My Primary Tutor is committed to safeguarding your privacy. We collect, use and are responsible for certain Personal Data about you. For the purposes of the Data Protection Legislation, the controller of your Personal Data is Mrs K Simpson, My Primary Tutor. Contact her at firstname.lastname@example.org if you have any questions or problems regarding the use of your Personal Data and she will gladly assist you.
We ask that you read this privacy notice 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 supervisory authorities in the event you have a complaint.
Controller – the is the organisation that determines the purposes and means for Processing Personal Data;
Data Protection Legislation – this means the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (the "GDPR") as amended and updated from time to time;
Personal Data – any information relating to an identified or identifiable natural person;
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data;
Data Subject – a natural person whose Personal Data is being Processed; and
Child – a person under 18 years of age.
Data protection principles
We adhere to the following data protection principles which require that Personal Data is:
Processed lawfully, fairly and transparently. This means that our Processing activities have lawful grounds. We always consider your rights under the Data Protection Legislation before Processing your Personal Data;
collected for specified, explicit and legitimate purposes and is not further Processed in a manner that is incompatible with these purposes. Our Processing activities fit the purpose for which Personal Data was gathered;
adequate, relevant and limited to what is necessary in relation to the purposes for which it was collected for. We only gather and Process the minimal amount of Personal Data required for the purpose it was collected for;
kept in a form which permits identification of Data Subjects for no longer than necessary. Processing is limited with a time period. We will not store your Personal Data for longer than needed; and
Processed in a manner that ensures appropriate security and confidentiality of the Personal Data.
The GDPR also includes a principle of 'accountability', which requires My Primary Tutor to take responsibility for its Processing and to be able to demonstrate compliance with the GDPR.
Data Subject’s rights
You can exercise any of the following rights by contacting us on email@example.com.
Under the Data Protection Legislation, you have the following rights:
Right to information – meaning you have to right to know whether your Personal Data is being Processed by us, what Personal Data is gathered, from where it is obtained and why and by whom it is Processed – as contained within My Primary Tutor's privacy notice;
2Right to access – meaning you have the right to access the Personal Data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered;
Right to rectification – meaning you have the right to request rectification of your Personal Data that is inaccurate or incomplete;
Right to erasure – meaning, in certain circumstances, you can request for your Personal Data to be erased from our records;
Right to restrict Processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data;
Right to object to Processing – meaning in certain cases, you have the right to object to Processing of your Personal Data;
Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you;
Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another;
Right to withdraw consent – you have the right to withdraw any given consent for Processing of your Personal Data;
Right to lodge a complaint – in the event that we refuse your request under the applicable Data Protection Legislation, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us;
Data we gather
Information you have provided us with
This includes your e-mail address, name, billing address, home address, medical information or emergency contact information. We also collect personal data from the Children we provide our services to. This includes their name, age, class,school, test score and their progress in activities.
Information from our partners
We gather information from our trusted partners with confirmation that they have a legal basis to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners –Airtable, Class Dojo, G-Suite, One Drive and Outlook.
Publicly available information
We might gather Personal Data about you that is publicly available.
Why we need your Personal Data
We need to collect your Personal Data so that we can in order to:
provide our service to you. This includes, for example, registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services;
enhance your customer experience;
fulfil an obligation under law or contract;
to track the progress of Children enrolled our programmes;
to communicate with you either about the services we provide to you, for sales or for invoicing purposes;
to send you personalised offers (from us and/or our carefully selected partners);
to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
to conduct questionnaires concerning client satisfaction; and to send you newsletters and campaign offers (from us and/or our carefully selected partners).
When we use your Personal Data we are required to have a lawful basis for doing so. There are various different lawful bases upon which we may rely, depending on what Personal Data we Process and why. We may Process your Personal Data where it is necessary for our legitimate interests or your legitimate interests. We may also Process your Personal Data with your consent, on the grounds of entering into a contract with us, fulfilling contractual obligations or fulfilling our legal obligations.
Where we Process your Personal Data for marketing purposes, you have the right to object to us using your Personal Data. If you wish to object to any of the above Processing, please contact us at firstname.lastname@example.org.
We might Process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
the link between purposes, context and nature of Personal Data is suitable for further Processing;
the further Processing would not harm your interests; and
there would be appropriate safeguarding for Processing.
We will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
￼Throughout our website (www.myprimarytutoronline.com) we may link to other websites. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
Who else can access your Personal Data
Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.
We share your Personal Data with:
We only work with Processing partners who are able to ensure adequate levels of protection to your Personal Data and when it is required for specific purposes. [ Personal Data when this occurs, please see "Transfer of your information out of the EEA" below.]]
We may also disclose your Personal Data to third parties or public officials when we are legally obliged to do so. This may include sharing Children's Personal Data with the consultants we engage with for the purposes of providing our services. We might disclose your Personal Data to third parties if you have consented to the disclosure.
Transfer of your information out of the EEA
We may transfer your Personal Data to the following which are located outside the European Economic Area (EEA) in order to provide you with our services.
Any transfer of your Personal Data outside the EEA for the above purposes to a country which has not been deemed by the European Commission to provide an adequate level of data protection similar to the laws which apply in the UK and EEA will be subject to one of the following safeguards:
ensuring there is a contract in place that provides adequate safeguards; or
using providers that are certified on the US Privacy Shield framework.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring your Personal Data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we cannot guarantee the security of information. We will notify you if there is a high risk to your rights and freedoms as a result of the data breach. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
How long we keep your Personal Data
We will retain your Personal Data for as long as necessary for the purposes we have set out above. At your request or if you do not engage with us for a period of 3 years, we will review and may delete any information that we no longer have a legitimate reason to retain.
Your Personal Data may be retained longer by the third parties listed above in accordance with their privacy policies.
My Primary Tutor,
Last reviewed: March 2022.