Last updated: August 18, 2019
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
1. Important information and who we are
We request that the parent/guardian completes our booking forms/provides information about the child who is going to use our tutoring services. We confirm that we are collecting and processing personal data about children in order to provide our services.
Full name of legal entity: Expertease Tuition Limited
Email address: firstname.lastname@example.org
Telephone number: 07414 907628
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name of you and the first name, last name of the child using our services.
• Contact Data includes billing address, email address and telephone numbers.
• Transaction Data includes details about payments from you and details of services you have purchased from us.
• [Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.]
• [Usage Data includes information about how you use our website and services.]
• [Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.]
We do collect data on children who are going to use our service and this may include Special Category Data, relating to their health and disabilities or learning difficulties they may have, whether they are in the care of a local authority.
We require your consent to process special category data of the child your are the parent or guardian of. Please tick the box below to provide consent:
I consent to the processing of special category data
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
• book an initial meeting with one of our tutors;
• book our services;
• subscribe to our publications;
• request marketing to be sent to you;
• give us feedback or contact us.
Technical Data from the following parties:
(a) analytics providers [such as Google based outside the EU];
(b) advertising networks [such as [NAME] based [inside OR outside] the EU]; and
(c) search information providers [such as [NAME] based [inside OR outside] the EU].
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the EU].
• [ANY OTHER WAYS YOU COLLECT PERSONAL DATA].
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Category of Personal Data Purpose/Activity Lawful basis for processing including basis of legitimate interest
Identity and Contact Data (i) To register you as a new customer;
(ii) For administration purposes, to record our transactions with you.
(iii) To deliver notifications and relevant marketing materials. (a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to manage our business).
(c) Necessary for our legitimate interest (to develop and grow our business).
Transaction Data (i) For administration purposes (a) Necessary for our legitimate interest to manage, develop and grow our business.
[Technical Data ] [Such as Electronic identification data including IP address and information collected through cookies and device and browser details] TBC [To enable us to analyse the use of the Website and help improve the Website’s usability.] [(a) Necessary for our legitimate interest (to define types of customers for our services, to keep our website up to date and relevant, for business development purposes)]
[Usage Data] TBC
Special categories of personal information (i)To enable us to prepare the tutors for the provision of our services.
(a) Performance of a contract with you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
• External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.