recovery: Reasonable procedures should be maintained for important systems and records.
• Staff Awareness: Personnel handling personal information should receive appropriate privacy and security
guidance.
No method of electronic transmission or storage can be guaranteed to be completely secure. Suspected security
incidents should be reported promptly.

DATA RETENTION

City Educare retains personal information only for as long as reasonably necessary for the purpose for which it was
collected, ongoing services, record verification, accounting, legal obligations, dispute resolution, security or other
legitimate purposes.
• Records should be securely deleted, destroyed or anonymised when no longer required, subject to applicable
retention requirements.
• Long-term records may be retained where necessary for certificates, verification or legal purposes.

CHILDREN AND STUDENT INFORMATION

City Educare may provide educational or training services to young persons. Where an individual is a minor, City
Educare may communicate with or obtain information from a parent or legal guardian where appropriate and
permitted.
• Only information reasonably necessary for education, safety, administration or legal purposes should be collected.
• Information relating to minors should receive heightened care.
• Access should be limited to authorised personnel

DATA ACCURACY AND UPDATES

City Educare aims to keep personal information accurate, relevant and reasonably up to date.
• Individuals should inform City Educare when important personal, contact or academic information changes.
• Supporting documents may be requested before changes are made to official records

INDIVIDUAL PRIVACY RIGHTS AND REQUESTS

Subject to applicable law, an individual may have rights concerning their personal information, including:
• Requesting access to personal information.
• Requesting correction of inaccurate information.
• Requesting withdrawal of consent where consent is the applicable basis.
• Making other privacy requests available under applicable law.City Educare may verify the identity of the requester before processing a request. Some requests may be limited
where information must be retained or processed for legal, contractual, security, accounting or other legitimate
purposes.

DATA BREACH AND INCIDENT RESPONSE

If City Educare becomes aware of a suspected or confirmed incident involving unauthorised access, loss,
disclosure, alteration or destruction of personal information, reasonable steps will be taken to:
• Assess and contain the incident.
• Protect affected systems and information.
• Preserve relevant evidence.
• Restore secure operations.
• Identify corrective actions and reduce the risk of recurrence.
• Make any legally required notifications or escalations

INTERNATIONAL OR CROSS-BORDER PROCESSING

If City Educare uses a service provider or platform that stores or processes information outside the individual’s
country, appropriate safeguards should be considered and applicable requirements for such transfers should be
followed.
City Educare should periodically review relevant third-party terms, processing arrangements and security
practices.

POLICY CHANGES

City Educare may update this Privacy Policy when its services, systems, legal requirements or data practices
change.
• The updated policy will be made available through appropriate channels.
• Individuals are encouraged to review the current policy periodically.
• Material changes may be communicated through appropriate channels where reasonably required

CONTACT AND GRIEVANCE HANDLING

Questions, privacy requests, complaints or concerns about the handling of personal information may be submitted
through City Educare’s official administrative/contact channel.
City Educare will make reasonable efforts to review and respond to privacy-related requests and complaints within
an appropriate timeframe.

ACCEPTANCE AND ACKNOWLEDGEMENT

By using City Educare’s website, submitting an application, enrolling in a programme, engaging with its services, or
otherwise providing information to City Educare, an individual acknowledges that they have had an opportunity to
review this policy.
• The policy explains the general manner in which personal information may be handled.
• Separate consent, enrolment, employment or service documents may contain additional privacy terms.
• Applicable legal requirements will continue to apply