This Privacy Notice explains in detail the types of Personal Data TutorPro may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe. We have included a lot of information in this Privacy Notice because we want you to be fully informed about your rights, and how TutorPro uses your data.
We hope the following sections will answer all questions you have but if not, please do get in touch with us.
This policy was last updated on April 30th, 2018, to comply with the General Data Protection Regulation (GDPR) that comes into effect on May 25th, 2018. Please be aware that it is likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to pop back and check it whenever you wish.
Understanding the Legal Bases That We Rely On
The law on data protection sets out a number of different reasons for which an organisation may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you submit a website enquiry and tick a box to receive TutorPro mailings. When collecting your personal data, we’ll always make clear to you what data is necessary in connection with a particular product or service.
In certain circumstances, we need your personal data to comply with our contractual obligations we have you, as a Client Family Member. For example, if you subscribe or purchase a product or service from us, we’ll require your Name, Email Address, Phone Number, Work Office Address and Firm’s Billing Information.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting TutorPro to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your subscription or purchase history to send you or make available product updates or offers.
We will also use your email address details to send you direct marketing information by email, telling you about products and services that we think might interest you.
When Do We Collect Your Personal Data?
Here is a list of how we collect your Personal Data:
- When you subscribe or purchase a TutorPro product or service.
- When you make an enquiry via the TutorPro website, or when you comment on or review a blog post on the TutorPro website.
- When you contact us by any means with queries or complaints.
- When you engage with us on social media.
- When you choose to complete any surveys, we send you.
Any individual may access personal data related to them, including opinions for third-parties. For example, if your comment or review on our website includes information about a TutorPro Partner who provided that service, it may be passed on to them if requested.
What Personal Data Does TutorPro Collect?
If you submit a web enquiry to us, or email TutorPro direct, your Name, Email Address, Telephone Number and Work Office Address is collected.
If you are a Client Family Member using any of the TutorPro products or services, we will collect your Name, Email Address, Telephone Number, Work Office Address and Firm’s Billing Information. Other data, depending on the TutorPro product or service you have, we may have collected your Date of Birth.
We will also collect information from interactions you have with us, online or on a phone call. For example, details of any complaints or comments you make, details of purchases you have made, web pages you visit, how and when you contact us and which site you came from to ours. To deliver the best possible web experience, we collect technical information, via Google Analytics, about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, and any search terms you entered
How and Why Does TutorPro Use Your Personal Data?
Providing the best service is key at TutorPro HQ. We want to give you the best possible experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when product updates are available, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
To respond to your queries, and any complaints, handling the information you sent enables us to respond to you. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, about relevant products and services including tailored special offers, discounts, promotions, events, and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
TutorPro will not send any marketing communications to you by post.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice. These messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To send you survey and feedback requests to help improve our products and services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Combining your data for personalised direct marketing?
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the business as described above. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third party processors such as Google Analytics.
How We Protect Your Personal Data
We know how much data security matters to all our Client Family Members and potential Client Family Members. We will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all areas of our website using ‘https’ technology and access to your personal data is password-protected.
Any Client Family Member using cloud-based services, your access is also via ‘https’ unless specified by your Data Controller and your data transferred internally is via secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing for the TutorPro LMS to identify ways to further strengthen security.
How Long Will We Keep Your Personal Data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
An example of Client Family Member data retention periods;
When you subscribe to or purchase a product or product, we’ll keep the personal and financial data you give us for six years, plus the current year, so we can comply with our legal and contractual obligations.
Who Do We Share Your Personal Data With?
TutorPro does not share your personal data with any third parties for their own purpose, such as marketing, unless otherwise stated below;
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell the Partnership and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
- For further information please contact our Data Protection Officer.
TutorPro uses trusted third parties to process some of the data. Here is a current list of trusted third parties, who will process your Personal Data as part of their contracts with us:
- Microsoft Azure (Azure)
- Google Analytics
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Where Will Your Personal Data Be Processed?
Third Parties, such as Freshworks, are outside of the European Economic Area (EEA) and other third parties such as Azure may be outside of the EEA. We have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What Are Your Rights Over Your Personal Data?
Here is an overview of your different rights;
You have the right to request:
- Access to the personal data we hold about you.
- The correction of your personal data when incorrect, out of
date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that TutorPro holds at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, or for your information to be amended, please contact the DPO by emailing firstname.lastname@example.org.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
How to Stop the Use of Your Personal Data for Direct Marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from TutorPro.
- Email email@example.com
- Write to TutorPro Ltd. 10 High Street, Wellington. Somerset. TA21 8RA.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or visit www.ico.org.uk/concerns. Please note that TutorPro cannot be responsible for the content of external websites.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
If you live outside the EU
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at DPO@tutorpro.com or write to us at Data Protection Officer, TutorPro Ltd. 10 High Street. Wellington. Somerset. TA21 8RA.