Tutorludi is dedicated to safeguarding your personal information. We have strived to craft this Privacy Policy in the most straightforward and unadorned language possible. Similarly, we have aimed to present our privacy commitments in a transparent and readily accessible manner. With that in mind, we hope you will find all the necessary details to ensure your data is secure with us.
Before you consent to the processing of your data or provide us with your data through any form on our Website, please read this Privacy Policy thoroughly so you can be fully aware of the conditions under which we would engage.
This Privacy Policy applies to your use of Tutorludi’s services, as outlined in our Terms of Service. It clarifies when, where, and why we process the personal data of individuals who use the Tutorludi Platform, how we use it, the circumstances under which we may disclose it to others, your rights regarding your data, and how we ensure its security.
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 as mentioned earlier.
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 change this Privacy Policy occasionally, 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 legal@tutorludi.com (mailto:legal@tutorludi.com).
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 clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
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 personalized 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 analyzing 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 are not able to do so following our obligations under any applicable legislation.
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 also 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 also 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 acknowledge 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 transactions you carry out through the Tutorludi Platform (such as I.D., date and time of transaction).
(7) Tutorludi Business
We may collect your name, email, company name, and phone number to give you more information regarding Tutorludi Business Services, as defined in Tutorludi Business Terms.
(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 analyze 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 subsection (10) of section (4) of this Privacy Policy, we will also collect and process your interaction data 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.
Required for Submitting Tax Documentation
To adhere to applicable tax and accounting laws, we may need to collect and submit various tax documents that include your personal information. This could involve federal tax form 1099 or other necessary tax forms for receiving sweepstakes prizes or for tax withholding purposes. For tax documentation purposes, we may process personal data such as your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.K. Taxpayer identification number or foreign tax identifying number.
The Directive (E.U.) 2021/514 (DAC7) mandates us, as a digital platform operator, to collect, verify, and report data on reportable sellers (i.e., tutors subject to DAC7) engaging in relevant activities through the tutorludi Platform. To fulfil our DAC7 reporting duties, we may process your first name, last name, primary address, date of birth, tax identification number (TIN), VAT number, and financial account identifier (e.g., bank account).
(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 support@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 and for A.I. data training purposes. 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.
We process the personal data you voluntarily provide for the purposes outlined below. Processing your data allows us to personalize 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 authorize 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.
We also invite you to take a language assessment test to determine your proficiency level.
For companies utilizing 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.
(3) Referral Programs
Through our “Tell-A-Friend” referral program, we generate a personalized 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. Upon initial contact, we will inform your colleagues that we’ve received their data as part of our referral program.
(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 record, audio record, or webcast your feedback without first 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 optimization.
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 personalized 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 analyze 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 analyze 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 personalized “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, optimize and serve you 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 lessons given by tutors on Tutorludi, we collect and process tutor credentials to verify their eligibility to teach the subjects they claim to teach. We also cooperate with the 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. From time to time, we conduct learning-focused competitions for individuals who meet certain criteria. Participants must fill in the registration forms to register for the competition and prove they are eligible. We process this information exclusively to organize 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 certain 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.
Providing quality services makes Tutorludi enter into agreements with independent contractors and cooperate with other service providers, companies, and organizations 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 optimization 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 subsection 12 of section 3 of this Privacy Policy.
(2) Use of Social Network Platforms
We maintain Tutorludi’s social media pages on social network platforms like 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.
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.
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.
tutorludi will store your data processed by AI-powered tools for A.I. data training purposes for two years in the E.U. and longer for non-EU jurisdictions.
However, in case of conflict situations in progress, tutorludi may retain your data for longer to be able 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, which will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the link in each of our emails.
If you have registered for any of our events or webinars using your account credentials, we will merge and store this information along with your account data. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar.
Lists of participants of the sweepstakes, including those who entered the sweepstakes via the alternative method of entry (mail-in), will be deleted 30 days after the close of the sweepstakes. 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 as to whether personal data concerning you 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 (mailto: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 of Your Data by Tutorludi: You can object to our processing of your data under certain circumstances.
If you believe that our use of your data violates your rights, you can complain to the competent data protection authority. Please note that when the processing of your data is carried out for direct marketing purposes, you have the right to object at any time to such processing without providing any justification.
tutorludi also ensures high standards of data privacy and compliance 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 a withdrawal request from you, we will process it on time, and we will no longer process your data unless otherwise set by law.
If one of the aforementioned reasons applies, please 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 that our use of your data violates your rights, you can complain to the competent data protection authority.
Please note that when the processing of your data is carried out 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 direct marketing purposes.
(1) Cross-border Transfers
We process your data both within the United States and outside the United States. Although countries where we process data may have different laws, we take measures to ensure high standards of data privacy and compliance (namely, 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 further months if Tutorludi is overwhelmed by the number of requests or if the request at issue 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 organizational measures to ensure the information is processed in a manner that ensures appropriate security, including protection against unauthorized 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 will be able to 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 if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.
(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) California Privacy Rights
If you are a resident of California, you are entitled to certain rights over your data under the California Consumer Privacy Act of 2018. Specifically, as a resident of California, you have the right to:
● know about the categories and specific pieces of personal data that we have collected about you and access a copy of your data (“Right to Know”);
● have inaccurate personal data about you corrected (“Right to Correction”);
● request deletion of your data that we have collected (“Right to Deletion”);
● opt out of the sale of your data (“Right to Opt-Out”).
Please note that we may ask you and/or your agent to provide certain information to verify your and/or your agent’s identity and authorization before fulfilling the request. The information we request will depend on your prior interactions with us.
For more information about the personal data we collect and how we collect it, please refer to sections 2 and 3 of this Privacy Policy. To learn about the purposes for which your data is collected and the categories of service providers who have access to your data, please refer to sections 4 and 5.
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 send an email to legal@tutorludi.com (mailto:legal@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.
Specifically, we use machine-learning algorithms that analyze various metric-based data and determine the tutor’s ranking on the tutored Platform and their visibility to students. This is done to increase the matching efficiency between students and tutors on the Tutorludi Platform and allow tutors to connect with the optimal number of students who best fit their way of working.
Please note that this type of processing is necessary to provide our Services. To know more about this process and the logic involved, please refer to Section 3.6 of our Terms of Service.
If you want to request human intervention, express your point of view, or contest the algorithms’ decisions, please email us at legal@tutorludi.com (mailto:legal@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.
(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/].
(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 utilizing 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 [legal@tutorludi.com](mailto:legal@tutorludi.com) or [dpo@tutorludi.com](mailto:dpo@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].
(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 subsequently 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.
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.