Privacy Policy

1. Introduction

1.1 Tutorwise Limited ("Tutorwise", "we", "us", "our"), a company registered in England and Wales, respects your privacy and is committed to protecting your personal data.

1.2 This Privacy Policy ("Policy") explains how we collect, use, store, and share personal data when you access or use the Tutorwise platform, website, applications, and related services (collectively, the "Platform").

1.3 This Policy applies to all users of the Platform, including Clients, Tutors, Agents, Organisations, and any other users who interact with the Platform.

1.4 By accessing or using the Platform, you acknowledge that your personal data will be processed as described in this Policy.

2. Definitions

2.1 "Personal Data" means any information relating to an identified or identifiable individual, as defined under UK GDPR.

2.2 "Special Category Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation.

2.3 "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.

2.4 "Data Controller" means the entity that determines the purposes and means of processing Personal Data. Tutorwise is the Data Controller for Personal Data processed through the Platform.

2.5 "Agent" refers to a user who makes or receives referrals on the Platform, as defined in the Terms of Service.

2.6 "Client" refers to a learner aged 18 or over, or a parent or guardian acting on behalf of a learner, as defined in the Terms of Service.

2.7 "Tutor" refers to a user providing educational services via the Platform.

2.8 "Organisation" refers to a business, school, or entity subscribing to Tutorwise CRM and operational features.

3. Data We Collect

3.1 Account Information

• Name, email address, phone number, postal address
• User role(s) and account preferences
• Profile information and photographs

3.2 Identity and Verification Data

• Date of birth, identification documents
• DBS certificate information (for Tutors and Agents working with minors)
• Professional qualifications and credentials

3.3 Payment Information

• Payment method details, transaction history, billing address
• Payout information for Tutors and Agents
• All payment data is processed via third-party providers (e.g., Stripe)

3.4 Platform Usage Data

• Session history, bookings, and scheduling data
• Referrals made and received, attribution data
• Activity logs, preferences, and interactions on the Platform
• Device information, IP addresses, and browser data

3.5 Content Data

• Uploaded materials, messages, and communications
• Reviews, ratings, and feedback
• Notes and records relating to tutoring sessions

3.6 Special Category Data

• DBS and safeguarding information is processed under Article 9(2)(b) UK GDPR (employment and social protection obligations) and retained in accordance with the DBS Code of Practice
• We do not intentionally collect other Special Category Data unless strictly necessary and with explicit consent

3.7 Cookies and Tracking Data

• Usage of cookies, analytics scripts, and similar tracking technologies
• See Section 11 for details on cookies

4. How We Use Your Data

4.1 Platform Operation

To facilitate tutoring sessions, referrals, payments, subscriptions, and core Platform functionality.

4.2 Account Management

To create and manage user accounts, verify identity, and maintain account security.

4.3 Communications

Notifications, reminders, and operational updates relevant to your use of the Platform.

4.4 Safeguarding

To comply with safeguarding obligations, verify DBS status, and protect minors using the Platform.

4.5 Legal and Regulatory Compliance

Anti-fraud measures, tax reporting, dispute resolution, and other statutory obligations.

4.6 Analytics and Service Improvement

Monitoring, analysing, and improving Platform performance and user experience.

4.7 Marketing

With your explicit consent, we may use Personal Data for promotional communications. You may withdraw consent at any time.

5. Legal Basis for Processing

5.1 Contractual Necessity (Article 6(1)(b) UK GDPR)

Processing necessary for the performance of obligations under the Terms of Service or agreements with users.

5.2 Legitimate Interests (Article 6(1)(f) UK GDPR)

Platform operations, fraud prevention, referral system management, analytics, service improvement, and network security. We balance our interests against your rights and freedoms.

5.3 Consent (Article 6(1)(a) UK GDPR)

Marketing communications and optional features requiring user consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5.4 Legal Obligation (Article 6(1)(c) UK GDPR)

Compliance with safeguarding legislation, tax requirements, anti-money laundering obligations, and other statutory requirements.

5.5 Special Category Data (Article 9(2)(b) UK GDPR)

DBS and safeguarding data is processed for employment and social protection purposes as required by law.

6. Automated Decision-Making

6.1 The Platform uses automated systems for referral attribution, determining which Agent is credited for a Session based on recorded referral data.

6.2 Users are not subject to decisions based solely on automated processing that produce legal or similarly significant effects without human oversight.

6.3 Users may request human review of automated decisions by contacting us.

7. Data Sharing and Disclosure

7.1 Third-Party Service Providers

We share Personal Data with service providers who assist in operating the Platform, including:

• Payment processors (Stripe)
• Cloud hosting and infrastructure providers
• Analytics and monitoring services
• Communication and email services

All third-party providers are bound by data processing agreements.

7.2 Organisations

Where Organisations use CRM features, relevant Personal Data (including student names, contact details, and session information) may be shared with authorised Organisation representatives for operational purposes.

7.3 Other Users

Certain information (such as tutor profiles, reviews, and availability) is visible to other Platform users as necessary for the Platform to function.

7.4 Legal Authorities

Where required by law, court order, or regulatory obligation.

7.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, Personal Data may be transferred to the successor entity.

8. International Transfers

8.1 Personal Data may be transferred outside the UK where our service providers operate internationally.

8.2 Where transfers occur, Tutorwise ensures appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the ICO
• Transfers to countries with adequacy decisions under UK law
• Binding Corporate Rules where applicable

9. Data Retention

9.1 Personal Data is retained only for as long as necessary to fulfil the purposes outlined in this Policy, comply with legal obligations, resolve disputes, or enforce agreements.

9.2 Retention periods include:

• Account information: duration of account plus 2 years after closure
• Payment and transaction records: 7 years for accounting and tax purposes
• Referral and session data: duration of user engagement plus 2 years
• DBS and safeguarding data: as required by law and DBS Code of Practice
• Marketing consent records: 2 years after consent withdrawal
• Platform logs and analytics: 12 months

9.3 Upon expiry of retention periods, Personal Data is securely deleted or anonymised.

10. User Rights

Under UK GDPR, you have the following rights. We will respond to requests within one month of receipt.

10.1 Right of Access (Article 15)

You may request access to the Personal Data we hold about you and receive a copy.

10.2 Right to Rectification (Article 16)

You may request correction of inaccurate or incomplete Personal Data.

10.3 Right to Erasure (Article 17)

You may request deletion of your Personal Data, subject to legal or contractual retention obligations.

10.4 Right to Restrict Processing (Article 18)

You may request restrictions on how your Personal Data is processed in certain circumstances.

10.5 Right to Object (Article 21)

You may object to processing based on legitimate interests, direct marketing, or profiling.

10.6 Right to Data Portability (Article 20)

You may request your Personal Data in a structured, commonly used, machine-readable format.

10.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time without affecting prior processing.

10.8 Right to Complain

You may lodge a complaint with the Information Commissioner's Office (ICO) at any time:

• Website: ico.org.uk
• Telephone: 0303 123 1113

11. Cookies and Tracking

11.1 Tutorwise uses cookies and similar technologies to improve Platform functionality and user experience.

11.2 Types of cookies we use:

• Essential cookies: Required for Platform operation
• Analytics cookies: Help us understand how users interact with the Platform
• Preference cookies: Remember your settings and preferences

11.3 Users can control cookie preferences through Platform settings or browser controls. Disabling certain cookies may affect Platform functionality.

12. Security Measures

12.1 Tutorwise implements administrative, technical, and physical safeguards to protect Personal Data against unauthorised access, disclosure, alteration, or destruction, including:

• Encryption of data in transit and at rest
• Access controls and authentication measures
• Regular security assessments and monitoring
• Staff training on data protection

12.2 Data stored with third-party service providers is subject to appropriate contractual safeguards.

12.3 While we take reasonable measures to protect Personal Data, no system is completely secure. Users should safeguard their account credentials.

13. Children and Minors

13.1 The Platform is intended for users aged 18 or over.

13.2 For learners under 18, a parent or guardian must create the account, provide consent, and supervise Platform use. The parent or guardian is the Client for data protection purposes.

13.3 Tutors and Agents providing services to minors must comply with all applicable safeguarding laws and maintain valid Enhanced DBS checks.

13.4 If we become aware that we have collected Personal Data from a child under 13 without parental consent, we will delete that data promptly.

14. Referral System and Intellectual Property

14.1 The Platform's referral system, including attribution logic, algorithms, and data structures, is proprietary and subject to intellectual property protections (designated "IP Pending").

14.2 Users acknowledge that participation in the referral system does not confer any ownership rights in the referral system, IP, or underlying mechanisms.

14.3 Tutorwise retains full operational control over referral logic, attribution, and reward distribution.

15. Changes to This Policy

15.1 Tutorwise may amend this Privacy Policy from time to time to reflect legal, regulatory, or operational changes.

15.2 Material changes will be notified via email or Platform notification.

15.3 Updated policies will be published on the Platform with a new "Last Updated" date. Continued use of the Platform following publication constitutes acknowledgement of the updated Policy.

16. Contact Information

16.1 For general enquiries: support@tutorwise.io

16.2 For legal enquiries: info@tutorwise.io

16.3 For data protection enquiries: info@tutorwise.io

16.4 Tutorwise Limited Registered in England and Wales