Access to the Tutorludi Platform (including the Website, related software, and the Tutorludi mobile device application) is available with or without registering an account. You may access our Website without registration. You must first register an account to use the Tutorludi mobile device application. Thus, limited use of the Services is always possible without providing your details (for example, browsing the Website, checking how Tutorludi operates, viewing the list of tutors, reading the Tutorludi Blog, reviewing the variety of services, etc.). However, whenever you access the Website, we collect log information and place cookies on your device, which we use to track your activity on the Website. You can always opt out of cookies, except those necessary for the Website's functionality.
When you are a registered user, Tutorludi may collect from you and process cookie identifiers and the data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID, or social network I.D. (if linked through Facebook or if accessing Google Calendar), time zone, interface language, I.P. address, and device type.
Specifically, if you are a tutor, we may also collect and process other data provided by you, including zip code, gender, year of birth, city of residence, and educational experience, in addition to the information above.
Registered users may additionally provide profile pictures and chosen currency to perform actions under our Refund and Payments Policy.
You can learn more about the specific cases of data collection and the purposes of processing such data in a separate section of this Privacy Policy.
We may occasionally change this Privacy Policy, so please check this page to ensure you're happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top. Additional notifications on any amendments will be sent to your email.
We may also occasionally experiment with different features of the Tutorludi Platform, which can affect the scope, purposes, or other details of the processing of personal data. In such cases, we will provide prior notification and, if necessary, obtain your Consent.
Any questions regarding this Policy and our services should be sent to support@tutorludi.com
1. What Is Personal Data and the Processing of Personal Data? Main Definitions
Personal data is any information relating to you that, alone or in combination with other information, allows a person who collects and processes such information to identify you as an individual.
Processing of personal data means any operation with your data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. The data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing, which means you are a user of Tutorludi.
Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by explicit affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Tutorludi's Lawful Bases for Processing
Tutorludi processes your data only when we have a lawful basis. Specifically, Tutorludi processes your data if:
- Processing is based on the Consent you gave. As such, our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, your participation in our events and webinars, and placement of different types of cookies, and posting of the sweepstakes winners are based on your Consent;
- processing is necessary to provide our services to you according to our Terms of Service, which constitute a contract between you and us as regards information services of Tutorludi; in particular, this concerns enhancing the learning experience for tutors and students by providing AI-powered personalised recommendations, improved lesson planning, and interactive learning tools;
- processing is based on the explicit Consent you have given to our online verification provider and us to process your biometric information for tutor identity verification and fraud identification;
- processing is necessary for our legitimate interests. Those legitimate interests may include but are not limited to:
- compliance with the U.K. financial and accounting legislation;
- the assessment of Tutorludi's business efficiency by analysing the Tutorludi Platform traffic and financial performance indicators;
- promotion of Tutorludi through social media networks, media outlets, referees, and affiliates, such as bloggers or influencers; this, in particular, concerns the right of Tutorludi to use the tutor's name, profile picture, and other details for marketing, advertising, or promotional purposes under the Terms of Service;
- performance of the contracts with Tutorludi Business customers and provision of reports on their employees' and contractors' language learning progress and results of language assessment tests;
- user session control and fraud prevention, ensuring the appropriate protection of personal data;
- tutor verification and development of high-quality learning programs with tutors;
- A.I. data training;
- where necessary, compliance with applicable legislation (e.g., data subject request processing);
- in exceptional cases, to protect your vital interests or the vital interests of another natural person; or for the performance of a task carried out in the public interest or the exercise of official authority vested in us.
In all cases, we will notify you about the legal basis applied for processing and other relevant details before we start processing your data on a specific legal basis unless we cannot do so following our obligations under any applicable legislation.
3. Data We Collect: Scope
Tutorludi collects from you only the following information and only for the stated purposes:
Sure, here is the revised text incorporating your requests:
(1) Account for Students
Tutorludi collects and processes personal data you submit upon registration and edits settings in your account. For registration purposes, you submit your login credentials (username and password), first name, last name, and email. You may edit your account anytime with additional information and sync your Google and Tutorludi Calendars. Such additional information may help you find a suitable time slot with a tutor or have more visibility of your schedule. At the same time, you are not required to provide additional information not specifically necessary for the registration; it is your choice.
(2) Account for Tutors
Tutorludi collects and processes personal data you submit upon registration and edits your profile further. For registration purposes, you submit your login credentials (username and password), first name, last name, and email. You may edit your profile anytime with additional information and sync your Google and Tutorludi Calendars. Such additional information may help you find a suitable time slot with a student or have more visibility of your schedule. At the same time, you are not strictly required to provide additional information that is not specifically necessary for the registration. Therefore, you can include additional data in your profile, such as zip code, country, language skills, education, and work experience.
Some personal data, such as users' names and locations listed in their user profiles or derived from IP addresses, may be publicly visible to other users on the Services or the Web. We may implement a feature that permits you to choose what information is made public by changing your privacy setting in "Edit My Profile" within the Service.
(3) Subscription to the Tutorludi Blog
You may subscribe to the Tutorludi Blog to receive newsletters and updates from the Tutorludi Blog. For this, we require you to give us your email.
(4) Posting of Information
We process personal data freely submitted to you on Tutorludi. This may be a survey and online form you fill in on Tutorludi, a question or comment left in the Q&A section of our Website, or feedback you provide us with.
Tutorludi may also process the information you provide (including content and messages) that you post on/through the Tutorludi Platform, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to Tutorludi and to other users of the Services (students/tutors). You also recognise that parts of your content cannot be deleted from the Service as they may be connected to the Lessons you created and used by other users (students/tutors).
From our turn, unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support, and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.
(5) Service Use, Cookies and Other Similar Technologies
When you use our Services, we monitor and analyse web traffic and keep track of your behaviour.
Please refer to our cookie policy for further details on cookies and similar technologies.
(6) Billing Information
We process the details of your transactions through the Tutorludi Platform (such as your ID and the date and time of the transaction).
(7) Tutorludi Business
We may collect your name, email, company name, and phone number to give you more information regarding Tutorludi Business Services
(8) Sensitive Data
Unless you expressly agree, Tutorludi does not process your sensitive data.
(9) Pages on Social Networks
We maintain Tutorludi's official pages on social networks, such as Facebook, TikTok, Instagram, and LinkedIn. When you interact with Tutorludi's official pages in social networks, such as subscribing to the pages or leaving comments or reactions (e.g., 'like' our posts), we can analyse this data to measure our efficiency and conduct an analysis of our social media marketing campaigns in our legitimate interests.
(10) Tutors Community (for Tutors Only)
We maintain a Tutors Community, which can be accessed through our Website via Single-Sign-On (SSO). To fulfil purposes specified under this Privacy Policy, we will also collect and process your interaction and usage data within the Tutors Community.
(11) Tutorludi Academy (for Tutors Only)
By registering as a tutor, you will access our Tutorludi tutor space, where you can enrol in various courses to acquire new skills, enhance your teaching methods, improve your ranking, and maximise your experience on the Tutorludi platform. We will collect and process your activity data, feedback, reviews, and survey responses to refine and enhance our courses, making them more engaging and effective.
(12)Payment and Refund Policy
Payments will be processed in USD, EUR, or GBP, with prices displayed in your local currency for convenience. If your chosen currency differs from the billing currency, you may incur additional fees, such as international and foreign exchange fees. Tutorludi is not responsible for these fees or currency fluctuations.
Tutorludi Commission
Tutors are charged a service fee known as the "Tutorludi Commission" for using our platform. This fee is applied to each lesson at a specified rate. We reserve the right to adjust this commission and will notify Tutors of any changes in advance.
Refund Procedure
To request a refund, please email support@tutorludi.com with the lesson date and time, the reason for the refund, and your Tutor's name. Refund decisions will be made within 30 days at our discretion and within legal bounds.
Subscriptions and Group Classes
Different purchases like lesson packages, subscriptions, and group classes have specific refund policies. For subscription-related refunds, refer to support@tutorludi.com
Chargebacks
We may suspend your account access in case of a chargeback by banks or third-party processors. Users are responsible for fees or costs resulting from chargebacks or payment disputes.
Account Expiry and Deletion
Inactive accounts for over 180 days may be suspended, and any remaining balance will expire. Deleting your account will also result in the balance expiration. No refunds or compensation will be provided for unused balances or scheduled lessons/classes in case of account suspension or termination due to policy violations.
Payment Services
Payment processing is handled by third-party processors for secure transactions. We do not collect or store billing information, which is managed by these processors.
Payments and Payouts
The platform supports various payment methods, and all service payments are made through it. Students bear transaction fees, and Tutors are paid for each confirmed lesson/group class, with costs deducted from the payout.
Please note that Tutorludi does not provide financial services or advice. Payments are strictly for accessing tutoring services, and any fraudulent or illegal payment activities are prohibited.
How to Manage Tax Payments
Tutorludi is an on-demand platform that connects students (learners) with tutors, providing tools to facilitate online language teaching and tutoring services. Please note that Tutorludi does not directly offer online tutoring services or function as a language learning school.
As an independent tutor registered on Tutorludi, you provide services to students through the Tutorludi platform and receive compensation via tutorludi's secure financial channel.
It's important to understand that independent tutors are not employees of Tutorludi. As an independent contractor working with Tutorludi, you are responsible for:
- Determining your applicable tax reporting requirements and obligations.
- Paying income tax as an individual in your country of residence (where you are a tax resident).
- Remitting any taxes included or received to the relevant tax authority.
While we cannot offer tax advice or legal documentation to tutorludi users, we want to assure you that we are here to support you. We highly recommend consulting a tax professional for any filing questions.
For your convenience, we have provided tools to simplify your tax reporting. You can request information from the tutorludi support team or generate an earnings report from your Statistics page.
Remember, this information is provided for informational purposes only and is not intended to serve as legal advice.
(13) Information Required for Marketing and Promotion
We may collect tutors' postal addresses to promote the Tutoring Services you offer via the Tutorludi platform and assist you in reaching more potential students within specific geographic areas.
(14) Video recording (Tutors Only)
During lessons on the third-party platform, we remind you that, according to our privacy policy, we must record all Zoom classes conducted through our platform. Additionally, these recordings must be sent to admin@tutorludi.com↗ (admin@tutorludi.com).
(15) Language Assessment
We process your data to evaluate your language proficiency level. This may include processing your name, email address, and the results of your language assessment, which can occur before or after registering on the Tutorludi platform.
(16) Video Lessons, Sales Calls, Events, and Webinars
We may process your voice recordings, video lesson recordings, likenesses, and interactions during group or individual lessons on the Tutorludi platform and during sales calls, webinars, and events. We will only record you after first notifying you and obtaining your consent if required.
(17) Information Processed by AI-Powered Tools
We have integrated third-party AI-powered tools to enhance your experience on the Tutorludi platform. For instance, we may use your text inputs and, with your Consent, voice recordings, audio recordings, lesson recordings, and lesson transcripts to offer personalised learning recommendations, create lesson plans, provide grammar explanations, enrich vocabulary cards or messages, suggest exercises and homework, assess language proficiency levels, and enable chatbot functionality for vocabulary practice and grammar inquiries.
(18) Tutor Verification (for Tutors Only)
We process your facial biometrics (using a third-party online verification provider) and I.D. to verify your identity and prevent fraud.
4. Data We Collect: Purposes
We process the personal data you voluntarily provide for the purposes outlined below. Processing your data allows us to personalise your tutorludi experience to the fullest extent and deliver high-quality Services under the Terms of Service.
(1) Provision of Services
Primarily, we process your data to authorise access to our Services and fulfil our obligations under the Terms of Service for service provision. Specifically, upon registration, we use your data to help others (whether tutors or students) find your account or profile, schedule, give and take lessons, and monitor your learning progress.
To use the Services, you must provide payment and billing information through our third-party payment providers, who process your data encrypted and securely. Please refer to our Refund and Payment Policy for more details.
For companies utilising Tutorludi Business Services, we process the personal data of their Authorized Users to create accounts, enable access to the Services, provide language assessments, and report on language learning progress and assessment results.
Please note that we need the information you provide under our Terms of Service to offer you the full functionality of the Tutorludi platform, connect you with other users, or enable communication and lesson exchanges.
(2) Payment Services
We use third-party payment providers to process your payments securely online instead of directly handling your credit/debit card information. Your balance for lessons is securely held in your account, facilitated by our integrated checkout system from partners-payment providers (e.g., Braintree, Stripe, PayPal), and tutors receive payment for each confirmed lesson securely through these third-party payment providers. All transactions are protected with SSL encryption by our partner payment providers. Payment information is stored encrypted and securely by services like Braintree (a PayPal service). We do not store your payment information on our servers. It is advised that those tutoring from other countries open a bank account they can use to receive payment.
(3) Referral Programs
Through our "Tell-A-Friend" referral program, we generate a personalised referral link for you to share with friends to encourage them to sign up. We will only collect your friend's data once they follow your link and access the Tutorludi platform.
For our B2B referral program, you can share the names, job positions, and emails of colleagues interested in Tutorludi Business Services. We will inform your colleagues that we've received their data for our referral program upon initial contact.
(4) Communications
We may contact you via email and other methods, including publicly available notices, for service-related purposes (welcome letter, security and legal notices, announcements, tutorludi updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through Tutorludi, including exchanging messages, conducting video calls, and leaving feedback about other users.
Certain push notifications may be sent via the tutorludi mobile device application. You can manage these notifications using your smartphone's internal settings.
Upon receiving communications from us, you can opt out of such communications in each message, except for legal notices, essential reminders/notifications, or changes to user settings on Tutorludi.
Your contact data (including email, phone number, and Skype name) may be used to gather feedback. We may contact you to participate in research to improve our product's user experience. The research is for internal purposes only, including:
- Feature development and product updates;
- Marketing activities, including their publication on tutorludi or other information resources;
- Customer Support updates;
- Other service updates to enhance your experience.
The interviewer will not video, audio, or webcast your feedback without obtaining your Consent. The same applies to your voice and image recording.
(6) Marketing and Promotion of tutorludi
We may process your first name, last name, and email for our mailing list or newsletter and send you messages with commercial or promotional information about our Services. However, we will seek your consent first, and you can always opt out of our marketing messages using the mechanisms described in each message and through the user settings available on Tutorludi.
If you provide us with your phone number, we may also contact you with commercial or promotional information about our Services.
To promote the tutorludi Platform through blogs and influencer channels, we enable individuals to participate in our affiliate program. When we receive your information for the affiliate program, we process it to register you as an affiliate and track the progress of the promotion of the tutorludi Platform.
We may use the postal address you provide, with your Consent, for search engine marketing and optimisation.
Also, please note that we may use the feedback you provide, which, under Section 12 of the Terms of Service, may be used by Tutorludi without any additional compensation.
(7) Behavioral and Social Media Marketing
We may share your email address with Google and Meta to deliver personalised advertisements to you and engage in behavioural and social media marketing. These marketing activities are based on our legitimate interest, considering your interests and privacy.
(8) Identifying Influencers for Potential Collaborations
We may use third-party services, such as Captiv8, Inc. and LiveRamp Holdings, Inc., to analyse the information you provide at registration (like your name and other identifiers), perform a matching exercise, and identify our most influential students for potential collaboration. In this process, we may receive some of your data from Captiv8, Inc. (like your social media profiles) and establish a joint controllership over your data. If we identify you as an influencer and decide to propose a collaboration, we will provide you with a short privacy notice explaining this processing activity in detail.
(9) Analytics and Development
To discover new ways to improve the tutorludi Platform, identify points of interest in our Services, and for analytics purposes, we monitor and analyse the personal data you provide, including information upon registration, web traffic, cookies, and usage data, such as the parts of our Services you visit, the date and duration of your visit, your location, the type of device you used during your visit, and other relevant usage data.
For these purposes, we use services like Google Analytics for Firebase, Hotjar HeatMaps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom, ensuring compliance with our privacy commitments.
We may also conduct occasional research activities, including personalised "A/B" tests, to understand user engagement and satisfaction with certain features, to improve user experience, develop new features, and streamline our Services.
Additionally, we may carry out polls and surveys through Tutorludi using external GDPR-compliant services.
You are not obliged to respond to them, and you may opt out of such polls and surveys through user settings. We may process your usage data and cookies to inform, optimise, and serve you with relevant advertising based on your past use of our Services. Please follow our Cookie Policy for additional information.
(10) Tutor Verification and Program Preparation
To ensure the high quality of tutors' lessons on Tutorludi, we collect and process tutor credentials to verify their eligibility to teach the subjects they claim to teach. We also cooperate with tutors and use their information to help them develop learning programs.
We process tutors' biometric information and I.D. to verify tutor identity and identify fraud.
We also process tutors' registration data for analytics to automate and improve the tutor verification process.
(11) Improvement of Tutors' Ranking Algorithm
We gather and use various metric-based data to enhance the tutors' ranking algorithm and improve your experience based on our legitimate interest. This data may also consist of personal data that the tutors and students provide on the Tutorludi Platform. You can refer to Section 3.6 of our Terms of Service to learn more about the categories of data we may collect.
(12) Managing Tutors Community
We process the email, interaction and usage data of tutors participating in Tutors Community to allow them to come together and share their best practices, get official, up-to-date information, and interact with each other and tutorludi based on our legitimate interest in community building. We also use the collected data for moderation and statistics and to improve the tutor's user experience.
Rest assured that access to the personal data you submit to the Tutors Community will be restricted to service providers and employees on a need-to-know basis.
(13) Support and Platform Supervision
In case of any disputes on Tutorludi and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behaviour on the Tutorludi Platform, and respond to complaints or requests.
(14) Events and Webinars Conducted by Tutorludi
We use the personal data we collect from you when you register and attend any of our events or webinars to provide access to such events or webinars and send you registration confirmation, reminders, associated functional materials or the information you have requested about our Services.
(15) Competitions and Sweepstakes
• Competitions. Occasionally, we conduct learning-focused competitions for individuals who meet specific criteria. Participants must fill in the registration forms to register for the competition and prove eligible. We process this information exclusively to organise and conduct the competition, determine the winner(s), and contact them regarding the results and prizes.
• Sweepstakes. Occasionally, we conduct sweepstakes among registered users meeting specific entry requirements. We would process your user I.D., name, date of birth, country of legal residence, and email address associated with your account on the Tutorludi Platform to administer the sweepstakes (including verifying eligibility to participate in the sweepstakes, contacting you in the event you are selected to win a prize, providing the prize) and to comply with other legal requirements. To get the prizes, the winners must submit an affidavit of eligibility and a federal tax form (or other required tax form(s)). In addition, we may post the names of the sweepstakes winners on our Website upon your Consent.
(16) Compliance with Legal Requirements
We process certain payment information to comply with applicable legal requirements in finances and accounting. We also may process the data collected on the Tutorludi Platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and establish our legal rights.
(17) Fraud Prevention
Certain information, such as your log information, payment information, and behaviour on the Tutorludi Platform, are subject to our supervision to prevent fraudulent activities and assist you in managing your user sessions.
(18) Changes
We may change the tutorludi Privacy Policy from time to time. Any changes to this Policy will not reduce your rights unless you provide explicit Consent. The latest version is posted on this page. If we make substantial changes, we will notify you by email.
5. How Is Personal Data Shared?
Providing quality services makes Tutorludi enter into agreements with independent contractors and cooperate with other service providers, companies, and organisations strictly under data processing agreements (DPAs) or Standard Contractual Clauses (SCCs). For those reasons, some of your data can be passed to those mentioned.
(1) Categories of Third-Party Service Providers
● Analytics services
Personal data shared with this category of third-party service providers may include the information described in subsections 5 and 14 of section 3 of this Privacy Policy.
● Social network platforms and search engines
Personal data shared with this category of third-party service providers may include the information described in subsection 7 of section 4 and subsection 2 of section 5 of this Privacy Policy.
● Customer communication solutions
Personal data shared with this category of third-party service providers may include the information described in subsection 4 of section 3 of this Privacy Policy.
● User research tools
Personal data shared with this category of third-party service providers may include the information described in subsection 5 of section 4 of this Privacy Policy.
● Services to manage emails and send out push notifications
Personal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.
● SMS providers for mobile marketing and notifications
Personal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.
● Payment services providers
Personal data shared with this category of third-party service providers may include the information described in subsection 6 of section 3 of this Privacy Policy.
● AI-powered service providers
Personal data shared with these categories of third-party service providers may include the information described in subsections 16 and 17 of section 3 of this Privacy Policy.
● Providers of video conferencing, speech-to-text, and conversation analytics tools
Personal data shared with these categories of third-party service providers may include the information described in subsection 16 of section 3 of this Privacy Policy.
● Influencer marketing solution providers to identify and engage influencers
Personal data shared with this category of third-party service providers may include your name and other identifiers described in subsections 1 and 2 of section 3 of this Privacy Policy.
● Language assessment tools
Personal data shared with this category of third-party service providers may include the information described in subsection 15 of section 3 of this Privacy Policy.
● Search engine optimisation and marketing tools
Personal data shared with this category of third-party service providers may include the information described in subsection 13 of section 3 of this Privacy Policy.
● Services to manage Tutorludi Academy
Personal data shared with this category of third-party service providers may include the information described in subsection 11 of section 3 of this Privacy Policy.
● Services to manage Tutor's Community
Personal data shared with this category of third-party service providers may include the information described in subsection 10 of section 3 and subsection 10 of section 4 of this Privacy Policy.
● Online verification providers
Personal data shared with this category of third-party service providers may include the information described in subsection 18 of section 3 of this Privacy Policy.
● Tax and accounting compliance software providers
Personal data shared with this category of third-party service providers may include the information described in above
(2) Use of Social Network Platforms
We maintain Tutorludi's social media pages on Facebook, Instagram, LinkedIn, and TikTok.Please note that LinkedIn acts both as a processor engaged by Tutorludi and as an independent controller of your data. Additionally, TikTok and tutorludi independently process your data as independent controllers.
As for Tutorludi's Facebook and Instagram pages, Meta Platforms, Inc. ("Meta") is a joint controller for processing personal data. In particular, Meta and Tutorludi are joint controllers for the pages' insight data and statistics, your reactions and comments under our posts, and other information you make available to Tutorludi upon contacting us.
You may find more information on the Meta joint controllership arrangement at the following link: [Meta's legal terms page].
You may contact us with any questions related to your activity on Tutorludi's social media pages on the above-mentioned social network platforms or our processing of your data.
The service providers mentioned under subsections 1 and 2 will help us ensure your data is secure within Tutorludi.
tutorludi has contractors and subsidiaries in other countries, including those outside the European Economic Area, who may have access to your data. At the same time, when we pass your data on to other persons, we ensure that your data is being protected and used only for the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for the protection of personal data with contractors and partners (including the Standard Contractual Clauses adopted by the European Commission and compliant with the E.U. data protection laws), as well as taking technical measures to ensure the information is protected when stored, used, and while being processed and transferred.
(3) Data Transfer in Case of Change of Control or Asset Disposition
In the event of any merger, acquisition, sale, or change of control, we'll continue to ensure the confidentiality of your data and give affected users notice before personal data is transferred or becomes subject to a different privacy policy.
(4) Companies Using Tutorludi Business Services
We may share the Authorized Users' language learning progress and language assessment test results with their employers.
(5) Tutorludi Independent Contractors
We work with independent contractors who help us provide you with our Services. Specifically, we may engage such contractors to assist us with data analytics and software development, customer support, promotion, marketing, user research, and financial and legal matters. These contractors will only have access to your data on a need-to-know basis and under strict privacy and security obligations.
6. Other Users of the Tutorludi Platform
Your data may also be visible to visitors and users of the Tutorludi Platform. This can happen via personal contacts (between student and tutor) or in connection with the Platform's social features. For example, your profile picture and name may be visible if you have signed up for a group class or left a tutor review.
7. How Long Will the Personal Data Be Processed and Stored by tutorludi?
Tutorludi will store your data for no longer than necessary for the purposes for which the personal data is processed.
Generally, tutorludi retains your data as long as your account is active. If your last activity on Tutorludi was over two years ago, your account will be considered expired. In this case, or when you decide to delete your tutorludi account, we undertake to remove your data from our active systems and servers within 90 days or earlier.
However, in case of conflict situations in progress, tutorludi may retain your data for longer to establish, exercise, or defend legal claims. Upon settlement of the conflict situation, we will delete all personal data if the standard retention period has expired.
We may also retain some of your data for longer if we need it to comply with the applicable legal, regulatory, tax, accounting, or other requirements.
We will store personal data collected when you register on our mailing list or for the newsletter if you want to receive our emails. We consider you interested until you unsubscribe from the mailing list or the newsletter by clicking the link in our emails.
We will merge and store this information with your account data if you have registered for any of our events or webinars using your account credentials. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar.
Lists of sweepstakes participants, including those who entered the sweepstakes via the alternative method of entry (mail-in), will be deleted 30 days after the sweepstakes close. The names of the sweepstakes winners published on our Website will remain publicly available till the withdrawal of your Consent. After the expiration of the retention period, tutorludi shall terminate the processing of your data unless otherwise set by the relevant legislation.
Regarding your rights as a data subject regarding your data tutored processes:
1. Right of Confirmation: You can obtain confirmation from Tutorludi whether your data is being processed.
2. Right of Access: You can access your data processed by Tutorludi.
3. Right to Rectification: You can ask Tutorludi to have incomplete personal data requiring corrections.
4. Right to Erasure (Right to Be Forgotten): You can request Tutorludi to erase personal data. In most cases, tutorludi will erase it unless otherwise required by legislation.
To delete your data, you can:
- Contact us by email at support@tutorludi.com
We will respond to your request to delete your information within 30 days and notify you of the outcome.
- Delete specific items from your account (such as your payment method, etc.) by going to your account "Settings" page at https://tutorludi.com/settings (https://tutorludi.com/settings).
- Delete your entire account by going to your account "Settings" page at https://tutorludi.com/settings (https://tutorludi.com/settings) and following the instructions for deleting your account.
5. Right of Restriction of Processing: You can contest the accuracy of your personal data or request processing to be restricted for different reasons.
6. Right to Data Portability: You can have your data transmitted directly from one controller to another where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
7. Right to Object to Processing Your Data by Tutorludi: You can object to our data processing under certain circumstances.
If you believe our data use violates your rights, you can complain to the competent data protection authority. Please note that when your data is processed for direct marketing purposes, you have the right to object at any time to such processing without providing any justification.
tutorludi also ensures high data privacy and compliance standards for cross-border transfers and takes security measures to protect your information. We will provide information on action taken on your request related to your rights within one month of receipt of the request.
8. Right to Withdraw Consent at any Time by Contacting Us
After we at Tutorludi receive your withdrawal request, we will process it on time and no longer process your data unless required by law.
If one of the reasons mentioned above applies, don't hesitate to contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.
If you believe our data use violates your rights, you can complain to the competent data protection authority.
Please note that when your data is processed for direct marketing purposes, you have the right to object at any time to such processing without providing any justification, and we will no longer process your data for such purposes.
8. Other Privacy Commitments
(1) Cross-border Transfers
We process your data both within the United Kingdom and outside the United States. Although the laws of the countries where we process data may differ, we take measures to ensure high data privacy and compliance standards (as provided in Section 5 of this Privacy Policy).
(2) Time for Reply and Reaction
tutorludi will provide information on action taken on your request related to your rights specified above within one month of receipt of the request. That period may be extended by two months if Tutorludi is overwhelmed by the number of requests or if the request is complicated and requires a lot of action. tutorludi will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.
(3) Security
tutorludi takes technical and organisational measures to ensure the information is processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage. For example, tutorludi uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.
(4) Accessing Account to Provide Support
In exceptional circumstances, such as when customer support is required, our support specialists may need to access your account. When such an occasion occurs, they can see the personal data submitted to your account, including your scheduled personal events, if your Google Calendar and Tutorludi Calendar are connected.
We undertake to always ask for your permission to access your account before we start troubleshooting. Before granting us your permission, consider editing your Google Calendar privacy settings with the Google Calendar Help Center to hide your events from us.
Please note that customer support may be delayed and affected if you do not want to grant permission to access your account.
(5) Children's Privacy
The privacy of children is one of our concerns. tutorludi Services are not intended for use by children under the age of 18 without the supervision of their parent or legal guardian. If you are under the age of 18 but not less than the age of 13, you will need to ask your parent/legal guardian to set up an account on the Tutorludi Platform that you may use under their supervision.
We do not knowingly collect information from children under 13 and discourage their use of tutorludi Services. We encourage parents and legal guardians to monitor their children's Internet usage and help enforce our Privacy Policy by instructing their children never to provide information on the Tutorludi Platform without their permission.
(6) Breach Notifications
If there is a personal data breach that is likely to result in a high risk of adversely affecting your rights as the data subject, we will inform you and the respective data protection agencies as to the accidents without undue delay. We would also do our best to minimise any such risks.
(7) "Do Not Track" Requests
tutorludi does not share personal data with third parties for direct marketing purposes. Also, our Services do not support "Do Not Track" requests.
(8) In London, privacy rights are primarily governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As a resident, you have several critical rights concerning your data:
1. Right to be Informed: You must be informed about how your data is used. This includes details of the data collected, the purposes for processing it, and who it is shared with.
2. Right of Access: You can access the personal data that organisations hold about you.
3. Right to Rectification: If your data is inaccurate or incomplete, you have the right to correct it.
4. Right to Erasure: Also known as the "right to be forgotten," you can request the deletion of your data under certain conditions.
5. Right to Restrict Processing: You can request the restriction or suppression of your data under specific circumstances.
6. Right to Data Portability: You can obtain and reuse your data across different services, allowing you to move, copy, or transfer it quickly.
7. Right to Object: You can object to processing your data in certain situations, such as direct marketing.
8. Rights related to Automated Decision-Making and Profiling: You have rights related to automated decision-making and profiling, ensuring you are not subject to a decision based solely on automated processing without certain protections.
These rights allow individuals in London and the wider UK to have greater control and transparency over how their data is handled.
The tutor undertakes to treat you like everyone else and not discriminate against you if you choose to exercise your rights. To submit the request to exercise your rights, please email support@tutorludi.com
(9) Automated Decision-Making and Profiling
As a part of the Tutorludi Platform functionality, we process the personal data of our tutors and students in a way that might be considered profiling.
This is done to increase the efficiency of matching students and tutors on the Tutorludi Platform and allow tutors to connect with the optimal number of students who best suit their way of working.
Please note that this type of processing is necessary to provide our Services.
If you want to request human intervention, express your point of view, or contest the algorithms' decisions, please email us at supportl@tutorludi.com
(10) Sale of Personal Data
We do not sell your data and the personal data of any minors under 16 years of age.
9 Data Privacy Framework Programme
(1) Participation in the Data Privacy Framework Programme
For personal data processed within the scope of this Privacy Policy, tutorludi, Inc. adheres to the United Kingdom General Data Protection Regulation (UK GDPR), the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as outlined by the U.S. Department of Commerce. tutorludi, Inc. has certified its compliance with the EU-U.S. DPF Principles for processing personal data received from the European Union under the EU-U.S. DPF and from the United Kingdom (including Gibraltar) under the U.K. Extension to the EU-U.S. DPF. Additionally, tutorludi, Inc. has certified its adherence to the Swiss-U.S. DPF Principles for processing personal data received from Switzerland under the Swiss-U.S. DPF. In case of any discrepancies between the terms in this Privacy Policy and the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, the Principles will take precedence.
To find out more about the Data Privacy Framework (DPF) programme and to access our certification, please visit [https://www.dataprivacyframework.gov/](https://www.dataprivacyframework.gov/).
(2) DPF Principles-Related Complaints
In alignment with the EU-U.S. DPF, the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, tutorludi, Inc. is dedicated to resolving DPF Principles-related complaints concerning collecting and utilising personal information. Individuals from the E.U., U.K., and Switzerland with complaints regarding how their data is done under the EU-U.S. DPF, the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF are encouraged to first contact tutorludi, Inc. at [support@tutorludi.com)
(3) Dispute Resolution
Where a DPF Principles-related complaint cannot be resolved through tutorludi, Inc.'s internal process as described above, in compliance with the UK Data Protection Framework (UK DPF), we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the UK DPF to the Information Commissioner's Office (ICO), an alternative dispute resolution provider based in the United Kingdom. If you do not receive timely acknowledgement of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit [https://ico.org.uk/make-a-complaint/](https://ico.org.uk/make-a-complaint/) for more information or to file a complaint. ICO services are provided at no cost to you.
(4) Binding Arbitration
You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms (see DPF Principles-Related Complaints section and Dispute Resolution section). For additional information, please visit [Data Privacy Framework Annex I: Arbitral Model](https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2).
(5) U.K. Oversight
The Information Commissioner's Office (ICO) has jurisdiction over Tutorludi, Inc.'s compliance with the UK DPF and is subject to the ICO's investigatory and enforcement powers.
(6) Disclosure of Personal Information to Law Enforcement Officials
Tutorludi, Inc. may disclose your personal information to the extent required by law or if we have a good-faith belief that we need to disclose it to comply with official investigations or legal proceedings (whether initiated by the government or law enforcement officials or private parties, including to meet national security or law enforcement requirements).
(7) Liability in Cases of Onward Transfers to Third Parties
In the context of an onward transfer, Tutorludi, Inc. is responsible for processing the personal information we receive under the DPF Principles and transferring it to a third party acting as an agent on our behalf. Tutorludi, Inc. shall remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with the DPF Principles unless we prove that we are not responsible for the event giving rise to the damage.
10. Legal Matters
Tutorludi considers your use of the Services to be private. However, we may disclose your data stored in our databases to:
(1) comply with the law or legal process served on us;
(2) enforce and investigate potential violations of this Privacy Policy, including the use of the Services to participate in or facilitate activities that violate the law;
(3) investigate potential fraudulent activities; or
(4) protect the rights, property, or safety of Tutorludi, its employees, customers, or the public.
Here at Tutorludi, we will protect your data so you can use our Services without worrying about your privacy. If you have any questions, email us at support@tutorludi.com.
Your Tutorludi Team.