1.0 This Policy
Our Policy outlines how we process your personal data and your rights under the Data Protection Act 2018 (DPA 2018) and UK data protection legislation. We retain the right to update this Statement at any time, without prior notice, by publishing any changes on this page.
2.1 What information do we collect?
NOVATUTORS requires Personal Information from you to use the Site and Services, as it is a necessary part of fulfilling our contract with you, which is governed by our Terms and Conditions. Without this information, we may not be able to provide our Services to you. The following are the types of Personal Information we require:
- Account information: This enables us to create an account for you on the Site. Depending on whether you register as a parent, tutor, or other, this information can include your name, email, telephone number, postal address, profile picture and date of birth.
- Tutor application details: We need these details to process your application to become a tutor. They include your educational background and qualifications, tutoring subjects, and video resume, curriculum vitae, prices and availability.
- Communication history: We store details of your communication history to facilitate communication with other users of the Site and with the NOVATUTORS team. This includes user messages, media files sent over our messaging app, booking requests, and interactions with the NOVATUTORS team and other users, including call recordings.
- Booking history: This information enables us to facilitate tutorials, including booking requests, booking status, booking subjects and levels, and recordings of your bookings (which include tutor interviews, free introductory sessions, lessons, and written sessions).
- Promotions you redeemed: We keep records of the referral codes you shared, redeemed, and other promotions you interacted with to apply rewards to your account.
- Identity verification information: We require this information when you apply to become a tutor. We ask for verification that you study at the university you claim to or proof of graduation from the university that you claim to have graduated from, have a valid ID card, and a clean DBS check (if applicable). We also request information to demonstrate that you have the right to work in the UK.
Please note that we reserve the right to modify this policy at any time without prior notice by posting changes on this page.
- Information collected automatically from your use of the NOVATUTORS Site
As part of our obligation to fulfill our contract with users and to enable our legitimate interests in providing the NOVATUTORS site and services, we collect certain information automatically from all users of the NOVATUTORS site, whether or not you are a registered client or tutor. This automatically tracked information includes the pages you visit and actions taken, times and dates of actions on our website, interactions with our email, texts, and messages through our website’s messaging app and your page response times.
For those with a tutor profile on the site, we also collect information on your on-site behaviour, capacity, and interactions with other users to help match you with the most relevant requests and to show customers the most relevant tutors.
- Financial Information
Our payment system is handled through our payment partner, Stripe, Inc (https://stripe.com/gb).
As a result of this, NOVATUTORS does not hold any of your payment details such as your credit/debit card details or your bank account details.
If you book Tutoring Services through the Site as a customer, or receive payment for delivering Tutoring Services through the Site as a tutor, you must give your payment details to our payment partner, Stripe, in order for your bookings (if you are a client) or payouts (if you are a tutor) to be processed. NOVATUTORS does not hold this information. By doing this, you must also agree to the terms and conditions of Stripe, Inc. These will be made available to you when you enter your payment/payout details.
2.2 How is the information used?
To improve the quality of the services we offer, the Site requests that you provide different types of Personal Information. Providing accurate information enables us to better understand and meet your needs. All Personal Information held by NOVATUTORS is subject to DPA 2018 regulations. NOVATUTORS acts as the data controller for all Personal Information obtained while using our Services.
- Data processing in order to provide and enhance the NOVATUTORS Site and Services
We utilise your information to fulfil our contractual obligation of providing you with requested Services and improving them. In order to do so, we undertake the following processes:
- Allowing you to access the Site and create an account
- Allowing tutors to create and showcase their profile on the Site
- Facilitating the matching process between customers and tutors, by customising the experience and presenting the most relevant matches
- Providing a platform for communication between users and sending NOVATUTORS account updates
- Facilitating bookings between customers and tutors
- Providing access to recordings of previous sessions
- Allowing payments for services
- Offering customer and tutor support services
- Providing access to photos and videos to create trust and build better connections between users.
- Facilitating technical administration to ensure the smooth operation of the Site
- Monitoring and assessing service quality to improve our offerings
- Analysing Site usage data to inform product development and enhance the User experience
- Analysing lesson data to improve features offered by NOVATUTORS to you and other Users.
- Drawing insights from demographic information to inform our business strategy
- Preventing fraudulent, spammy, abusive, or inappropriate behaviour to maintain a safe and respectful environment for all Users
- Fulfilling our legal and safeguarding obligations to protect Users and their Personal Information.
You acknowledge that your Personal Information may be used by NOVATUTORS to contact you by post, phone or by electronic mail when necessary in connection with the Services requested by you on the Site.
- Data processing to provide, tailor and improve our marketing activities
We also use your information to support our legitimate interests in marketing our Site and the Services. These processes include:
- Marketing activities to promote our services to registered users. These communications may be personalised to you and your interactions with the Site and can be delivered by email, social media advertising and other digital marketing channels
- Notifying you about upcoming promotions, Referral Discount Codes, services or customer surveys
- Undertaking impact reporting to understand the efficacy of our Services
- Undertaking research to better understand our customers interests
- Analysing your interactions to improve the efficiency of our marketing activities
- Direct marketing
The Site may use your contact information to provide you with information or offers directly related to the Site and the Services. By registering on the Site, you consent to receive direct marketing communications from NOVATUTORS. You will receive a welcome email upon registration, which cannot be opted out of, but you will be provided with an opportunity to unsubscribe from marketing emails in all subsequent communications. Depending on your decision not to opt-out, NOVATUTORS may contact you by post, phone (recorded for quality assurance purposes), or email with information or offers, such as discounts or exclusive offers for products or services. If you wish to opt-out of future marketing communications, you can contact NOVATUTORS at firstname.lastname@example.org with the subject line "UNSUBSCRIBE REQUEST" or a similar statement. NOVATUTORS may still contact you regarding contractual obligations and legal requirements even if you choose to opt-out of marketing communications.
- The legal grounds under DPA 2018 and GDPR for processing your personal data described above are as follows:
We process your personal information because it is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, in order to provide you with our products and services. If we need specific information from you to provide these services, we have indicated above which information is necessary. Without this information, we may not be able to provide you with our services.
In addition, we process your personal information for the purposes of our legitimate interests, such as fraud prevention, child protection, maintaining quality of service, error detection, and cybersecurity, unless these interests are overridden by your interests, rights or freedoms. In making this determination, we consider a range of factors such as what you were told at the time you provided your data, your expectations about data processing, the nature of the data, and the impact of the processing on you. To protect children from harassment and abuse, we may video record and store tutoring sessions.
We also process your personal information because you have given us explicit opt-in consent for one or more specific purposes, such as receiving electronic Direct Marketing from us and/or from third parties as described in this notice.
We may also process your personal information to comply with legal obligations or to protect your interests (or someone else’s interests) in rare circumstances, and/or where it is necessary in the public interest or for official purposes.
3.0 Who can else can access your information
- Other users on the NOVATUTORS site
Tutors (if you are a Client) or Clients/Tutors (if you are a Tutor) may access your Personal Information solely for the purpose of providing Tutoring Services and related information through the Site. For instance, if you request Tutoring Services as a Client, your Personal Information (including first name, initial of surname, message content, profile picture, and the requested subject and level) will be shared with the Tutor to facilitate the service. Similarly, if you are a Tutor and create a profile on the Site, your Personal Information (such as first name and initial of surname, university details, resume, profile picture, grades, tutoring subjects, pricing, tutoring record, and reviews) may be visible to any User who visits the Site. Such sharing of Personal Data is necessary to utilise the Site and the Services.
When you communicate with other users on the Site, you acknowledge that NOVATUTORS may monitor your messages to fulfil our safeguarding obligations and protect our legitimate interests.
- Third party companies and service providers
To provide our services, we work with a range of third-party companies who may require access to some of your Personal Information. We take measures to limit the amount of information shared with these parties. The following are categories of third-party providers that we may share personal data with:
- Providers of analytics services to help us analyze how our Site and Services are used
- Sponsors of tutorials to enable them to communicate with Users and provide offers or information
- Providers of payment services to facilitate payment transactions on the Site
- Providers of communications platforms, such as email, text, and in-app messaging, for us to communicate with Users
- Marketing platforms to help us with our marketing efforts
- Tools to help us with our business operations
- Providers of identity verification services to verify the identity of Users
- Providers of surveys and research services to enable us to gather feedback and conduct research
- Platforms for accounting and finance to manage financial transactions and accounting data
- Customer support platforms to help us manage and respond to inquiries and issues from Users.
- Disclosure of your personal information and financial information in compliance with laws
Please note that we may disclose your Personal Information or Financial Information if we deem it necessary to comply with applicable laws or regulations, to aid law enforcement, to enforce the terms of your agreement with NOVATUTORS, or to safeguard the rights, property, or safety of NOVATUTORS, Site Users, or other parties. We may also share your data with the Department for Education and other relevant authorities, or third-party auditors, upon request for audit purposes.
- Transfer of your personal information and financial information outside of the UK or the EEA
We may need to transfer your personal data to entities located outside of the UK or EEA, including the United States. These countries may not have data protection laws as strict as those in the UK or EEA. In such cases, we will either assess the level of protection provided in light of the circumstances surrounding the transfer, or:
- Transfer your data only to non-EEA countries with privacy laws that provide the same level of protection as the EEA;
- Establish an agreement with the recipient that requires them to protect your data to the same standards as those in the EEA;
- Ensure that any transfers are limited to the minimum amount of information necessary and not repetitive. In certain cases, we may need to obtain your consent unless there is an overriding legal need to transfer the information; and
- Inform you of the measures we have put in place in all cases where your information is transferred outside the EEA, and you have the right to contact us for this information. Please note that we may need to disclose your Personal Information or Financial Information in response to laws or regulations, to cooperate with law enforcement, to enforce the terms of your transaction with NOVATUTORS, or to protect NOVATUTORS, Site Users, or others. We may also share your data with the Department for Education and other governing bodies, or contractual parties for audit purposes, upon request.
- Other sites/third party vendors and their privacy policies and cookie policies
This Site may contain links to other websites. NOVATUTORS is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, and so you should be careful to read and understand those website policies independently.
4.0 Protecting your information
We value the privacy and security of your Personal Information. However, please be aware that email messages sent through the internet are not encrypted and may not be fully secure. Despite our efforts to safeguard your Personal Information, we cannot guarantee the security of any information transmitted to or from our online Services. As a result, NOVATUTORS cannot be held responsible for any breaches of confidentiality that may occur due to the use of email. If you have any sensitive or confidential information that you prefer not to communicate through email, please contact us via telephone or post to arrange an alternative communication method. Please note that any information you transmit via email is done so at your own risk. Once we receive your transmission, we take all necessary precautions to ensure that it is secure on our systems.
To protect the information we control, the Site has implemented various security measures against loss, misuse, and unauthorised alterations. All your transactions with us are encrypted with 128-bit industry standard Secure Server Software (SSL), which includes your Personal Information, such as credit card number, name, and address. This encryption ensures that your information cannot be read as it travels over the Internet.
6.0 Complaints procedure
At NOVATUTORS, we strive to adhere to the highest standards when it comes to the collection and use of Personal Information. We take any complaints regarding our practices very seriously and encourage individuals to bring any concerns to our attention if they believe our collection or use of information is unfair, misleading, or inappropriate. We also welcome any suggestions for improving our procedures.
It is important to note that this Statement does not provide an exhaustive detail of all aspects of NOVATUTORS's collection and use of Personal Information. However, we are happy to provide any additional information or explanation as needed. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you have the right to file a complaint with the UK data protection regulator, the Information Commissioner's Office. For more information, visit ico.org.uk or call 0303 123 1113.
7.0 How long do we keep your information for?
We will store your personal data for different periods based on the service you are using. In some cases, we may need to hold your data for a longer time period than is necessary to provide the services to you due to regulatory or statutory requirements. We will keep the data for as long as needed to fulfil the purposes for which we collected it in the first place.
By default, we store personal data for six years after your last activity on the Site. This is because the average lifecycle of a NOVATUTORS user is typically within this timeframe. After this time has passed, or after you request us to delete your data (whichever is earlier), we will remove your personal data except when we have a specific reason for keeping it for a longer duration.
Records that you have shared publicly or with other users, such as reviews, messages, and bookings, may remain on the Site after your personal information has been deleted, but we will no longer associate any identifying information with them. We may retain records when it is necessary to fulfil our regulatory or statutory duties.
8.0 Access and rectification of personal information
NOVATUTORS aims to be transparent and provide individuals with access to their Personal Information. You have the right to request a copy of the information we hold about you by making a "subject access request" under data protection legislation. This request is typically free of charge. If we do hold your information, we will provide you with a copy unless there is a legal exception, in which case we will inform you at the time. Additionally, you have the right to request that any incorrect, incomplete, or outdated information we hold about you is updated or removed. To make a request for either of these rights, please write to us at the address provided below or email us at email@example.com with the subject line "Subject Access Request".
9.0 Moving your information
If we process your data using automated means and you have given us your consent or if we have used your information to perform a contract with you, you have the right to request that we provide you, or another organisation of your choosing, with an electronic copy of the personal data we hold about you in a structured, commonly used, and machine-readable format. This is particularly useful when you are dealing with a different service provider. If you wish to exercise this right and have us provide you with, move, copy, or transfer your information in this way, please let us know by emailing us at firstname.lastname@example.org. We will evaluate whether this is feasible, taking into account technical compatibility with the other organisation, and respond to your request within one month.
10.0 Deleting your personal information
You have the right to request the deletion or removal of your personal data where there is no justifiable reason for us to continue processing it. Additionally, if you have exercised your right to object to processing, or if you have withdrawn your consent for us to process your personal data, or if we have processed your information unlawfully, or if we are required by local law to erase your personal data, you can ask us to delete or remove your personal data. However, please note that there may be certain legal reasons that prevent us from complying with your request, and we will notify you of any applicable legal reasons at the time of your request.
If you want us to delete your personal data, please email us at email@example.com with the subject line "Request for Personal Data Deletion".
11.0 Withdrawing your consent from our processing of your personal information
You may withdraw any explicit consent you have given us to process your personal data at any time. Please note that this will not affect the lawfulness of any processing of your personal data that we have carried out before you withdraw your consent. If you wish to withdraw your consent or change your consent preferences, you can do so by changing your account settings or by contacting us at firstname.lastname@example.org. If you want to withdraw your consent for us to send Third-Party Promotions, please let us know by contacting us at the same email address or by updating your preferences on your account settings.
12.0 Restricting or objecting to our processing of your personal information
You have the right to request that we suspend the use of your personal information in certain situations, or to object to our processing of your data if we rely on a legitimate interest (or that of a third party) that you believe impacts your fundamental rights and freedoms, or if we process your data for direct marketing purposes. However, in some cases where you object, we may have compelling legitimate grounds to continue processing your data, which override your rights and freedoms.
Please be aware that if you ask us to restrict or stop processing your data, this may affect our ability to provide our services to you. Depending on the extent of your request, we may be unable to continue providing you with our service.
If you have any questions or concerns regarding the use of your data, please send them to email@example.com.
13.0 Our use of automated decision making
In order to deliver our services, we may need to engage in profiling and automated decision-making activities with respect to your data, which may involve:
- Reviewing tutor applications to ensure that they meet our requirements, including the right to work in the UK
- Screening user messages to protect contact details and ensure privacy
- Collecting data about tutor behaviour, site activity, and availability to determine which requests are sent to them
- Monitoring login activity to keep tutor profiles current on the site
If you have any questions or concerns about these automated activities or wish to dispute any decisions made, you have the right to request that a human review and reconsider the decision. Please contact us at firstname.lastname@example.org to initiate this process.
14.0 How to contact us with respect to your personal information
Requests for information about our Statement can be emailed to email@example.com or requested in writing to:
19/1 Oxgangs farm gardens , Edinburgh, EH13 9QE
We keep our Statement under regular review. This Statement was last updated on 21 Feb 2023.