Privacy Policy

Introduction

The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements. Please read this Policy carefully. It provides important information about how we use personal data and explains your legal rights.

This Policy applies only to the Website and does not extend to the websites of any other companies or organizations to which we may link which are managed by third parties. If you are a user of these links, it is your responsibility to understand how those third parties will use your data as once you leave our Website, we have no control over information that is submitted to or collected by any third-party links.

By visiting our Website, and contacting us on telephone, WhatsApp or email, you agree and, where required, you consent to the collection, use and transfer of your personal data as set out in this Policy. Our Website uses cookies to distinguish you from other users.

For the purpose of data protection regulations, Tutor Tod W.L.L, a company incorporated under the laws of Kingdom of Bahrain, will be the data controller for your personal data when you use the Website.

For any privacy related queries in relation to our business or this Policy, please contact us at: [Email address].

What Information Do We Collect From You and How?

We may collect and process the following data about you:

• Account information: name, contact details, date of birth, username and password, educational records, email address, subject and interests, gender, identity records, country of residence and payment information.
• Communications: messages you send via our 'contact us' feature, social media interactions, and emails. We may also monitor and record calls to customer services.
• Device and technical data: location data, device characteristics, performance data, carrier/operating system, device type, connection type, IP address, and unique device identifiers.
• Usage data: details of your visits to our Website including traffic data, location data, weblogs, other communication data, and the resources you access.
• Computer/browser data: IP address, operating system and browser type for system administration purposes.
• Survey and feedback responses: your responses to surveys, ratings, competitions or promotions.
• Session recordings: live recordings of classes, recordings of interactions between you and other users, and payment details when you purchase services.
• Academic information: academic level, year group, learning objectives and goals, subject interests.

Special Categories of Personal Data

We do not generally collect special categories of personal data (also known as sensitive personal data) about you. This includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, health data, or genetic and biometric data.

However, we may collect health or disability information if:

• You voluntarily provide it to help us provide appropriate support or reasonable adjustments for educational services you purchase; or
• It is necessary to comply with legal obligations (e.g., safeguarding requirements).

If we need to collect special categories of personal data, we will obtain your explicit consent or rely on another lawful basis permitted by data protection law.

Minors

Our Website provides educational services to students of all ages, including children under 18 years of age. We recognise that children require additional protections when their personal data is processed, and we are committed to protecting children's privacy in accordance with data protection laws.

TutorTod does not knowingly collect or process personal data from children under the age of 12 without the explicit consent of their legal guardians. The Website is not directed at children under the age of 12. In the event that we learn that we have accidentally collected personal data of a child under the age of 12, we will promptly take steps to delete that information.

If you are a parent or legal guardian registering a child under 18 years of age, we require your consent before we collect and process the child's personal data. You are responsible for ensuring that the child understands this Privacy Policy, and you consent to the processing of the child's personal data as described in this Policy.

How Do We Use Your Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform our contract with you (e.g., to provide tutoring services you have purchased);
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal obligation; and
• Where you have given us your consent to use your personal data for a specific purpose.

To Register You and Deliver Services

• Collecting identity and contact information to register you as a user and provide access to the Website.
• Carrying out our obligations under any terms and conditions entered into between you and us.
• Processing payments via third-party payment gateways and producing accurate invoices.
• Recording tutoring sessions to deliver services via meetings and virtual classrooms.
• Managing tutoring profiles, payment, fees, charges, and responding to your requests.
• Notifying you about changes to our terms and privacy policy and asking for reviews or surveys.

Ensuring Quality of Our Services

• Recording and reviewing customer service calls to maintain service standards and for training purposes.
• Reviewing lesson and transcript recordings for quality assurance and tutor performance improvement.
• Using data analytics to improve our Website, lessons, services, marketing, and customer experience.
• Collecting location and device data to ensure optimal service delivery.
• Requesting your participation in surveys, feedback, and tutor ratings.
• Matching students and tutors to deliver personalized tutoring services.

General Marketing and Direct Marketing

• Providing information via telephone, SMS, WhatsApp, and email about services you request or that may interest you, where you have consented.
• Sending push notifications relating to services and offers where you have opted in at the device level.
• Displaying testimonials and tutor ratings on our Website.
• Sending direct marketing communications about offers, promotions, or related services via email, SMS, WhatsApp or targeted online advertisements.

Internal Business Purposes

• Internal reviews, website and system administration, internal audits, and troubleshooting.
• Using recorded transcripts for tutor management, training, and administration.
• Carrying out data analytics to predict future customer trends.
• Complying with legal and regulatory obligations, preventing fraud, and meeting Bahraini law requirements.
• Retaining personal data, payment records, and account access data to meet security and regulatory obligations.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Marketing Communications

We may send you marketing communications about our services, offers and news if:

• You have requested information from us or purchased services from us; and
• You have consented to receive marketing communications (including for existing users, or where you have not opted out).

You can ask us to stop sending you marketing communications at any time by:

• Clicking the unsubscribe link in the footer of any marketing email from us;
• Updating your communication preferences in your account settings; or
• Contacting us at [email].

Please note that even if you opt out of marketing communications, we will still send you service-related communications such as booking confirmations, class reminders, payment confirmations and important updates about our services or policies.

Who Do We Disclose Your Information To?

We may share your personal data with third parties in the following circumstances:

• To provide our services and fulfil our contract with you.
• Where required by law or to comply with legal obligations.
• To protect our rights, property or safety or that of our users or the public.
• With your consent.

Our Service Providers

We disclose information to service providers who provide services on our behalf. Your data will only be used by our third-party providers to provide the requested services to us, and each service provider is subject to a set of terms consistent with this Policy. We use the following types of third-party providers:

• Providers of website management and hosting services.
• Providers of database, sales administration and market interaction software.
• Payment solution and payment processor providers.
• Fraud prevention agencies to assist with identity checks, fraud prevention and money laundering management.
• Survey and market research providers.
• Providers of email communication tools and webinar platforms.
• Cloud hosting and storage providers.
• Providers of outsourced printing services.
• Third-party auditors, lawyers, and accountants, where necessary to meet legal and regulatory obligations.

Other Third Parties

• Any member of our group, including our subsidiaries and ultimate holding company.
• In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer.
• If you request or authorize the disclosure of information to a third party.
• If TutorTod or substantially all of its assets are acquired by a third party, personal data may be one of the transferred assets.
• If we are under a duty to disclose your personal data to comply with any legal or regulatory obligation.

Where Do We Store Your Data?

As we are located in Bahrain, the information that we collect from you will be transferred to and stored/processed within Bahrain. A minority of our service providers are based outside the Kingdom of Bahrain. Where data is transferred outside Bahrain, we will always take steps to ensure that any international transfer of personal data is carefully managed to protect your rights and interests.

International Data Transfers

In cases where your data is transferred outside the Kingdom of Bahrain, we will ensure it is protected by:

• Only transferring your personal data to countries recognised as providing an adequate level of legal protection and approved by the Competent Authority;
• Ensuring that transfers outside the Kingdom of Bahrain are subject to appropriate legal safeguards such as standard contractual clauses and binding common rules.

Data Retention and Deletion

Unless longer retention periods are required by applicable laws in the Kingdom of Bahrain, we will retain your personal data for as long as the account is active, as well as for an additional period afterwards to cover any outstanding issues or queries. We will periodically review retention periods to check they are appropriate. We will not keep your personal data for any longer than is necessary.

If you are not an active user of the Website and you do not wish to hear from us, you can contact us at [email] and we will delete your information in accordance with applicable data protection law.

Your Rights

You have the right to object to the processing of your personal data and to withdraw your consent at any time. As a data subject, you have the following rights:

• The right to be informed of the use of your personal data.
• The right to access your personal data.
• The right to request correction of your personal data, including any data that requires updating.
• The right to request destruction or deletion of your personal data.
• The right to request provision of your personal data in a clear and readable format.
• The right to withdraw consent at any time.
• The right to be notified and object to the processing of your personal data for marketing purposes.
• The right to not be subjected to automated decision-making.

If you are a parent or legal guardian exercising rights on behalf of a child under 18, we may request proof of parental responsibility before acting on the request.

If you have a complaint in relation to the processing of your data under this Policy, you have the right to lodge a complaint with the Competent Authority.

You may seek to exercise any of these rights by updating your information online (where possible) or by sending a written request to [email].

Updates to This Policy

We may update this Policy from time to time to reflect changes in laws, data processing practices or services we offer. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date.

We will ensure you are aware of any significant changes by sending an email message to the email address you most recently provided to us or by posting a notice on the Website. We encourage you to regularly check and review this Policy.

How to Contact Us

If you have any questions about this Policy or our data privacy practices, or if you wish to exercise your rights, please contact us:

• Email: [insert email]
• Postal Address: Tutor Tod W.L.L, [Street Address], [City, Postal Code], Kingdom of Bahrain
• Telephone: [Insert telephone number]

How to Complain

If you are not satisfied with how we handle and process your personal data, please contact us first using the details in the Contact Us section.

We will investigate your complaint and respond to you within 28 business days.

You have the right to file a complaint with the Competent Authority if you believe we have processed your personal data unlawfully or in breach of your rights. In Bahrain:

• Competent Authority: Kingdom of Bahrain
• Website: [Insert website URL]
• Email: [Insert email]
• Telephone: [Insert telephone number]

You will not suffer any adverse consequences for making a complaint to us or a Competent Authority.