Privacy Policy.

1. Introduction

This Privacy Policy is provided by Sophyra Tutors Ltd, a company registered in England and Wales under company number 16822139, with registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX ("we", "our", or "us"), for use of our products and services including our website (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use, and share any information relating to you or your child's personal data (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use, and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used. Given the nature of our Services, we may collect the personal data of children under 18 years old with explicit consent from you, the Parent or Guardian of that child.

2. What this policy applies to

This privacy policy relates to your use of the Services only. The Services may link to or rely on other websites, APIs, or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other websites, APIs, or services may also gather information about you in accordance with their own separate privacy policies.

3. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

• Identity and account data you input into the Services. Registration is mandatory in order to use the Services: name, email address, address, education level, and your account details such as username and password.
• Data collected when you use specific functions in the Services: data you store online with us using the Services including your usage history or preferences.
• Other data the Services collect automatically: your activities on, and use of, the Services which reveal your preferences, interests, or manner of use of the Services and the times of use.
• Data collected when you make an enquiry: your name and email address.

If you do not provide personal data we ask for where it is required, it may prevent us from providing services to you.

4. Special category personal data

Certain personal data we collect is treated as a "special category" to which additional protections apply under data protection law. This is also known as "Sensitive Data". Where we process Sensitive Data, we will ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent.

Sensitive personal data means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person's sex life; and data concerning a person's sexual orientation. We may collect sensitive personal data or information about criminal convictions from individuals as required from a DBS or equivalent police check.

5. How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly, reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change, you would be notified of this change, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

6. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

7. Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including tutors, developers, and cloud storage providers.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with external auditors, professional advisors (such as lawyers), law enforcement agencies, courts or tribunals, regulatory bodies, or other parties in connection with a significant corporate transaction or restructuring. In all cases, recipients will be bound by confidentiality obligations.

8. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a need-to-know basis have access to such data. Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

9. Transferring your personal data out of the UK

As part of providing the website and Services, we may share your personal data with third parties based outside of the UK. Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (an "adequacy regulation") further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law.

10. Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website.

• Access to a copy of your personal data. The right to be provided with a copy of your personal data.
• Correction (rectification). The right to require us to correct any mistakes in your personal data.
• Erasure (right to be forgotten). The right to require us to delete your personal data in certain situations.
• Restriction of use. The right to require us to restrict use of your personal data in certain circumstances.
• Data portability. The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format.
• To object to use. The right to object at any time to your personal data being used for direct marketing, including profiling.
• Not to be subject to decisions without human involvement. The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you. We do not make any such decisions based on data collected by the Services.

11. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

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.

12. How to complain

Please contact us if you have any queries or concerns about our use of your information. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner can be contacted here or by telephone: 0303 123 1113.

13. Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means such as email.

14. How to contact us

You can contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law, or to make a complaint.

Email: info@sophyratutors.com

Telephone: +44 7305 131971