PRIVACY AND COOKIES POLICY
Version number: 1.0
Effective date: 01/08/2019
Who are we?
We are AP Education Services Ltd trading as “Tutorspot”. For privacy queries, you can contact us at
email@example.com. Other contact details are on our website.
What’s the point of this policy?
It tells you what to expect when we collect your personal
information via our website. Please only use our service if you are
completely happy with this policy.
Generally, the policy covers only information provided to us. If
you give personal information to other people, such as payment
providers or other websites, please check their privacy policies.
payment provider Stripe. (Note that this payment provider may
Might the policy change?
Yes. Please check it whenever you visit our
website. We will assume you agree to the new version of the policy
if you use the site after its effective date. We may also notify
you of any changes by email or in-service message.
What do we collect?
Information which you upload to our service or otherwise give us
your name and contact details;
other information provided when you register with us such as (in the
case of tutors) profile photo, education and qualification details,
identity documents and criminal records check certificates;
details about your transactions on our service;
information included in your profile or which you otherwise provide for
display on our service or which you include in messages sent via our
contact or other information which you give or allow us to use for
newsletters or other marketing; and
your communications with us.
Automated information about your use of our service such as: the
internet protocol (IP) address used to connect your device to the
internet, connection information such as browser type and version,
information about your device including device-type and device
identifier, operating system and platform, mobile network data, a
unique reference number linked to the data you enter on our system,
login details, the site from which you arrived at our service,
details of your activity with date / time stamps including pages
you visited and your searches / transactions.
The following information about you may be provided to us by other
Limited billing information sent to us by our payment provider for
verification purposes e.g., your name, email address and billing
What’s our reason / legal basis for collecting the information?
Because it’s necessary to take steps at your request to enter into
a contract with you and/or to perform such a contract, e.g., send
service messages, process payments and fulfil orders. This applies
to initial enquiries and to contact and transaction details as well
as to profiles and other information which you provide for public
display on our service.
Because it’s in our “legitimate interests”, e.g., to manage and
improve our service including tracking usage patterns and
preventing or detecting fraud or abuse. This applies to automated
Because you’ve specifically agreed on our service (e.g, by ticking
a consent box). This applies to contact or other information which
you give or allow us to use for newsletters or other marketing. You
can withdraw permission at any time as explained on our service or
by emailing us at the above email address.
If you supply us with someone else’s email address for a “Refer A
Friend” or similar offer, to send a referral message to that person
and we will then immediately delete it.
How long do we keep personal information?
Until you delete your account, which you can do by emailing us at
the above email address.
We may hold on to some of your information for longer (typically up
to six years) if reasonably needed for legal, regulatory or tax
reasons, deal with disputes, prevent fraud or abuse and/or enforce
our terms and conditions.
We will keep your information which we use only for newsletters or
other marketing until you tell us to stop sending you such
To whom do we send or make available your personal information?
To other people who supply us with a service, e.g., website hosts,
payment providers, customer service providers and businesses which
help us send communications or monitor our website and which
provide us with e-commerce, online advertising, analytics, live
chat and other IT services.
To the other party to any tuition contract which you enter via our
To other users of our service, if you enter personal information
into your public profile or include it in a review or other public
action on our service. You can ask us to remove
displayed information by emailing us at the above email address.
To credit reference agencies, regulators and the police and other
law enforcement authorities to help deal with fraud and abuse
and/or comply with legal requirements.
To insurers and professional advisers in connection with our
insurance cover or to deal with legal claims.
To potential buyers so far as reasonably necessary, in the case of
an actual or proposed (including negotiations for a) sale or merger
or business combination involving all or the relevant part of our
Do we send your information outside the European Union?
Your personal information which we collect is stored within the EU
and is not transferred to any third countries except as follows.
Your personal information may be transferred to the US by the
following companies certified under the
EU-US Privacy Shield Framework
, which provides certain safeguards for your personal information:
Google (analytics / advertising), Facebook (advertising), SendGrid
(email delivery), Intercom (chatbot, email delivery, customer
What rights do you have?
If the legal requirements are met: To ask us for access to your
personal information, to rectify it if there are mistakes, to
delete or restrict its use in certain circumstances or to “data
portability” or to withdraw any consent you’ve given (e.g.
You may also have the right to object to use of your personal
information in certain circumstances.
If you have a complaint about how we are dealing with your personal
information, please contact us via the email address above. If you
are not happy with our response or think we are not handling your
personal information in accordance with the law, you have the right
to complain to the Information Commissioner’s Office (ICO).
For more information about your rights, visit the ICO’s website: www.ico.org.uk.
What about cookies?
technologies on our website. A cookie is an identifier (a small
file of letters and numbers) that is sent to your web browser.
Cookies are widely used to make websites work, or work more
efficiently, as well as to provide information to the website owner
or others. Some are session temporary “session” cookies that remain
in the cookie file of your browser only until your browser is
closed. Whereas persistent cookies stay for longer (depending on
the lifetime of the specific cookie). For further information on
cookies, including how to use your browser to block them and how to
delete existing cookies, visit:
. Our site’s functionality will be limited if you configure your
browser to reject cookies.
We ourselves place the following types of cookies:
Type of cookies
Assess whether you are logged in to our site
Identify and authenticate you to help you move easily
through the site
Store your response to our cookie notice
Companies which provide us with a service also place cookies. Some
of these cookies (e.g. from Google) may involve certain
information, such as your IP address and web address of the page
you’re visiting, being sent to the company concerned. Below is a
summary of the kinds of cookies used together with details about
who places them and where you can go to get more information and to
opt out (where possible):
These kinds of cookies recognise and count the number of website
visitors as well as providing other information about the visit such as
duration, route through the website and where the visitor came from.
This information helps us to improve the way our website works, for
example by making sure users find what they need easily. These cookies
are provided by:
Google Analytics (“GA”).
These kinds of cookies are typically used to personalise ads on this or
other sites based on your use of our site, to measure ad effectiveness
(for example, how often you click on or view ads and whether you go on
to buy something from the advertiser) and to stop you being shown the
same ad repeatedly. These cookies are provided by:
Google (including Analytics Ad Features / AdSense / Doubleclick)
Facebook (including “Facebook Pixel”)
Facebook’s cookies policy
(see especially under “Advertising, recommendations, insights and
Note that there are various places where you can go to opt out of many
companies’ advertising cookies in one go including some or all of the
Payment provider cookies:
Our payment provider may place cookies if you use their payment
services on our site: