Privacy Policy

Privacy Policy

Last Updated On 14-Feb-2023
Effective Date 14-Feb-2023

PRIVACY POLICY

Welcome to Tutoring4You’s Privacy Policy (Policy).

We respect your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit and use our Platform (defined below) and tell you about your privacy rights and how the law protects you. References to “we”, “us”, or “our” in this Policy mean Tutoring4You. Any other capitalised terms that are not defined herein are defined in our Terms.

We ask that you read this Policy carefully.

This Policy is divided into the following sections:

 

  • Who we are, purpose of this privacy policy, and our processing role
  • Contact details:
  • Our collection and use of your personal data
  • How we use your personal data and our lawful basis
  • Transfers of your personal data out of the UK and EEA
  • Marketing
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this Policy

Who we are, purpose of this Policy and our processing role:

Tutoring4You operates a digital learning website and mobile application (hereafter, the Platform) where you can browse and purchase tutoring services on behalf of children. For more information see: [insert about us link]

As such, we collect and use the personal data of three (3) categories of data subjects (Data Subjects):

  1. Visitors to our Platform and those who enquire about the services offline;
  2. Users with accounts and guest accounts on the Platform being both Guardians and Tutors; and
  3. Students who receive our services.

 

We collect, use and are responsible for certain personal data about Data Subjects. When we do so we are regulated under the UK GDPR (consisting of the UK Data Protection Act 2018, as amended and updated in light of the UK’s departure from the European Union) and the EU GDPR (the General Data Protection Regulation (EU) 2016/79, as amended from time to time), as applicable based on your location in the United Kingdom or the European Union and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

Throughout the Platform, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you, or provide external services. These other third party websites may also gather information about Data Subjects in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Contact details:

If you have any questions about this Policy or our privacy or tracking practices, please contact us using the following details:

Full Name of Legal Entity: Tutoring4You Ltd

Contact: www.tutoring4you.co.uk

Postal Address: 39 Windsor Drive, Solihull, United Kingdom, B92 8HS

You have the right to make a complaint at any time to your local supervisory authority. If you are based in the United Kingdom, then this will be the Information Commissioner’s Office (the ICO), who is the UK regulator for data protection issues. For more information, please visit www.ico.org.uk.

If you are based in the European Union, please consult the following website to find out the details of your local supervisory authority, https://edpb.europa.eu/about-edpb/board/members_en.

We would, however, appreciate the chance to respond to your query and deal with your concerns before you approach a supervisory authority.

Our collection and use of Data Subjects’ personal data:

We collect personal data about Data Subjects when they access our Platform or make enquiries about our services offline, including when you create an account with us, contact us, send us feedback, post material to our Platform, where Guardians and Tutors sign up to our Platform and where Guardians purchase Tutoring Services via our Platform,.

We collect this personal data from Data Subjects either directly, such as when you create an account with us, contact us or sell or purchase Tutoring Services via our Platform or indirectly, such as your browsing activity while on our website (see our Cookie Policy for more information on automatic collection).

The personal data we collect about Data Subjects depends on the particular activities carried out through our Platform.

If you create an account on the Platform to purchase or provide Tutoring Services, we collect the following personal data:

  • your name, billing and delivery address and contact details such as email address and telephone number;
  • in respect of Tutor’s, data required to carry out a background check and vetting;
  • the name, date of birth and educational needs of the Student;
  • transaction data such as details of any payments you make to us via our nominated payment provider;
  • details of any feedback you give us by phone, email, post or via social media;
  • information about the Tutoring Services we provide to you and are interested in purchasing, or have purchased;
  • your account details, such as username, login details;
  • Data Subjects’ IP address, login data, browser type and version, operating system and platform, and device data; and
  • usage data on how Data Subjects use our Platform, and services.

 

If Data Subjects merely visit the Platform, but do not have an account or have not purchased any services from us or use our services , we only collect the following personal data:

 

  • IP address, login data, browser type and version, operating system and platform, and device data;
  • usage data on how you use our Platform, and services; and
  • preferences in receiving marketing from us.

 

We use this personal data to:

  • create and manage your account with us;
  • verify your identity;
  • Facilitate the provision of the Platform Services and Tutoring Services by Tutors to the Student;
  • offer and sell our Platform Services and the Tutoring Services to you;
  • customise our Platform and its content to your particular preferences and requirements;
  • notify you of any changes to our Platform or to our services that may affect you; and
  • improve our Platform Services.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Data Subjects’ personal data but is not considered personal data in law as this data will not directly or indirectly reveal the identity of Data Subjects. For example, we may aggregate Data Subjects’ usage data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify Data Subjects, we treat the combined data as personal data which will be used in accordance with this Policy.

 

We do not collect any Special Categories of Personal Data about Data Subjects (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Data Subjects’ health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use Data Subjects’ personal data and our lawful basis for processing your personal data

We will only use Data Subjects’ personal data when the law allows us to. Most commonly, we will use Data Subjects’ personal data in the following circumstances:

  • If you are a Guardian who has purchased services from us, we will process the personal data of you and the Student in order to perform the contract we are about to enter into or have entered into with you;
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or
  • Where we need to comply with a legal obligation.

When we process Data Subjects’ personal data, we are required to have a lawful basis for doing so. There are various different lawful bases on which we may rely, depending on what personal data we process and why.

Please see the below for more information on the lawful basis that we may rely on:

  • consent: where Data Subjects or in the case of Students, where the Guardian has given us clear consent for us to process personal data for a specific purpose
  • contract: where our use of Data Subjects’ personal data is necessary for a contract we have with that Data Subject, or because the Data Subject has asked us to take specific steps before entering into a contract
  • legal obligation: where our use of a Data Subject’s personal data is necessary for us to comply with the law (not including contractual obligations)
  • legitimate interests: where our use of a Data Subject’s personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect a Data Subject’s personal data which overrides our legitimate interests)

Further information—the personal data we collect, when and how we use it

For further details on when we collect personal data, the type of data we collect as well as the lawful basis we rely on, please read the following table:

Purpose for processing your personal data

Type of data

Lawful basis for processing including basis of legitimate interest

To create an account for a Data Subject on the Platform.

(a) Identity

(b) Contact

(c) Date of birth of student

(d) Information about the education needs of the student including school of attendance

Performance of a contract with you

To onboard and vet Tutors

(a) Identity

(b) Contact

(c) DBS criminal background check

(d) Qualifications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To help process and facilitate delivery of the Tutoring Services including:

(a) Organising Lessons;

(b) Sending out homework;

(c)  Manage payments, fees and charges; and

(d) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with Data Subjects which will include:

(a) Notifying you about changes to our Terms of Use or Privacy or Cookie Policy

(b) Asking Data Subjects to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Platform content and advertisements to Data Subjects and measure or understand the effectiveness of the advertising we serve to Data Subjects

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to Data Subjects about goods or services that may be of interest

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Who we share your personal data with

If you are a customer on the Platform, we share the personal data of customers such as identity, contact and transactional data with our payments services provider Stripe. For more information about how Stripe processes your personal data please visit: https://stripe.com/gb/privacy-center/legal.

We use Amazon Web Services for our cloud storage of lesson recordings. For more information about how Amazon processes your personal data please visit: https://aws.amazon.com/privacy/.

This data sharing enables us to ensure orders are fulfilled and services are performed accordingly and also allows us to recover the sums for the Tutoring Services owed by you.

We also share the personal data of Guardians and Students with our Tutors who are providing the Tutoring Services to the relevant Student in order to facilitate the provision of the Tutoring Services with the consent of that Student’s Guardian.

Some of these third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.

We will share personal data with law enforcement or other authorities if required by applicable law.

Where we do share your data with third parties, we will always ensure that such third parties are bound by a contract setting out how they are authorised to process data on our behalf and which contains provisions regarding data security and confidentiality, as required by applicable privacy laws.

Transfer of your personal data out of the UK and EEA

We may transfer your personal data to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA):

  • Canada

Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.

Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

Transfers of personal data from the EEA to the UK shall be done on the basis of an adequacy decision awarded by the European Commission to the UK in June 2021.

If you would like further information please contact us using the details provided at the start of this Policy.  We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Marketing

We would like to send you information about the Platform, our services, the products on sale and any special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

We will ask whether you would like us to send you marketing messages when you provide consent to such marketing, or where you have purchased products from us.  

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us using the detail provided at the beginning of this Policy;

—using the ‘unsubscribe’ link in emails; or

—updating your marketing preferences on our Platform within your account.

Your rights

Under the UK GDPR and the EU GDPR, you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal data
  • access to your personal data and to certain other supplementary information that this Policy is already designed to address
  • require us to correct any mistakes in your personal data which we hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal data
  • otherwise restrict our processing of your personal data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email or write to us using the details provided at the beginning of this Policy.

We will require information from you to allow us to identify you. We will endeavour to respond to all requests with 30 days of receipt.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Policy

This Policy was last updated on 14th February 2023.

We may change this Policy from time to time, when we do, we will update this Policy on the Platform. It is your responsibility to ensure you are always up to date of the latest policy in force.