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This privacy policy was last updated on 23rd December, 2022.

Scholearn have created this privacy statement (“Statement”) in order to demonstrate our firm commitment to the privacy of the details that users provide when using our Website, as the data controller for the purposes of the GDPR (General Data Protection Regulations EU 2016/679) and related UK legislation.

In this Statement, references to “you” and “your” are references to the User of i.e. www.scholearn.co.uk (the “Website”) regardless of whether you are a Student or a Tutor or other User. It applies to information we collect about Users of our Website and, amongst other things, this Statement describes what personally identifiable information, “Personal Information”, we collect from you, how and when it is used, how we protect it and who has access to it. This Statement incorporates our Terms and Conditions and Tutor Policy by this reference.

1. This Policy

This Policy explains our processing of your personal data and your rights according to EU General Data Protection Regulation and UK Data Protection Legislation. We reserve the right to modify this Statement at any time without notice by posting the changes on this page.

2. What information is collected?

a. Personal information you give us that is necessary for the use of the Scholearn Website

Scholearn processes personal data as a necessary part of entering into and performing our contract with you, which is governed by our Terms and Conditions. As part of this process of using the Website and the Services, we require you to give us certain Personal Information which we need to provide our Service. Without this information, we may not be able to fulfil our contract with you. This information includes:

·        Account information: to enable us to create an account for you on our Website. Depending on whether you register as a Parent, Student, School Pupil, or Tutor, this information can include your name, email, telephone number, postal address, and date of birth.

·        Tutor application details: so that we can process your application to become a Tutor. These details include your educational background and qualifications, your tutoring subjects, your profile picture, your CV, your availability and your gender.

·        Communication history: to enable communication with other Users of the Website and with the Scholearn team, we store details about your communication history including User messages, requests you have made, and your interactions with the Scholearn team.

·        Booking history: to facilitate tutorials including information on booking requests, status of bookings, booking subjects and levels, and recordings of your bookings (bookings include Tutor interviews, free meetings, lessons and written sessions).

·        Identify verification information: when you apply as a Tutor we ask for verification that you study at the University you claim to, have a valid ID card and a clean DBS check (if applicable). We also ask for information to demonstrate that you have Right to Work in the UK.

(b) Information we automatically collect from your use of the Scholearn Website

We collect some information from all users of the Scholearn Website regardless of whether you are registered with us as a customer or Tutor, to fulfil our contract with users and to enable our legitimate interests in providing the Scholearn Website and services.

·        Automatically tracked information includes: Cookie information, your IP address, details of the device you use to access the Website, the pages you visit and the actions taken, the times and dates of action you take on our Website, your interactions with our email, text and in-app messages, the source of your visit and your page response times.

·        Tutor capacity information: If you have a profile as a Tutor on the Website, we collect information on your on-site behaviour, capacity and interactions with other users to help show you the most relevant requests and show customers the most relevant Tutors.

(c) Financial information

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 customers your payment history and payment card details.

When you book Tutoring Services via the Website (if you are a Client) or when you receive payment for delivering Tutoring Services via the Website (if you are a Tutor), we will pass your Financial or Personal Information to those third parties necessary to process your transactions with us, such as credit card companies and banks.

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 need to comply with a legal obligation.

This includes 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.

2.1 How is this information used?

The Website asks you to provide various types of Personal Information to enhance the quality of the Services we can provide to you and the more accurate the information you provide, the better we are able to respond to your requirements.

Any Personal Information that is held with Scholearn shall be retained in accordance with the GDPR. Scholearn is the data controller in respect of all of the Personal Information which Scholearn collects and receives about you when you use the Scholearn Services.

a. Data processing to provide and improve the Scholearn Website and Services

We use your information primarily to fulfil our contract to provide you with the Services that you request, and relative Services, (this includes providing this Website, Website administration and security). We run the following processes to fulfil our contract with you:

·        Enabling you to access the Scholearn Website and create an account

·        Enabling Tutors to create and promote their profile on the Scholearn Website

·        Facilitating matching between customers and Tutors, including personalising your experience to show you the most relevant matches

·        Enabling you to communicate with other Users, and receive updates from Scholearn about your account

·        Enabling bookings between customers and Tutors

·        Providing recordings

·        Enabling and processing payments

·        Providing support for customers and Tutors

·        Providing photos and videos to create trust and enable better connections between Users

We also use your information to support our legitimate interests in developing the Site and the Services. These processes include:

·        To aid the technical administration of the Website

·        To ensure quality of service

·        To better understand how the Website is performing for Users to inform our product development

·        To draw conclusions upon demographic information

·        Preventing fraud, spam and abusive or inappropriate behaviour

·        Fulfilling our safeguarding and legal obligations

You acknowledge that your Personal Information may be used by Scholearn to contact you by post, phone or by electronic mail when necessary in connection with the Services requested by you on the Website.

b. Data processing to provide, tailor and improve our marketing activities

We also use your information to support our legitimate interests in marketing our Website and the Services. These processes include:

·        Marketing activities to promote our services to registered Users. These communications may be personalised to you and your interactions with the Website and can be delivered by email, social media advertising and other digital marketing channels

·        Notifying you about upcoming promotions, Services or customer surveys

·        Undertaking impact reporting to understand the efficacy of our Services

·        Undertaking research to better understand our customer’s interests

·        Analysing your interactions to improve the efficiency of our marketing activities

c. Direct marketing

From time to time, Scholearn may contact you by post, by telephone or by electronic mail, with information or offers relating directly to the Website and the Services it provides.

When you register on the Website, you accept that your contact information may be used by Scholearn for direct marketing purposes relating directly to the Website and the Services.

Opting out: If you do not wish to be contacted by Scholearn in respect of future marketing communications, in the case of our own promotional communications please contact Scholearn by sending an email to lottieingham1@gmail.com with “UNSUBSCRIBE REQUEST” or a similar statement in the subject line.

d. The legal grounds under GDPR for processing your personal data described above are as follows:

·        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, for us to provide you with our products and services. Where we require information from you for these purposes we have set out above which information it is necessary for us to process, without which we will be unable to provide you with our services.

·        It is necessary for the purposes of our legitimate interests, such as fraud prevention, child protection, maintaining quality of service, error detection and cyber security, except where our interests are overridden by the interests, rights or freedoms of effected individuals (such as you). To determine this, we shall consider a number of factors, such as what you were told at the time you provided data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

·        You have given us explicit opt-in consent to the processing of your personal data for one or more specific purposes, namely where you have given us consent to receive electronic Direct Marketing by us and/or by third parties as described in this notice.

·        Where we need to comply with a legal obligation: or in rare circumstances:

·        Where we need to protect your interests (or someone else’s interests); and/or

·        Where it is needed in the public interest or for official purposes.

3. Who else has access to this information?

a. Other users on the Scholearn Website

Your Personal Information may also be viewed by Tutors (where you are a Client) or by a Client or Tutor (where you are a Tutor) for the sole purposes of enabling Tutors to deliver their Tutoring Services direct to you and to provide you with information about their Tutoring Services and access to the Tutoring Services themselves.

If you as a Client make a request for Tutoring Services with a Tutor via the Website, your Personal Information will be shared with the Tutor to enable the Tutor to deliver the Tutoring Services or to follow up on any enquiry. Such details may include: first name and initial of surname, the contents of your message, and the subject level you requested.

If you as a Tutor submit Personal Information on the Website, for example by creating a profile, Personal Information in your profile may be accessible by a User who visits the Website. The personal information shared may include: first name and initial of surname, University details, the CV you write for Scholearn, your profile picture, your qualifications, tutoring subjects, price band and record. Releasing this personal data is necessary for you to make use of the Website and Services.

If you as a User send a message to another User on the Website, you acknowledge that Scholearn may monitor the content of your message to fulfil our safeguarding obligations and to protect our legitimate interests.

b. Third party companies and service providers

From time to time, Scholearn will use a variety of third-party companies to provide its Services and we may need to pass some Personal Information to these third parties. If we pass some Personal Information to third parties, we minimise as far as possible what Personal Information is shared. The categories of third-party providers we may share personal data with include:

·        Analytics providers

·        Payment providers

·        Communications platforms for email, text and in-app communications

·        Marketing platforms

·        Business operations tools

·        Identity verification tools

·        Surveys and research providers

·        Accounting and finance platforms

c. Disclosure of your personal information and financial information in compliance with laws

You should be aware that we may release your Personal Information or Financial Information when we believe it is necessary to comply with laws of regulations, to assist law enforcement, to enforce the terms under which you transacted with Scholearn, or to protect the rights, property or safety of Scholearn, Website Users or others.

4. How do we protect your information?

The privacy and protection of your Personal Information is important to us. 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 Scholearn 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 Scholearn by telephone or post to arrange an alternative method of communication. You transmit all such information at your own risk. However, once we receive your transmission, we use of our best efforts to ensure its security on our systems.

The Website has security measures in place to protect the loss, misuse and alteration of the information under our control.

5. Complaints or queries

Scholearn tries to meet the highest standards when collecting and using Personal Information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This Statement does not provide exhaustive detail of all aspects of Scholearn’s collection and use of Personal Information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below (see Section 13). If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK Data Protection Regulator, the Information Commissioner’s Office. Further details can be found at ico.org.uk or 0303 123 1113.

6. How long do we keep your information for?

We will retain your personal data for different periods depending on the service you have chosen to use us for, which may be a longer period than that for which we need to hold your data to provide those services, i.e., where we are under regulatory or statutory duties to hold your data for a longer period. Data will be held by us for the period necessary to meet the purposes for which we initially collected the information.

·        By default, we retain personal data for six years after you have last been active on the Website. This is to allow you to continue to use your Scholearn account for the duration of the average lifecycle of a Scholearn User.

·        After that 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 a specific reason which means we need to keep it for longer.

·        Records that you have shared publicly or have shared with another User, for example reviews you leave, messages you send and bookings you make, may remain on the Site after your Personal Information has been deleted but will no longer have identifying information which links them to you.

·        We may retain records where necessary to fulfil our regulatory or statutory duties.

7. Access to and rectification of personal information

Scholearn tries to be as open as it can be in terms of giving people access to their Personal Information. Individuals can find out if we hold any Personal Information by making a “subject access request”, normally free of charge, under the GDPR. If we do hold information about you we will let you have a copy of that information unless a legal exception applies, in which case we will inform you of this at the time. You also have the right to request that information we hold about you which may be incorrect, incomplete, or which has been changed since you first told us, is updated or removed.

To make a request to exercise either of these rights, please either put the request in writing addressing it to the address provided below (see Section 13) or email us your request to lottieingham1@gmail.com with the subject line “SUBJECT ACCESS REQUEST”.

8. Moving your personal information

In the event that we process your data by automated means, where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, an electronic copy of the personal data we hold about you in a structured, commonly used and machine-readable format, for example when you are dealing with a different service provider. If you would like us to provide, move, copy or transfer your information in this manner, please let us know by email to lottieingham1@gmail.com. We will endeavour to respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

9. Deletion of your personal information

You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remote your personal data where you have successfully exercised your right to object to processing (see Section 11), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

To request that we delete your personal data, please send an email with the subject line “PERSONAL DATA DELETION” to lottieingham1@gmail.com.

10. How can you withdraw consent to our processing of your personal information

You have the right at any time to withdraw any explicit consent you have given us to process your personal data. Please note, if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried about before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time. To withdraw your consent or change your preference please contact us at lottieingham1@gmail.com.

11. How can you restrict or object to our processing of your personal information

You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing of your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights or freedoms, or where we are processing your personal data for direct marketing purposes. In some cases, where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Please note that if you want us to restrict or stop processing your data, this may impact on our ability to provide our services. Depending on the extent of your request, we may be unable to continue providing you with our Service.

Any queries or concerns about the way in which your data is being used can be sent to lottieingham1@gmail.com.

12. Automated decision making and profiling

To provide you with our services, it is necessary for us to conduct profiling and automated decision making on your data consisting of:

·        Screening applications from prospective Tutors to check that your qualifications match our criteria and you have the Right to Work in the UK

·        Screening User messages sent on the Website to ensure contact details are kept private

·        Compiling metrics for Tutors on behaviours, activity on the Website, and availability to determine which requests you receive

·        Monitoring log in activity to determine whether Tutors’ profiles remain active on the Website

Should you wish to discuss or contest this decision or request that a person is involved in this automated decision, which you have a legal right to do, please email lottieingham1@gmail.com.

13. How to contact us to request information

Requests for information about our Statement can be emailed to lottieingham1@gmail.com or requested in writing to:

Charlotte Ingham

Vicarage,

Vicarage Hill,

Badby,

Daventry

NN11 3AP

Version Name: Scholearn-PrivacyPolicy-V1

To be reviewed on: 23/12/2023