Privacy promise

At toota we understand how important your privacy and personal data are. We’re committed to protecting and respecting your privacy and data. We ask that you read this privacy promise carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and other organisations in the event you have a complaint

Introduction

We are toota (herein referred to as ‘us’, ‘we’, ‘our’), a trading name of Intuition Clubs Limited which is a wholly owned subsidiary of the Supporting Education Group Limited (the ‘Group). In this privacy statement, references to ‘you’ and ‘your’ are references to the User of www.toota.me (the ‘site’) regardless of whether you are a Client or a Tutor or a holder of parental responsibility for a Client under the age of eighteen (18) years of age or other user

In order that we can provide tutoring and academic support (collectively, our ‘service’), we collect and use certain personal data. Personal data means any information about you from which you can be identified, but it does not include information where your identity has been removed and is sometimes referred to as anonymous data. As the ‘data controller’ of your personal data when using our service, we are responsible for how that data is managed and will ensure that the personal data we hold about you is:

  • Used lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes we have told you about
  • Kept securely

The Data Protection Act 2018 and The General Data Protection Regulation (GDPR Regulations EU 2016/679) and related United Kingdom legislation, set out our obligations to you and your rights in respect of how we manage your personal data

If you have any questions about this privacy statement or would like further explanation as to how your personal data is managed then please contact us by emailing our Data Protection Office at dpo@supportingeducation.com

The personal data we collect and use

Here we outline how we collect and use personal data in relation to people who enquire about and use our service

Information collected by us

We only collect and process information as a necessary part of entering into and performing our contract with you, which is governed by our Terms and Conditions, and so that we can provide the best possible service for you. We will not collect any personal data that you do not voluntarily provide. If you are aged under 13, please get your parent/guardian’s permission before you provide any personal information to us. When you enquire about our service through our site, phone, email, post, face to face or social media, when you create an account, and during the course of providing service to you we collect the following personal data and information when you provide it to us:

  • Your account information to enable us to create an account for you on the site. Dependant on whether you register as a parent, student, tutor or other user, this information can include your name, email, telephone number, postal address and date of birth
  • Your tutor application details so we can process your application to become a tutor. These details can include your education background and qualifications, your tutoring subjects, your resume, your availability, your gender and information required for identity verification, safeguarding (a DBS, if applicable) and professional vetting checks. We also ask for information to demonstrate that you have the right to work in the UK
  • Your communication history, complaints, compliments, questions or concerns about the service we provide
  • Your booking history, requests, status and feedback to facilitate and record tutorials
  • Your feedback and contributions to questionnaires and surveys about the service we offer
  • Promotions and referral codes shared with you, redeemed and other promotions you interact with

In addition to the above information, all electronic based conversations and notebooks are digitally captured during a lesson and stored to enable future playback by you or our representative

When using our service, we collect information about the purchase or financial transaction and how you use our service. We also use analytics tools and collect standard internet log information (commonly known as cookies), including but not limited to:

  • IP address
  • Details of the pages you visit, and actions taken
  • General details about the type of computer or device that you are using
  • Times and dates of actions you take on our site, and your page response times
  • Your interactions with our email, text and in-app messages
  • The source of your visit and/or previous webpage before visiting our site
  • Your interactions with other users

This is statistical information which we collect in order to determine the performance of our service, including what pages you visit, how much time you spend on each page and various data about how you use and interact with us. The information provided allows us to provide you with more relevant product offerings and a better experience. See our full cookie policy for more information Cookies policy

Please be aware that our site may provide you with links to other websites. If you follow a link to any other website, please note they have their own privacy promises. We do not accept any responsibility or liability for the privacy and security practices of such third party websites and your use as such is at your own risk

Financial information collected from by us

We may require you to provide us with financial information to authorise or process payment and bill you or pay you for the services. These details include for tutors: your nominated bank account, your invoices and your payment history, and for clients your payment history. When you use the service or when you receive payment for delivering the service, we will pass your financial or personal information to those third parties necessary to process your transactions with us, such as banks and credit card companies. The legal basis under GDPR by which we are permitted to process this information in this way is that it is necessary for the performance of a contract to which you are a party or to take steps prior to entering into a contract with you or where we need to comply with a legal obligation. This may include exchanging information with other companies and organisations for fraud protection and credit risk reduction. Except as provided above, we will not share financial information with third parties without your prior consent

Information collected from other sources

We work closely with third parties, such as tutor software vendors and payment service providers, and obtain personal data about you, such as payment and transaction information details

We may utilise this data so that we can update and analyse the accuracy of our records and provide services that may be of interest to you. Users of the service can rate tutors after online lessons, this information can be shared with you if you are a tutor and may be displayed on our site

We do reserve the right, where permitted by law, to collect and use information on you from third party providers. If you provide us personal data about others, or if others give us your information, we will only use that data for the specific reason for which it was provided to us

How we use your personal data

We strongly believe in both minimising the data we collect and limiting its use and purpose to only that

  • for which we have been given permission
  • as necessary to deliver the service you purchase
  • as required or permitted for legal compliance or other lawful purposes

We use your information primarily to fulfil our contract to provide you with the service that you request and related services, which may include site administration and security. We use your personal data for:

  • Enabling you to access the site and create an account
  • Facilitating matching between clients and tutors
  • Provision of service
  • Providing recordings
  • Billing and payment purposes, in accordance with our terms and conditions
  • Communication with you
  • Providing support to you
  • Notifying you about changes to our service
  • Diagnosing problems and/or improving our service
  • Internal audit purposes
  • Fulfilling our safeguarding and legal obligations
  • Preventing fraud, spam and abusive or inappropriate behaviour
  • Empirical research
  • Producing statistical information to inform the business about the service use

Much of the data collected is statistical data about how our service is used, and is not linked to any personal data, but where use of personal data is evident, we will handle this with care

Who we share your personal data with

In order to deliver the service to you we share your personal data with our staff and tutors who require access to carry out their duties and with third parties we rely on to provide specialist support to us. Third parties are subject to strict data processing terms and conditions to ensure the same level of privacy and security that we promise to you, and are prohibited from utilising, sharing or retaining your personal data for any other purpose than that they have been specifically contracted for (or without your consent). To provide this support they will have access to, or a duty of care over your personal data. These providers are:

  • Software companies – to provide specialist services, support and resolve issues with the software that we run, for example online tutoring
  • Communication platforms – for the delivery and analysis of email, text and in-app communications
  • Marketing platforms - to organise marketing communications and conducting surveys
  • Payment processing companies – to provide credit or debit card transactional processing services
  • Identity verification tools
  • Analytics providers
  • Data archiving companies – responsible for the secure storage and destruction of records

We will not share, sell or trade your personal data to other third-parties outside of the Group without your consent

Compliance with Legal, Regulatory and Law Enforcement Requests

We will share personal data with government, law enforcement or other authorities if legally required to do so. This includes information required by public bodies to evidence our compliance with any applicable regulatory framework

We will disclose any information about you to government, law enforcement officials or private parties as we believe necessary or appropriate to respond to legal processes, to protect our property and rights or the property and rights of a third party, to protect the safety of others, or to prevent or stop activity we consider to be illegal or unethical. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal data to third parties as part of a legal process

If we are obliged to disclose personal data by law, or if the disclosure is necessary for purposes of national security, taxation and criminal investigation or to safeguard a child, we will do so. In some circumstances, you may not be notified first

How long your personal data will be kept

We will not retain your personal data any longer than is necessary to provide our service to you, and no longer than the statutory limits as set out relevant data protection legislation, or if you instruct us to delete the personal data about you that we hold

By default, we retain personal data for 6 years after you have last been active on the site. This is to allow you to continue to use your account for the duration of the average lifecycle of a user. After the period has passed or after you request us to delete your data, whichever is earlier, we will delete your personal data except where we have specific reason which means we need to keep it longer. Records that you have shared publicly or have shared with another user may remain on the site after your personnel data has been deleted but will no longer have identity information which links them to you

We may retain records where necessary to fulfil our regulatory or statutory duties. We will hold financial records and transactions for 7 years in line with our legal requirements

Reasons we can collect and use your personal data

You have given consent for us to process your personal data for the purpose of delivering our service to you. Our terms and conditions, which you have read and accepted, forms the agreement between yourself and us, and the processing of your data is necessary for us to comply with our legal obligations

International transfers

All your personal data is stored and processed on systems that are within the European Economic Area (EEA) and offer the same level of legal protection and rights over your data

Your rights

Under the GDPR you have important rights free of charge. In summary, those include rights to:

  • Fair processing of information and transparency over how we use your data
  • Access to your personal data
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure (i.e. deletion) of personal data concerning you, in certain situations. Please note that if you ask us to delete any of your personal data which we believe is necessary for us to comply with our contractual or legal obligations, we may no longer be able to provide service to you
  • Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

If you wish to exercise any of your rights, find any mistakes in your information we hold or you would like your personal data removing from our database, please contact us. For further information on your rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation

How to contact us

You can contact us by:

  • Email – dpo@supportingeducation.com
  • Post – Data Protection Office, Supporting Education Group Limited, 99 Bridge Road East, Welwyn Garden City, Herts, AL7 1GL, United Kingdom

If you would like to exercise any of those rights, please:

  1. Contact us using the details above – making clear that you wish to exercise one of your information rights
  2. Let us have enough information to identify you (e.g. your name and address)
  3. Let us know the information to which your request relates, including any account or reference numbers, if you have them

If you would like to unsubscribe from any marketing emails you can also click on the ‘unsubscribe’ button at the bottom of the marketing emails. It may take up to 14 days for this to take place

Keeping your personal data secure

The confidentiality and security of your information is of paramount importance to us. We use our best efforts to ensure we have appropriate organisational and technical security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so

You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, or to or from our online services. You accept that we cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential information which you do not wish to communicate by email, please contact us by telephone or post to arrange an alternative method of communication. You transmit all such information at your own risk

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at ico.org.uk/concerns/ or telephone: 0303 123 1113

Data Protection Officer
Steve Bryce,
Supporting Education Group Limited,
99 Bridge Road East,
Welwyn Garden City,
Herts,
AL7 1GL
dpo@supportingeducation.com

Additional information

Sale of the Business

If our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business

Changes to this privacy promise

We may update this privacy statement from time to time, so you may wish to check it each time you access or submit personal information to us. The date of the most recent revisions will appear below:

Last Amended: 29th April 2019