Privacy Policy

Our commitment to your family's privacy

At Early Learners International Preschool, we take the protection of your family's personal information seriously. This comprehensive privacy policy outlines exactly how we collect, use, store, and protect the information of children in our care. We're committed to transparency, security, and compliance with both Japanese and U.S. privacy laws while serving our diverse international community in Japan.

We collect special categories of data including basic biometric health information and photos only with your explicit consent. Your child's privacy is our priority – we implement rigorous safeguards, limit data retention to 3-5 years, and ensure you maintain control over your family's information at all times.

Information we collect

We collect several types of personal information to provide quality educational services and ensure the health and safety of children in our care.

1. Basic personal information

Child's full name, date of birth, gender, nationality
Parent/guardian names, relationship to child
Contact information (address, phone numbers, email addresses)
Emergency contact information
Enrollment and attendance records

2. Health and biometric information

Medical history and conditions relevant to childcare
Allergies and dietary restrictions
Immunization records
Basic biometric data including height and weight measurements
Temperature readings when checking for illness

3. Visual and audio information

Photographs of children for educational documentation
Video recordings of special events and activities
Voice recordings for language development assessment

4. Educational information

Development assessments and progress reports
Behavioral observations
Learning preferences and needs

How we use your information

1. Core educational and administrative purposes

We use personal information primarily to:

Provide age-appropriate educational activities and care
Monitor and support children's development
Communicate with parents about their child's progress
Maintain attendance and enrollment records
Ensure health and safety, including emergency response
Comply with legal obligations to educational authorities

2. Special categories of data

We handle sensitive information with additional care.

3. Biometric health information

We collect basic biometric data solely for health monitoring and developmental tracking. This includes height, weight, and temperature readings. We do not use advanced biometric identification systems or share this data with third parties except as required for health and safety purposes.

4. Photographs and media

We use photographs and videos to:

Document children's development and learning activities
Share children's experiences with their own parents
Create memory books and classroom displays
Occasionally for preschool promotional materials (only with separate explicit consent)
We obtain specific consent for each use of photographs through our separate Photo Release Form, which allows you to consent to some uses while declining others.

Consent and parental rights

1. Consent framework

As the parent or legal guardian, your consent is essential before we collect, use, or share your child's personal information. We use different consent mechanisms depending on the type of information and its intended use:

General consent: Provided during enrollment for basic operations of the preschool.
Special category consent: We obtain additional explicit written consent before collecting health information or biometric data.
Photograph consent: Our separate Photo Release Form allows you to specify exactly how your child's images may be used.
Third-party service consent: We obtain separate consent before sharing information with non-essential third-party services.

2. Your privacy rights

As a parent or guardian, you have the following rights regarding your child's personal information:

Access: You may request copies of any personal information we hold about your child.
Correction: You may request correction of inaccurate or incomplete information.
Deletion: You may request deletion of information that is no longer necessary for the purposes for which it was collected.
Withdrawal of consent: You may withdraw previously given consent at any time.
Complaint: You have the right to lodge a complaint with the Japanese Personal Information Protection Commission.

To exercise these rights, please submit a written request to our Privacy Officer at elipokinawa@gmail.com - We will respond to all requests within 14 business days.

Data sharing and third parties

1. When we share information

We limit sharing of children's personal information to situations that are necessary for operational purposes or required by law:

Within our preschool: Staff members access children's information only on a need-to-know basis to perform their duties.
With parents/guardians: We share information about your child only with persons having legal custody or authorized by legal custodians.
Third-party educational services: We use specific educational platforms and services to enhance our educational program:
- Class Dojo App: For classroom management and parent communication
- [Other educational services if applicable]
Cloud service providers: For administrative and operational purposes, we store information with:
- Dropbox: Administrative document storage
- Google (Gmail): E-mail communications
- Microsoft (OneDrive): Document storage and sharing
Regulatory authorities: We share information when required by Japanese educational authorities or U.S. military base requirements for enrolled military dependents.
Emergency services: In case of medical or other emergencies, we may share relevant information with emergency service providers.

2. Facebook advertising and analytics

We use Facebook for advertising our preschool services and analyzing our online presence.

We do not target advertisements directly to children under 13
We do not allow Facebook to use children's personal information for behavioral advertising
Facebook may collect information through cookies and similar technologies when adults visit our website
You can opt out of Facebook's targeted advertising by following instructions HERE
We use Facebook analytics tools to understand how adults interact with our online content in aggregated, de-identified form

3. Third-party safeguards

All third-party service providers that process personal information on our behalf must:

Process information only as directed by us
Implement appropriate security measures
Assist us in fulfilling our obligations to parents exercising their rights
Delete or return all personal information when the service ends
Submit to audits and inspections as appropriate

We regularly review our third-party providers' security and privacy practices to ensure continued compliance with our standards.

Data security

We implement appropriate technical and organizational measures to protect personal information from unauthorized access, disclosure, alteration, or destruction.

1. Technical safeguards

Encryption of sensitive data during transmission and storage
Secure authentication systems with strong password requirements
Regular system updates and security patches
Network security controls including firewalls
Encrypted and secured backups

2. Operational safeguards

Staff privacy and security training conducted quarterly
Background checks for all staff with access to children's data
Strict access controls limiting data access to only those who need it
Comprehensive data breach response plan
Regular security and privacy compliance audits

3. Physical safeguards

Secure, locked storage for physical records
Building access controls
Clean desk policy and secure disposal of physical records

4. Data breach notifictaion

In the event of a data breach that may compromise personal information, we will:

Promptly investigate the scope and cause of the breach
Notify affected families without undue delay
Report to Japan's Personal Information Protection Commission as required by law
Take necessary measures to prevent recurrence
Provide regular updates on remedial actions taken

Data retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations.

Standard retention periods

Enrollment and basic identification data: 5 years after the child leaves our preschool
Attendance and daily activity records: 3 years after the end of the academic year
Health and medical records: 3 years after the child leaves our preschool
Developmental assessments and portfolios: 3 years after the child leaves our preschool
Photographs and videos: 1 year after the child leaves our preschool, unless specific consent for longer retention has been obtained
Financial records (if any): 7 years (as required by tax regulations)
Security camera footage: 30 days maximum, unless preserved for a specific incident
Biometric data: Deleted immediately when the child leaves the preschool or when consent is withdrawn

After the retention period expires, personal information is securely deleted or anonymized. Parents may request earlier deletion, which will be honored unless we have a legal obligation to retain the information.

International data transfers

As an international preschool serving primarily U.S. military families in Japan, we may occasionally need to transfer personal information across borders, particularly to the United States. This may occur when:

Communicating with U.S. military base administration
Using U.S.-based educational software or cloud services
Facilitating children's transitions to schools in other countries

For any transfer of personal data outside Japan, we will:

Obtain specific prior consent from parents/guardians
Enter into data processing agreements with all service providers that include standard data protection clauses
Ensure that recipients of data implement appropriate security measures
Transfer only the minimum necessary data for the stated purpose
Parents/guardians have the right to withhold or withdraw consent for international data transfers.

Compliance with privacy laws

Our privacy practices comply with multiple regulatory frameworks.

1. Japanese Act on the Protection of Personal Information (APPI)

As a preschool operating in Japan, we comply with all APPI requirements including:

Purpose limitation and data minimization
Security control measures
Transparency about data processing
Respecting data subject rights
Obtaining consent for special categories of data and cross-border transfers

2. United States of America privacy laws

For our U.S. military families, we respect applicable U.S. privacy standards including principles from:

Family Educational Rights and Privacy Act (FERPA)
Children's Online Privacy Protection Act (COPPA)
Department of Defense privacy regulations for military dependents

In cases where Japanese and U.S. requirements differ, we typically apply the higher standard of protection to all children in our care.

Changes to this policy

We may update this Privacy Policy periodically to reflect changes in our practices or regulatory requirements. When we make significant changes, we will:

Post the updated policy on our website
Send email notifications to parents/guardians
Provide physical copies upon request
Obtain new consent when required by law

The revised policy will be effective immediately upon posting, and the revision date will be noted at the top of the policy.

Contact Information

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact:

Privacy Officer
Early Learners International Preschool
elipokinawa@gmail.com
098-989-3628
3-25-20 Noborikawa, Okinawa City, Okinawa Japan 904-2142

For urgent privacy concerns, please call 098-989-3628