Privacy Policy

Assemblr EDU Privacy Policy

Protecting the security and privacy of your personal data is important to us, and we conduct our business in accordance with the guidelines set out in this Policy in accordance with applicable laws of the Republic of Indonesia. Assemblr respects your privacy and is fully committed to protecting your personal information and using it properly in accordance with applicable regulations. This Privacy Policy applies to our website, including edu.assemblrworld.com and the Assemblr mobile app. This Privacy Policy explains what information we (together with our affiliated companies) collect and use relating to individual Account holders and non-Account holders (such as Site visitors) through the Site, how we use that information, and what choices you have regarding with information we collect about you. Our Site and services are available through the Site collectively called "Services." Assemblr Edu is committed to protecting the privacy of children who use our sites and applications. This Children's Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 ("child" or "children"), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the Children's Online Privacy Protection Act ("COPPA") and Global Data Privacy Regulation, ("GDPR"). We will take reasonable steps to protect user privacy. Under this Policy, "user" or "you" means anyone who uses or benefits from the Service or sends personal information to us through the Service. BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE. This Privacy Policy is incorporated by reference into the Terms and Conditions of Use ("Terms and Conditions of Use"), which you agree to be bound by using the Service.

Identified Data Controller

The data controller responsible for the processing of Personal Information in connection with the Services is PT. Assemblr Teknologi Indonesia ("Assemblr"), with its registered office at Jl. Ir. H. Juanda No. 477A Block D, Coblong, Dago, Bandung, West Java 40135, Indonesia. You can contact us at support@assemblrworld.com for general privacy questions. If you are located in the EU/UK or otherwise wish to contact our privacy lead, please write to our Data Protection Officer at privacy@assemblrworld.com. If required by law, Assemblr will appoint an EU/UK representative whose contact details will be made available via privacy@assemblrworld.com. For all school/institutional privacy inquiries, please contact privacy@assemblrworld.com.

User Information

We collect only the Personal Information necessary for specified purposes. Core account data includes: full name, email address, role (teacher/student/parent), grade/class, school/organization, as well as location-related information such as city, country, etc. We use Personal Information solely to: (i) provide and support the Services; (ii) secure and maintain our platform; (iii) comply with law; and (iv) with your (or your school's) consent for optional features. We do not collect open-ended "other necessary information." Any additional fields will be disclosed, justified, and optional unless strictly required. We prohibit secondary uses incompatible with these purposes.

CHILDREN'S PRIVACY POLICY

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. When we intend to collect personal information from children, we take additional steps to protect children's privacy. If the Service is being used by a school and/or teacher (the "Educational Institution") with students that are under 13 years of age, such Educational Institution agrees that it has reviewed our Terms of Use and our Privacy Policy. Assemblr Edu only requests Personal Information from parents and/or teachers and we will never knowingly solicit, nor will we accept, Personal Information from users known to be under 13 years of age. We collect only the minimum amount of information needed about students from teachers, and any such information is used only in connection with the Educational Institution's use of the Assemblr EDU for authorized educational/school purposes. If we learn that personally identifiable information has been provided to us and/or collected on our Sites from persons under 13 years of age and without verifiable parental consent, such as through a support request, we take the appropriate steps to delete the information. All users are the owners of their accounts so therefore can visit their account online at any time to delete any information and/or the account.

For users between the ages of 13 and 17, access to the Services requires parental or guardian consent, obtained either directly by the parent or by the Institution on the parent's behalf. We apply the same data minimisation, no-sale, and no-advertising commitments to all minor users regardless of age. Institutions are responsible for ensuring appropriate consent is in place for all minor users within their account.

No Sale or Commercial Monetisation of Student Data

Assemblr does not sell, rent, or otherwise monetize Student Personal Information. We do not permit behavioral advertising, targeted advertising, or profiling of students on the Services. Student Personal Information will be used only to: (i) provide and improve the educational services requested by the school/teacher; (ii) ensure security and integrity; (iii) comply with law; and (iv) as otherwise expressly permitted by the school under a written agreement. We will not disclose Student Personal Information to third parties except: (i) to vetted service providers acting under written contracts with data-protection obligations and solely on our instructions; (ii) as required by law; or (iii) with the documented direction of the school/parent. We will not combine Student Personal Information with information from third-party services for advertising or marketing purposes.

No Advertising or Profiling of Students

Assemblr does not use Student Personal Information for targeted advertising, behavioral advertising, or profiling for non-educational purposes. We do not allow third parties to use student data accessed through our Services for advertising or marketing. Student accounts are not subject to interest-based advertising or cross-context behavioral tracking.

FERPA

Assemblr Edu agrees to work with educational institutions to ensure compliance with FERPA and the Parties will ensure compliance by providing parents, legal guardians or eligible students with the ability to inspect and review student records and to correct any inaccuracies therein as allowed by FERPA.

Breach Notification Commitment

If Assemblr becomes aware of a Personal Information breach affecting users of the Services, we will without undue delay (and, where applicable law requires, within 72 hours) notify the relevant school/institutional customer and, where required, affected parents/guardians and/or users. Our notice will include: (a) a description of the incident; (b) the categories and approximate volume of data subjects and records concerned; (c) likely consequences; and (d) measures taken or proposed to address and mitigate the breach. We will cooperate with schools/institutions to meet regulatory notification requirements and with law enforcement as appropriate. We will document the breach and remediation steps and make such records available upon reasonable request.

Lawful Basis for Processing

We process Personal Information on the following legal bases: (a) Contract (GDPR Art. 6(1)(b)) — to create and manage accounts, deliver the Services, provide support, and fulfill our contractual obligations; (b) Legitimate Interests (Art. 6(1)(f)) — to secure and improve the Services, prevent fraud/abuse, and perform aggregate analytics that do not identify individuals; (c) Consent (Art. 6(1)(a)) — for optional features, communications, or cookies not strictly necessary; and (d) Legal Obligation (Art. 6(1)(c)) — to comply with applicable laws. For students, we rely on the school's authorization (and, where required, verified parental consent) to process Student Personal Information solely for educational purposes. Where consent is used, it may be withdrawn at any time without affecting prior lawful processing.

Third-Party Data Sharing Transparency

We disclose Personal Information only to: (i) service providers (processors) for hosting, storage, analytics, customer support, communications, and payments; (ii) schools/teachers and authorized guardians for educational purposes; (iii) authorities where required by law; and (iv) with consent. We require written contracts with processors mandating confidentiality, security, and data-use limits, and we monitor changes with 30 days prior notice to institutional customers. In the event of a merger, acquisition, or sale of assets, Student Personal Information will remain subject to the protections in this Privacy Policy, and affected schools will be notified in advance.

Protection of Personal Data

Any party who conducts irresponsible action for the disclosure of user information related to the protection of personal data, or use fake accounts in the form of Electronic Documents or Electronic Information that is informed to Assemblr EDU (to change, fake, add, reduce, transmit, damage, eliminate, transfer, or hide) the form of Electronic Documents or Electronic Information without the right and in a way that violates the law will be solely responsible and set Assemblr free from all lawsuits from any party. The actions will be subject to sanctions in accordance with applicable laws and regulations.

Retention of Personal Information

All personal information that you provide to us is stored on a secure server. All payment transactions on the Platform will be encrypted. By submitting your Personal Information on the Platform, you agree to the transfer, storage and processing that occurs on our Platform. We will take steps within the reasonable limits necessary to ensure that Personal Information is treated safely and in accordance with the Privacy Policy and Applicable Regulations. All Personal Information that you provide will be retained by us: (i) as long as you are still a user of our Platform and (ii) at least 5 (five) years from the date on which you stop using our Platform; or (iii) in accordance with the original purpose of collecting the Personal Information. In situations where we provide (or you choose) a password that allows you to access certain parts of our Platform, you are responsible for maintaining the confidentiality of this password. We ask that you do not share your password with anyone. Please note that the transmission of information via the internet is not completely secure. However, we will do our best to protect the Personal Information. We cannot guarantee the security of data sent to our platform; the risk of each transmission is your responsibility. Once we receive your personal information, we will use strict procedures and security features to prevent unauthorized access.

International Data Transfers

Personal Information may be processed in Indonesia and in other countries where we or our subprocessors operate. Where Personal Information is transferred across borders, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) under GDPR Art. 46, and supplementary measures where needed. Schools and users in regions with data-transfer requirements may request details of applicable safeguards at privacy@assemblrworld.com. We will not transfer Student Personal Information to jurisdictions without adequate protection unless compliant safeguards are in place.

Complaints and Questions

We ensure your personal information is treated confidentially and in accordance with privacy laws. If you believe your personal information has been handled in a way that is not in accordance with privacy laws, or if you want to access or request corrections to information we have about you, please contact us in writing. Please provide as much information as possible to help us provide you with a fast response.

User and School Rights

You (or, for students, your school/parent where applicable) have the right to: request access to your Personal Information; request correction of inaccurate data; request deletion of your data; request portability of your data in a machine-readable format; object to or restrict certain processing; and withdraw consent for optional processing at any time. Requests may be submitted to privacy@assemblrworld.com. We will verify identity and respond within 30 days (or the shorter period required by applicable law). Institutional administrators may request export or deletion of Student Personal Information under our School DPA. We do not discriminate against users who exercise their rights.

Cookies

In some cases, we may also use cookies, which are small files of letters and numbers that have been downloaded to your device when you access our media. We will use cookies specifically to recognize you the next time you visit our media and to display content that may suit your needs. Web browsers are usually set by default to accept cookies, but you can easily change this by modifying your browser settings. However, please note that if you choose to disable cookies, you may not be able to use some of our media.

Security

We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet transmission is fully secure, and we cannot guarantee that security breaches will not occur. Without prior limitation, we are not responsible for the actions of hackers and other unauthorized third parties who violate our reasonable security procedures.

Acknowledgement and Consent

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. We process your Personal Information only on the lawful bases described in the Lawful Basis for Processing section above. Where we rely on consent for optional features or communications, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal. In the event that you provide Personal Information relating to other individuals (for example Personal Information relating to your spouse, family members, friends or other parties) to Us, you represent and warrant that you have obtained the consent of that individual for, and with This agrees on behalf of these individuals for, the collection, use, disclosure and processing of their Personal Information by us.

Changes to the Privacy Policy

We will post the effective date of this Privacy Policy. For material changes to the Privacy Policy that affect how we process Personal Information, we will provide advance notice via email or in-app notification at least 30 days before the change takes effect. For institutional customers, continued use after the effective date requires written acceptance or may permit termination without penalty. Non-material or clarifying updates will be posted and indicated by the revised effective date.

Legal Compliance

Assemblr complies with Indonesian Law Article 26 of Law No. 11 of 2008 concerning Information and Electronic Transactions ("ITE Law") and Indonesian Law No. 27 of 2022 on Personal Data Protection (PDP Law) which is the main legal basis regarding the protection of information concerning a person's personal data used through electronic media. Assemblr users have the right to obtain and, if necessary, correct or delete their Personal Information by contacting Assemblr. To the extent required by applicable law, users can, for legitimate reasons, request that Assemblr stop using Personal Information.

Jurisdiction

Assemblr Edu is located in Indonesia and is subject to Indonesian State law. If you choose to access or use the Service, you agree to use and disclose information in accordance with this Policy and are subject to these laws.

Criticism and suggestions

All types of criticism, suggestions, and other needs can be addressed to us.

Privacy Information for Schools

Schools and educators can find a plain-language summary of our student data practices on our Privacy for Schools page.