TutorTech Data Privacy Policy

Updated: 1^st May 2026

Version: v2.4

This Data Privacy Policy ("Policy") explains how TutorTech Ltd. ("TutorTech", "we", or "us") collects, uses, and discloses information, including personal data, about you when you use our website, learning platform, mobile apps, Marketplace, private microsites and other services (collectively, the "Services").

TutorTech operates a technology platform that enables independent Tutors to offer tutoring services directly to Customers, allows TutorTech to provide certain Classes, and enables approved Tutors to create and sell educational digital content through the TutorTech Marketplace.

TutorTech may also provide private microsite access for schools, sports academies, SEND providers or similar organisations, where Students and Parents/Guardians can access relevant tutoring, classes, learning support or educational content through shared links.

This Policy explains how personal data is processed in connection with the operation of the TutorTech platform, Marketplace, private microsites, tutoring services, Classes, payments, communications, safeguarding and related services.

This Policy should be read together with our Terms of Service ("TOS"), Marketplace Terms, Safeguarding Policy, User Code of Conduct, Payment and Cancellation Policy, Cookie Policy and any other policies that apply to your use of the Services. By using our Services, you agree to the practices described in this Policy.

1. Information We Collect

We collect information about you in several ways when you use our Services:

Information you provide

This includes information you give us when you:

·       create an account;

·       apply to become a Tutor;

·       complete Tutor onboarding;

·       connect Stripe Connect or other payment functionality;

·       enrol in a course or book tutoring services;

·       purchase or access Marketplace content;

·       create, upload, list or sell Marketplace content;

·       access a private school, sports academy, SEND or organisation-linked microsite;

·       request information or contact customer support;

·       submit reviews, ratings, comments or complaints;

·       participate in platform features.

Examples include your name, email address, phone number, location, account details, role type, communication preferences, purchase history, support messages, consent records and platform activity.

For Tutors, this may also include:

• qualifications and verification information;
• identity, safeguarding, DBS or suitability information, where applicable;
• business and service-related information, such as service descriptions, pricing, availability, trial lesson settings and public profile information;
• Tutor application and onboarding information;
• signed agreement records and policy acceptance records;
• payment-related information required to facilitate payouts via Stripe Connect or similar services, processed by Stripe or relevant payment providers;
• Tutor profile visibility and search indexing preferences;
• communications with Customers, Students, TutorTech or support teams;
• lesson, Class or Marketplace activity linked to the Tutor account.

For Marketplace Sellers

For approved Tutors who create, upload, list or sell Marketplace content, this may also include:

• Marketplace seller status;
• content listings;
• uploaded content files;
• resource descriptions;
• content previews, images, titles, subjects, categories, age ranges and tags;
• pricing information;
• sales records;
• refund, dispute and chargeback information;
• ratings, reviews and buyer feedback;
• content access records;
• copyright, intellectual property, safeguarding, quality or complaint records;
• AI-assisted or AI-generated content declarations, where applicable.

For Marketplace Buyers

For Customers, Tutors or other permitted users who purchase, access or download Marketplace content, this may include:

• purchase history;
• download or access records;
• content licence records;
• refund requests;
• support messages;
• ratings, reviews and feedback;
• payment status and transaction records;
• records of digital delivery consent, where applicable.

For users accessing school, sports academy, SEND or organisation-linked microsites

Where users access services through private microsites, shared links or organisation-linked pages, this may include:

·       microsite access records;

·       organisation-linked class enrolments;

·       Student name and account details;

·       Parent/Guardian name and contact details;

·       attendance information;

·       subject, year group, curriculum, topic or learning pathway information;

·       learning progress and engagement information;

·       sports academy qualification requirements or educational support needs, where relevant;

·       SEND support needs or service-related information, where provided by a Parent/Guardian or relevant specialist;

·       parent/guardian consent records;

·       anonymised or aggregated progress data;

·       student-specific progress data where appropriate consent or another lawful basis applies.

Lesson recordings, including one-to-one and multi-student sessions, may capture voice, image, screen content, chat messages or lesson participation information, but only where this is permitted and handled in accordance with the Terms of Service, this Policy and applicable consent or notice requirements.

Information collected automatically

We automatically collect certain technical and usage information when you use our Services, including:

• Device type and operating system
• IP address
• Browser type
• Pages visited and interactions on the platform

We also use cookies and similar technologies to collect information about how users interact with our Services. Further details are set out in our Cookie Policy.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To operate and maintain the Tutortech platform
• To connect Students with Tutors and facilitate online learning
• To operate a tutoring marketplace, including displaying Tutor profiles and services
• To manage accounts, bookings, subscriptions, and payments
• To facilitate payments and payouts via Stripe Connect and comply with financial and regulatory obligations
• To personalise user experience and recommend relevant Tutors or services
• To communicate with users regarding accounts, services, updates, and support requests
• To manage referral and affiliate relationships
• To analyse usage and improve platform performance and user experience
• To measure marketing effectiveness using tools such as Google Analytics, Microsoft Clarity, and Google Ads, where permitted by law
• To comply with legal and regulatory requirements
• To enforce our Terms of Service and platform policies
• Where a Tutor has explicitly opted in, Tutortech may include selected public Tutor profile information in structured metadata files (for example, sitemap or structured data feeds) used to improve discoverability through search engines and promotional discovery features.
• These metadata files do not create standalone public Tutor webpages and contain only approved profile information. Tutors may withdraw this consent at any time via account settings.
• Following withdrawal of consent, the Tutor profile will be removed from future indexing updates. However, due to search engine caching and indexing processes outside TutorTech’s control, previously indexed content may remain visible in search results for a limited period of time.
• To operate the TutorTech Marketplace, including content listings, purchases, downloads, seller tools, buyer access, reviews, refunds, complaints and content moderation.
• To manage Tutor seller access, Marketplace payouts, platform fees, refunds, disputes, chargebacks and transaction records.
• To provide private microsites for schools, sports academies, SEND providers or similar organisations.
• To align TutorTech Classes or learning support with curriculum, topic, year group, qualification, sports academy or SEND-related needs where relevant.
• To provide anonymised or aggregated progress summaries to relevant schools, sports academies, SEND providers or similar organisations.
• To share student-specific progress information with an organisation where appropriate Parent/Guardian consent has been obtained or where another lawful basis applies.

2.1. Marketplace data use

When users buy, sell, upload, list, review or access Marketplace content, TutorTech may process information including:

• content listings;
• content files and previews;
• pricing information;
• seller information;
• buyer information;
• purchase history;
• download or access records;
• digital delivery consent records;
• refund, dispute and chargeback information;
• ratings, reviews and support messages;
• copyright, safeguarding, quality or complaint records;
• AI-assisted or AI-generated content declarations, where applicable.

We use this information to operate the Marketplace, process purchases, provide access to digital content, support buyers and sellers, detect misuse, handle disputes, process refunds, manage seller payouts, enforce our policies, comply with legal obligations and improve the platform.

2.2. School, Sports Academy and SEND Microsite Data Use

TutorTech may provide private microsite access for schools, sports academies, SEND providers or similar organisations.

These microsites may allow Students and Parents/Guardians to access classes, tutoring services, learning support or educational content linked to a particular organisation.

Where applicable:

• schools may share curriculum, topic or progress information so TutorTech can align classes to school learning priorities;
• sports academies may share general educational requirements or qualification expectations so TutorTech can guide appropriate learning support;
• SEND services may be delivered by TutorTech’s internal qualified SEND expertise or by vetted third-party SEND specialists through the platform.

TutorTech may provide anonymised or aggregated progress summaries to the relevant organisation, for example by subject, year group, class series or learning programme.

Student-specific progress information will only be shared with the organisation where the Parent/Guardian has given appropriate consent or where another lawful basis applies.

Where safeguarding concerns arise, TutorTech may share relevant information with appropriate persons, organisations or authorities where necessary and lawful to protect a child or user.

2.3. Safeguarding and children’s best interests

TutorTech processes children’s personal data with regard to safeguarding, privacy, proportionality and the best interests of the child.

Where services are likely to be accessed by children, TutorTech aims to apply appropriate privacy and safety protections, including limiting unnecessary data collection, restricting inappropriate data sharing and providing age-appropriate safeguards where relevant.

TutorTech may process and share information where necessary to protect a child, investigate safeguarding concerns, comply with legal obligations or support the safe operation of the platform.

3. Sharing Your Information

We may share your information with third-party service providers who help us operate and improve our Services. These service providers are obligated to protect your information and use it only for the purposes we specify.

We may also share your information with third parties in the following circumstances:

1. With your consent: We may share your information with third parties when you give us your explicit consent to do so.
2. For legal reasons: We may share your information if we are required to do so by law or in response to a legal process.
3. In the event of a business transfer: We may share your information if we are involved in a merger, acquisition, or other business transaction.

 Marketplace buyers and sellers

Where Marketplace content is purchased, accessed, reviewed, refunded or disputed, limited information may be shared between TutorTech, the buyer, the Tutor seller, payment providers and relevant service providers as necessary to complete the transaction, provide access, handle support, manage refunds, investigate complaints, comply with legal obligations or enforce our policies.

 TutorTech does not sell Marketplace buyer personal data to Tutor sellers.

Stripe Connect

We share personal data with Stripe for payment processing and the payout of tutoring fees to Tutors. Stripe acts as an independent data controller for payment data. Stripe’s privacy practices are governed by its own privacy policy.

 Where a Tutor sells Marketplace content, Stripe Connect or another payment provider may process information needed to facilitate seller payouts, refunds, chargebacks, tax reporting or payment compliance.

 Schools, sports academies, SEND providers and similar organisations

Where a user accesses TutorTech services through a private microsite linked to a school, sports academy, SEND provider or similar organisation, TutorTech may share limited information with that organisation where appropriate.

 This may include anonymised or aggregated progress summaries, attendance summaries, subject-level engagement or class-series performance information.

 TutorTech will only share student-specific progress information with the relevant organisation where:

• the Parent/Guardian has given appropriate consent;
• sharing is necessary to provide the agreed service;
• sharing is required for safeguarding or legal reasons; or
• another lawful basis applies.

 TutorTech does not permit organisations to use student-specific information received from TutorTech for unrelated marketing or commercial re-use.

 SEND specialists and third-party service providers

Where SEND services are provided by TutorTech’s internal qualified SEND expertise or by vetted third-party SEND specialists, TutorTech may share information necessary to assess, provide, support or review the relevant SEND service.

 This may include information provided by a Parent/Guardian, service records, learning support requirements, progress information and safeguarding-related information where relevant.

 TutorTech will seek to limit SEND-related data sharing to what is necessary for the relevant service and will handle such information with appropriate care due to its sensitive nature.

Analytics, Advertising, and Payment Providers

We share limited personal and usage data with trusted third-party providers, including Google, Microsoft, and Stripe, for analytics, advertising measurement, payment processing, fraud prevention, and platform operation. These providers process data in accordance with their own privacy policies.

4. Your Choices

You have choices regarding your information:

1. Accessing and Updating Your Information: You can access and update your account information at any time by logging into your account and visiting your profile settings.
2. Marketing Communications: You can choose not to receive marketing communications from us by following the unsubscribe instructions in those communications or by contacting us at customer.service@tutortech.co.uk.
3. Cookies: You can control how cookies are used on your device by adjusting your browser settings.
4. Public Tutor Profile Visibility: Tutors can enable or disable public search indexing of their Tutor profile at any time via their account settings.

Progress sharing for private microsites

Where a Student accesses services through a school, sports academy, SEND provider or similar microsite, Parents/Guardians may be asked to consent to student-specific progress information being shared with that organisation.

 Parents/Guardians may contact TutorTech to understand or manage applicable consent options.

 Anonymised or aggregated progress summaries may be shared with the relevant organisation without identifying individual Students, where appropriate and lawful.

 Marketplace content visibility

Tutor sellers may manage certain Marketplace listing visibility settings through their Tutor account, subject to platform rules, prior purchases, legal obligations and TutorTech’s rights to retain records.

 Removing a Marketplace listing from sale may not remove access for buyers who have already purchased or accessed that content.

Reviews and ratings

Users may be able to submit reviews, ratings or feedback about Tutors, Classes or Marketplace content. Where available, users may request support regarding reviews that they believe are inaccurate, inappropriate or in breach of TutorTech policies.

5. Data Retention

We will retain your information for as long as necessary to fulfil the purposes described in this Policy unless a longer retention period is required or permitted by law.

Retention periods may vary depending on the type of information and the reason it is processed. For example, TutorTech may retain:

• account records while the account remains active and for a reasonable period afterwards;
• payment, purchase, refund, chargeback and payout records for accounting, tax, dispute and compliance purposes;
• Tutor application, onboarding, agreement and verification records for compliance, safeguarding, audit and dispute purposes;
• Marketplace listing, purchase and access records to support previous purchases, refunds, complaints, legal obligations and platform integrity;
• safeguarding-related records for as long as reasonably necessary to protect users and meet legal or regulatory obligations;
• consent records, including progress-sharing consent, digital delivery consent, recording consent and profile indexing consent, for audit and compliance purposes.

Where possible and appropriate, TutorTech may anonymise or aggregate information so that it no longer identifies individual users.

6. Security

We take reasonable steps to protect your information from unauthorised access, disclosure, alteration, or destruction. However, no Internet transmission or electronic storage is completely secure.

Access to personal data is limited to users, staff, contractors, specialists and service providers who need access for legitimate platform, support, safeguarding, payment, legal or operational purposes.

Where sensitive or child-related information is processed, TutorTech aims to apply additional care, access control and proportionality.

7. Children's Privacy

Our Services are not intended for children under the age of 7.

Children under 18 may use certain TutorTech services with the involvement, permission or supervision of a Parent/Guardian, as described in our Terms of Service.

TutorTech aims to collect and process only the information reasonably required to provide, safeguard, support and improve the relevant service. This may include Student name, year group, subject, attendance, engagement, learning progress, class participation, lesson records, support needs and other information needed to deliver tutoring, Classes, Marketplace content, private microsite services or learning support.

Where children access TutorTech services through tutoring, Classes, Marketplace content, private microsites or the Learner Management Platform, TutorTech aims to handle their data with particular care and with regard to the child’s best interests.

Where student-specific progress information may be shared with a school, sports academy, SEND provider or similar organisation, TutorTech will seek appropriate Parent/Guardian consent unless another lawful basis applies.

Where safeguarding concerns arise, TutorTech may process and share relevant information where necessary and lawful to protect a child or user.

If you are a Parent/Guardian and believe your child has provided us with personal information that should not have been provided, please contact us at legal@tutortech.co.uk.

8. Your Right to Access Your Data (Subject Access Request)

The General Data Protection Regulation (GDPR) grants you the right to access your personal data that we hold. This is known as a Subject Access Request (SAR).

How to Submit a Subject Access Request

To submit a Subject Access Request, please follow these steps:

1. Contact Us: Submit your request in writing to our Data Protection Officer at:
• Email: privacy@tutortech.co.uk
2. Verification: To protect your privacy and security, we will take steps to verify your identity before processing your request. This may involve requesting additional information, such as a copy of your government-issued ID.
3. Responding to Your Request: We aim to respond to your request within one month of receipt. However, this timeframe may be extended by an additional two months if the request is complex or we receive a high volume of requests. We will notify you if an extension is necessary. Where a request relates to a child’s personal data, TutorTech may take additional steps to verify the identity and authority of the person making the request and to consider the child’s rights, age, understanding, welfare and best interests.
4. Providing Your Information: If your request is valid, we will provide you with a copy of your personal data in a commonly used electronic format (e.g., PDF).
5. Fees: In most cases, we will not charge you a fee to process your request. However, we may charge a reasonable fee if your request is manifestly unfounded, excessive, or repetitive. We will inform you of any potential fees before processing your request.

Additional Information:

• You can find more information about your data protection rights under the GDPR on the website of the Information Commissioner's Office (ICO) at https://ico.org.uk/.

9. Data Controller roles

TutorTech acts as a data controller for its own platform operations, including account management, platform administration, payments, safeguarding, analytics, communications, Marketplace operations, support, dispute handling and legal compliance.

Tutors act as independent data controllers in relation to the tutoring services they provide and in relation to any personal data they independently process when delivering tutoring services or managing their own Tutor business.

Tutor sellers may act as independent data controllers for certain Marketplace seller activities, including content they upload, buyer communications they receive where applicable, and records they are required to maintain for their own legal, tax or business purposes.

Stripe acts as an independent data controller for payment and payout data processed through Stripe Connect or other Stripe services.

Schools, sports academies, SEND providers and similar organisations may act as independent data controllers for personal data they provide to TutorTech or receive from TutorTech, where applicable.

Third-party SEND specialists may act as independent controllers or processors depending on the service arrangement and the nature of the support provided.

TutorTech may act as a processor, joint controller or independent controller depending on the specific processing activity, the service being provided and the applicable legal context.

10. International Transfers

Your information may be transferred to and processed in countries outside your own, where data protection laws may be different from those in your country. We will take steps to ensure that your information is treated securely and in accordance with this Policy.

Some third-party providers used for payments, analytics, hosting, communications, support, safeguarding operations or platform functionality may process personal data outside the UK or European Economic Area. Where required, TutorTech will use appropriate safeguards for international transfers.

11. Changes to this Policy

We may update this Policy from time to time. We will notify you of changes by posting the updated Policy on our website and Services.

Where changes materially affect Marketplace activity, children’s data, school/sports academy/SEND microsites, progress sharing, payment processing, profile visibility or other important privacy matters, we may provide additional notice where appropriate.

12. Contact Us

If you have any questions about this Policy or how TutorTech handles personal data, please contact us at:

Email: legal@tutortech.co.uk

For privacy or subject access requests, you may also contact:

Email: privacy@tutortech.co.uk

For safeguarding concerns, please contact:

Email: safeguarding@tutortech.co.uk

13. Alignment with Other TutorTech Policies

This Data Privacy Policy should be read together with TutorTech’s Terms of Service, Marketplace Terms, Payment and Cancellation Policy, Cookie Policy, Safeguarding Policy, User Code of Conduct, Copyright / IP Policy, Tutor Agreement and any other policies that apply to your use of the Services.

Together, these documents explain how TutorTech operates the platform, protects users, manages payments, handles Marketplace content, processes personal data, supports safeguarding and manages user rights and responsibilities.