Lead Montessori Privacy Policy
Lead Montessori collects and uses personal information about visitors of it's website, clients, staff, students, members, participants of conferences and other individuals who come into contact with our organisation. The information is gathered in order to enable Lead Montessori to provide professional development, education, membership, services and other associated functions. In addition, there is a legal requirement to collect and use information to ensure that the organisation complies with its statutory obligations.
This is Privacy Policy summarising the information held, why it is held and the other parties to whom it can be passed on.
This policy applies to our websites, our use of emails and text messages for information, and any other methods that we use for collecting information. It covers what we collect and why, what we do with the information and what we won’t do with the information, and what rights you have.
Who are we?
We are Lead Montessori s.r.o. (further only LM). Our seat is Na sekyrce 3, Praha 6, 160 00. Our ID is 07152779. Our contact person is Executive Director Miroslava Vlckova: mirka@leadmontessori.com. We are the owner of www.leadmontessori.com.
Purpose of this Privacy Policy
This policy is intended to provide information about how LM will use (or "process") personal data about individuals. This information is provided because the GDPR gives individuals rights to understand how their data is used. All are encouraged to read this Privacy Policy and understand the LM’s obligations to its entire community.
This Privacy Policy applies alongside any other information LM may provide about a particular use of personal data, for example when collecting data via an online or paper form.
This Privacy Policy is applicable in addition to LM’s other relevant terms and conditions and policies.
Anyone who works for, or acts on behalf of, LM (including staff, volunteers, board members and service providers) should also be aware of and comply with LM’s data protection policy for staff, which also provides further information about how personal data about those individuals will be used.
LM’s Commitment to Privacy
LM is committed to keeping the personal information that you share with us (on paper, over the telephone or via the internet) accurate, up to date and confidential.
Responsibility for Data Protection
Executive Director of LM will is responsible for the oversight of data protection compliance. The Executive Director will deal with all your requests and enquiries concerning LM’s uses of your personal data (see section on Your Rights below) and endeavour to ensure that all personal data is processed in compliance with this policy and the GDPR.
What Information Do We Collect?
We will only ever collect the information that we need, including data that will be useful to help us to improve our services. We collect two kinds of information:
- Non-personal information such as IP addresses (the location of the computer on the internet), pages accessed, and files downloaded. This helps us to determine how many people use our website and how popular the pages are. It doesn’t tell us anything about who you are or your address. It simply allows us to monitor and improve our website. We also use cookies on our website. Please see our cookies policy for further information.
- Personal information as detailed below. This information will be used for administration and for other normal purposes of a non-government organisation.
Personal Data Processed by LM
Personal data processed by LM includes contact details, and professional development, training and assessment results. LM may also process sensitive personal data such as ethnic group or nationality.
How We Collect Personal Data
We will collect information about you at the time you apply for or purchase a membership, course, programme, event, service or product. From time to time we may request that you confirm and where necessary update the information that we hold. On occasion, we may request additional information if it is deemed necessary for administration or service provision.
Your personal data will usually be collected directly from you.
Purposes For Which Your Data May Be Processed
Your personal data (including sensitive personal data, where appropriate) is processed by LM strictly in accordance with the GDPR in order to:
- support its students and conference participants learning;
- monitor and report on their progress;
- support membership services;
- assess how well the LM as a whole is doing;
- communicate with staff, members, students/trainees, participants of conferences;
- for the purposes of management planning and forecasting, research and statistical analysis, including that imposed or provided for by law (such as tax, diversity or gender pay gap analysis);
- to enable relevant authorities to monitor LM's performance and to intervene or assist with incidents as appropriate;
- to give and receive information and references about past, current and prospective staff;
- to give and receive information about past, current and prospective students/trainees;
- to give and receive information and references about past, current and prospective trainers;
- to monitor (as appropriate) use of LM’s IT and communications systems in accordance with the LM’s acceptable use policy;
- to make use of photographic images in publications, on the website and (where appropriate) on social media channels in accordance with the LM’s policy on taking, storing and using images; and other reasonable purposes relating to the operation of LM.
Unless you have requested otherwise, LM may also use your contact details to send you promotional and marketing information by post, email and SMS about LM and its activities. When you submit information via our website you will have the option to opt out of receiving marketing information. Should you subsequently decide that you would rather not receive such information then there is an “unsubscribe” option on all of our emails or you can contact info@leadmontessori.com.
Third Parties with Whom We May Need to Share Your Personal Data
From time to time LM may be required to pass your personal data (including sensitive personal data where appropriate) to third parties, including local and public authorities, and professional advisers, who will process the data:
- to comply with the law, for example to comply with a court order, or if requested by a government or local authority department which has the lawful authority to obtain the information;
- in response to a request from either the police or a local authority department in connection with our Child Protection obligations;
- to enable the relevant authorities to monitor LM's performance;
- to compile statistical information (normally used on an anonymous basis);
- to secure funding for LM (and where relevant, on behalf of individuals);
- to enable trainers and students/trainees to take part in assessments and to monitor progress and educational needs;
- to obtain appropriate professional advice and insurance for LM;
- where a reference or other information is requested by another educational establishment or employer to whom they have applied;
- where otherwise required by law; and
- otherwise where reasonably necessary for the operation of the LM.
Finally, in accordance with the GDPR, some of LM’s processing activity is carried out on its behalf by third parties, such as IT systems, web developers or cloud storage providers, such as Smartselling, Facebook, Google, Fapi, Pragoecon- services we are not able to secure ourselves. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with LM’s specific directions.
Storing Your Information
Information is stored by us on servers located in Prague, Czech Republic. We may transfer the information to other reputable third-party organisations as explained above and they may store their information inside or outside the European Economic Area. We may also store information in paper files.
Unfortunately the transmission of information via the internet is not completely secure; any transmission is at your own risk. Once we have received your information we have in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Whilst we cannot guarantee that loss, misuse or alteration of data will not occur whilst it is under our control, we make every effort to try to prevent this
Where a password is required to enable you to access parts of our website, it is your responsibility to keep this password confidential. Please do not share your password with anyone.
Retention of Data
LM will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason.
If you have any specific queries about how our retention policy is applied or wish to request that personal data that you no longer believe to be relevant is considered for erasure, please contact the Executive Director at LM. However, please bear in mind that LM will often have lawful and necessary reasons to hold on to some personal data even following such request.
A limited and reasonable amount of information will be kept for archiving purposes, for example; and even where you have requested we no longer keep in touch with you, we will need to keep a record of the fact in order to fulfil your wishes (called a "suppression record").
When we no longer require information, we will always dispose of it securely, using specialist companies if necessary.
What LM Won’t Do With Your Information
We will never sell or share your information with other organisations to use for their own purposes.
Your Rights
Individuals have various rights under the GDPR to access and understand personal data about them held by LM, and in some cases ask for it to be erased or amended or have it transferred to others, or for MIP to stop processing it but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing to the Executive Director.
LM will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).
LM will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, LM may ask you to reconsider, or require a proportionate fee (but only where the GDPR allows it).
For more information about your rights, please see the EU GDPR portal.
You should be aware that the right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege (for example legal advice given to or sought by MIP, or documents prepared in connection with a legal action).
LM is also not required to disclose any student scripts, provide or other test marks ahead of any ordinary publication, nor share any confidential reference given by MIP itself for the purposes of the education, training or employment of any individual.
You may have heard of the "right to be forgotten". However, we will sometimes have compelling reasons to refuse specific requests to amend, delete or stop processing your personal data: for example, a legal requirement, or where it falls within a legitimate interest identified in this Privacy . All such requests will be considered on their own merits.
Consent
Where LM is relying on consent as a means to process personal data, any person may withdraw this consent at any time. Examples where we do rely on consent are certain types of uses of images and certain types of marketing activity. Please be aware however that LM may not be relying on consent but have another lawful reason to process the personal data in question even without your consent.
That reason will usually have been asserted under this Privacy Policy or may otherwise exist under some form of contract or agreement with the individual (e.g. an employment contract, or because a purchase of goods, services or membership has been requested).
Data Accuracy and Security
LM will endeavour to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. Individuals must please notify the Executive Director of any significant changes to important information, such as contact details, held about them.
An individual has the right to request that any out-of-date, irrelevant or inaccurate or information about them is erased or corrected (subject to certain exemptions and limitations under the GDPR): please see above for details of why MIP may need to process your data, of who you may contact if you disagree.
LM will take appropriate technical and organisational steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and access to systems. All staff, volunteers and board members will be made aware of this policy and their duties under the GDPR and receive relevant training.
This Policy
LM will update this Privacy Policy from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.
Further Questions
If you have any queries about this Policy or how personal data is processed by LM, please contact the Executive Director. Please put GDPR in the subject heading.
If an individual believes that MIP has not complied with this policy or acted otherwise than in accordance with the GDPR, they should utilise the complaints procedure and should also notify the Executive Director.