Privacy policy (Singapore)

Last updated 30 October 2026

1. About our policy

1.1 Introduction

Hello, we're Tutero (we, us, our, Tutero, all of which refer to Tutero Pty Ltd, ACN 647 042 251, a company incorporated in Australia). This Privacy Policy (Policy) explains how we collect, use, disclose, store and protect your personal data when you are in Singapore, or when you use our products and services offered for Singapore, which include but are not limited to:

(a) the Tutero website at https://www.tutero.com/sg through which you can access the Tutoring Platform;

(b) our personalised online tutoring platform (Tutoring Platform);

(c) our AI teaching software for teachers and schools (Teacher Software); and

(d) any other new service released by us from time to time,

(together, the Services).

Tutero respects the privacy of all individuals and is committed to complying with the Personal Data Protection Act 2012 of Singapore (PDPA), including its Do Not Call provisions, the Spam Control Act 2007 of Singapore, and other privacy laws that apply to us. Because Tutero is incorporated in Australia, we also handle personal data in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This Policy forms part of, and should be read together with, our Terms of Service at https://www.tutero.com/sg/info/terms-of-service.

1.2 Your agreement to this Policy

We will tell you the purposes for which we collect, use and disclose your personal data before or at the time we collect it, and we will ask for your consent where the PDPA requires it. When you create an account, submit an enquiry or otherwise provide your personal data to us after reading this Policy, you consent to us collecting, using and disclosing your personal data for the purposes set out in this Policy.

Children. If you are under 18 years of age, a parent or legal guardian must give consent on your behalf, and must create and manage the account. We apply this rule to every student under 18, even where Singapore law might allow an older child to consent for themselves. A parent or guardian who provides personal data about their child confirms that they are the child's parent or legal guardian and that they consent on the child's behalf.

Personal data about other people. If you give us personal data about another person (for example, your child or another parent), you confirm that you have their consent, or are otherwise entitled, to give it to us for the purposes in this Policy.

You do not have to give us your personal data. However, if you choose not to, we may not be able to provide the Services to you, or to provide them to the same standard.

1.3 Changes to this Policy

We may review and update this Policy from time to time, including to reflect new or amended laws, new technology or changes to our operations. The latest version on our website applies to all personal data we hold, subject to applicable law.

If we make a change that materially affects how we use your personal data, or that reduces your rights, we will give you prominent notice on the Services and/or by email before the change takes effect. Where the change involves a new purpose that requires fresh consent under the PDPA, we will ask for that consent.

If you disagree with the revised Policy, you may withdraw your consent (see section 7.2), stop using the Services and close your account.

If we make material changes to the types of personal data we collect from students, or how we use it, we will notify parents so they can give or withhold consent.

1.4 Personal data

In this Policy, "personal data" has the meaning given in the PDPA. It means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information we have or are likely to have access to. It includes, for example, your name, date of birth, contact details (including phone numbers and email addresses), photographs, video recordings, identification numbers and payment information.

2. What personal data does Tutero collect?

2.1 Types of personal data from different users

We may collect personal data about you from the following people or places. This list is not exhaustive.

Students

From your parent or guardian (or from you, with your parent's or guardian's consent): name, date of birth or age, school level and school, curriculum (for example PSLE, O-Level, A-Level, IP, IB or IGCSE), subjects, learning goals, relevant learning needs that your parent chooses to tell us about, interests and language preference.

From your teacher (only where the necessary consent has been obtained, for the Teacher Software): name, class, historical assessment information, email address, education background and language preference.

From your use of the Services:

1. For the Tutoring Platform: your curriculum understanding, how often you use the platform, lesson schedules, notes and comments, details of your lessons, homework tasks, video and audio recordings of your online lessons, lesson transcripts, and the lesson reports we generate from them (see section 4.6). 2. For the Teacher Software: your curriculum understanding, how often you use the platform, notes and comments, details of your learning activities and homework tasks.

Tutors

From you: your name, contact details, residential address in Singapore, photograph, education background and results, qualifications and teaching credentials, subjects and levels you teach, your availability, application answers and videos, and the declarations you sign (including your declaration about criminal records and your suitability to work with children).

To verify your identity and confirm that you are a Singapore citizen or permanent resident: your NRIC number and NRIC card details, which we check once at onboarding (see section 2.4).

For payments and tax: your bank account details, and your business registration details (UEN) if you have one.

From your use of the Tutoring Platform: how often you use the platform, lesson schedules, notes and comments, details of your lessons, homework tasks, video and audio recordings of your online lessons, lesson transcripts and lesson reports, and feedback and ratings about your lessons.

Teachers

From you: your name, job title, school name and address, email address and contact number.

From your use of the Teacher Software: teaching materials, curriculum, usage information and changes to lesson plans.

Parents and guardians

Your name, email address, mobile number (including any WhatsApp number), address, which student is your child, your child's details as listed above, your preferences and feedback, records of your calls and messages with us, and payment information.

2.2 Information we automatically collect from you

When you use any of our Services, we automatically collect certain information, including personal data.

(a) Usage information. Information about your activities on the Services, such as the pages or content you view, your searches and other actions you take.

(b) Communication records. If you contact us by phone, email, WhatsApp, SMS, online chat or in person, we keep a record of the communication and any personal data you provide. Phone calls with our team may be recorded for quality, training and record-keeping, and we will tell you at the start of a recorded call.

When you communicate with other users through the Services (for example, messages between a parent and a tutor), we monitor, record and store those communications and any information you choose to share, to keep students safe, to resolve disputes and to operate the Services.

(c) Log data and device information. We automatically collect log data and device information when you use the Services. This includes recordings of how you use our website (such as clicks, scrolls and page activity), your IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you viewed before and after using the Services. We use this information to provide and secure the Services and to analyse trends.

(d) Cookies and similar technologies. We use cookies, tags, pixels, web beacons and log files to understand how people use our website, to measure our advertising and to improve the Services. A cookie is a small text file that lets our systems recognise your browser or device. The main third-party technologies on our website are:

Technology · Provider · What it does

Google Tag Manager · Google · Loads and manages the tags below

Google Analytics · Google · Measures website traffic and how pages are used

Google Ads conversion tracking · Google · Measures whether our Google ads lead to enquiries

Meta Pixel · Meta Platforms · Measures whether our Facebook and Instagram ads lead to enquiries, and helps show our ads to relevant audiences

Microsoft Clarity · Microsoft · Records how visitors interact with our pages (clicks, scrolls, page movement) so we can improve them

Mixpanel · Mixpanel · Measures how our apps and Services are used

These providers may collect information such as your IP address, device and browser details and the pages you visit, and may combine it with information they already hold about you under their own privacy policies. You can restrict or delete cookies in your browser settings, and you can manage ad personalisation in your Google and Meta account settings. If you block cookies, some parts of the Services may not work fully.

We may also log IP addresses to analyse trends, administer the website and gather broad demographic information.

(e) Payment transaction information. We collect information about your payments, including the payment method used, payment dates and times, amounts, billing address and related transaction details. We need this to perform our agreement with you.

2.3 Information we collect from third parties

We may collect personal data about you from third parties, as described below. Where we do, we rely on the third party to have obtained any consent required for disclosing it to us, or on another basis permitted by the PDPA. Questions about a third party's own handling of your data should go to that third party.

(a) Third-party services. If you link, connect or log in to the Services through a third-party service (for example Google, Apple or Facebook), that service may send us information such as your profile details. What is shared depends on that service and your privacy settings with it. These services may also use this to evaluate your use of the Services and other websites, deliver customised advertising and measure the effectiveness of advertising.

(b) Advertising services. If you click on a Tutero advertisement (for example on Google, Facebook or Instagram), or submit an enquiry form inside one of those platforms, the platform will share information with us, such as the details you entered and information that helps us measure our advertising.

(c) Identity checks. If you are a tutor, we may use a third-party identity verification provider to check your identity document and confirm your details.

Tutero makes no representations about the privacy practices of third-party services and is not responsible for their privacy policies or content.

2.4 How we handle NRIC numbers

We only collect a tutor's full NRIC number, or an image of their NRIC, where it is necessary to verify the tutor's identity and Singapore citizen or permanent resident status to a high degree of accuracy. We do this because tutors work one-to-one with children, where mistaking someone's identity could create a real safety risk. After we have verified the tutor's identity and status, we keep only a record that the check was done, the tutor's status (citizen or permanent resident), and a partial NRIC (the last three digits and the final letter). We delete the full NRIC number and any NRIC images once verification is complete, unless the law requires us to keep them.

We do not collect NRIC numbers from parents or students. We never use a full or partial NRIC number as a password, login or way of confirming who you are when you contact us.

3. How we store and protect your personal data, and how long we keep it

3.1 Where we store your data

Our main databases are hosted by Google Cloud in Sydney, Australia. Some of our service providers store or process personal data in other countries, mainly the United States (see section 5.3).

3.2 How we protect your data

We make reasonable security arrangements to protect personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or loss, and from the loss of any storage medium on which it is stored. These include encryption in transit, access controls based on role, logging of access to sensitive systems, and contracts that require our service providers to protect the data they handle for us. Tutors may only access student data for the lessons they deliver, and may not keep, copy or use it for any other purpose.

No method of transmission or storage is completely secure. You must keep your login details safe (see section 7.1).

3.3 How long we keep your data

We keep personal data only for as long as it is needed for the purposes for which it was collected, or as required or permitted by law. When we no longer need it, we delete it or anonymise it so that it can no longer be linked to you. As a guide:

Data · How long we keep it

Account and lesson records (schedules, notes, lesson reports) · As long as we need it to provide the Services. If you stop using the Services and ask us to delete it, we take reasonable steps to do so

Lesson video and audio recordings and transcripts · As long as we need them to provide the Services, or longer if needed to investigate a complaint, a safety concern or a dispute

Enquiries from people who never become customers · As long as we need it to respond to you and provide the Services

Payment and tax records · As long as accounting and tax law requires (generally 5 to 7 years)

Tutor verification records · While the tutor uses the Tutoring Platform, and after that only as long as needed to meet legal obligations, resolve disputes or enforce our agreements; full NRIC numbers and images are deleted once verification is complete

Records of your marketing consents and withdrawals · As long as needed to show we respected your choices

We may keep personal data longer where we need it to comply with legal or regulatory obligations, resolve disputes or enforce our agreements. We may keep anonymised and aggregated information, which no longer identifies you, for reporting, benchmarking, analytics and improving our Services.

If you stop using the Services and ask us to delete your personal data, we will take reasonable steps to do so, subject to the exceptions above.

3.4 Data breaches

If we have reason to believe that a data breach affecting personal data we hold has occurred, we will take immediate steps to contain it and assess whether it is notifiable under the PDPA. If we assess that a breach is notifiable, we will notify the Personal Data Protection Commission (PDPC) as soon as practicable, and in any case no later than 3 calendar days after we make that assessment. Where the breach is likely to result in significant harm to you, we will also notify you as soon as practicable, unless an exception under the PDPA applies. Where the affected individual is a child, we will also inform the child's parent or guardian.

4. How we use your personal data

Below is information about how we use your personal data. These lists are not exhaustive. We may also disclose personal data to others (for example, professional advisers, auditors, insurers, or government and law enforcement agencies) where required or permitted by law.

4.1 General purposes

We may use your personal data to build, operate and improve the Services and as necessary to perform our agreement with you. We may use your personal data to:

• verify or authenticate your identity and the information you give us;
• carry out the checks needed to approve a tutor to use the Tutoring Platform;
• enable you to access and use the Services;
• enable you to create and update your profile;
• maintain and update our records;
• operate, protect, improve and optimise the Services and our customers' experience;
• perform analytics and research to improve the Services;
• provide customer service and respond to your questions;
• process, manage and administer payments, refunds, billing issues and tutor payouts;
• send you service messages, updates and account notifications;
• keep students safe, including investigating safety concerns and complaints;
• detect and prevent fraud, misuse and breaches of our Terms;
• comply with our legal and regulatory obligations, including tax obligations;
• complete internal accounting and administration; and
• any other purpose you have consented to.

4.2 Purposes for different users

In addition to the above, we use your personal data for different purposes depending on the type of user you are.

Students

To provide a personalised tutoring and learning experience. We use the information we collect about you to:

1. provide you with the Services; 2. match you with a suitable tutor; 3. build a picture of your learning (your knowledge profile), which may be linked across the Services you use; 4. keep a record of your tutoring progress; and 5. help your study by sharing your progress with your parent or guardian, your tutor and, where you use the Teacher Software, your teacher.

Depending on which Services you use, we may share your account information with your parent or guardian, teacher and school administrator.

We do not use students' personal data to show them advertising, we do not make student profiles public or searchable, and we do not collect the precise location of a student's device.

Tutors

We use the information we collect about you to:

1. verify your identity, citizenship or permanent residence, qualifications and the declarations you make; 2. decide whether to approve you to use the Tutoring Platform, and check that you continue to meet our standards; 3. present your tutor profile to parents and match you with students; 4. enable you to access the Tutoring Platform; 5. collect lesson fees on your behalf and pay you; 6. review lesson quality and student safety; and 7. perform our agreement with you.

Teachers

We use the information we collect about you to:

1. verify the teacher profile information you provide; 2. enable you to access the Teacher Software; and 3. perform our agreement with you or your school.

Parents and guardians

We use the information we collect about you to:

1. understand your child's needs and match your child with a tutor; 2. arrange and manage lessons; 3. keep you updated about your child's progress, including through lesson reports; 4. take payments for lessons on behalf of your child's tutor; and 5. contact you about your account and your child's lessons.

4.3 Sharing your personal and platform information with tutors

When you engage a tutor through Tutero, we share with that tutor the personal data and platform information they need to deliver lessons to your child, such as your child's name, level, subjects, learning goals, relevant learning needs you have told us about, lesson history and progress. An account can be linked with a tutor's account if the tutor invites you to join the platform, or if you use the account linking function for an existing account.

Tutors may use this information only to deliver lessons through the Tutoring Platform. They must not use it for any other purpose, must not contact students outside the platform, and must not keep copies after they stop tutoring the student.

4.4 Use of your personal data for marketing and advertising

With your consent, or where otherwise permitted by law, we may use your personal data to:

• send you information about our Services and offers by email;
• call you, or send you SMS or WhatsApp messages, about our Services;
• conduct product and market research; and
• personalise, measure and improve our advertising and marketing.

Calls, SMS and WhatsApp to Singapore numbers. We will only send marketing calls, SMS or WhatsApp messages to a Singapore telephone number if you have given us clear and unambiguous consent in writing or another accessible form (for example, by ticking a separate consent box on our enquiry form), or if we have checked that the number is not registered on the relevant Do Not Call register, as the PDPA requires. Service messages about lessons you have booked or an enquiry you have made are not marketing.

Email. Our marketing emails will identify Tutero, include a working unsubscribe link, and comply with the Spam Control Act 2007.

Withdrawing consent. You can opt out of marketing at any time by clicking "unsubscribe" in an email, replying "STOP" to an SMS or WhatsApp message, telling us on a call, or contacting our Privacy Officer (see section 8). We will act on your request within the time the PDPA allows. You will still receive service and account messages while you have an active account.

We do not sell your personal data, and we do not send marketing directly to students under 18.

4.5 Use of financial information

When you pay for lessons, we collect payment information such as your credit or debit card details, billing details and other account and contact information (Financial Information). Card payments are processed by our payment provider, Stripe. Full card numbers are held by Stripe, not stored on our own servers.

We collect Financial Information only with your knowledge, and use it only to process payments for the Services you request, issue refunds and keep records required by law. Financial Information is encrypted throughout the payment process and is shared only with our payment provider, your card issuer and the financial institutions involved in processing the payment.

Our payment provider is not permitted to use your Financial Information for any other purpose, except as its own terms and privacy policy allow and as required by law. Tutero makes no representations about the privacy practices of third-party payment providers and is not responsible for their privacy policies.

4.6 Lesson recordings and AI lesson reports

We may record (video and audio) and transcribe online lessons on the Tutoring Platform. Where we do, parents, tutors and students are told before the first recorded lesson and on screen while a lesson is being recorded. We use lesson recordings and transcripts to:

• generate lesson reports and progress summaries for parents, using artificial intelligence (AI) tools;
• check lesson quality and help tutors improve;
• keep students safe and investigate any concerns or complaints; and
• resolve disputes, for example about whether a lesson took place.

The AI tools we use are provided by third-party technology companies (see section 5.3), which process recordings and transcripts on our behalf under contracts that do not allow them to use the content to train their own models. Lesson reports are reviewed against our quality standards, and you can contact us if you think a report is wrong.

Recordings can be viewed by the student's parent or guardian, by the tutor who taught the lesson, and by authorised Tutero staff. Tutors must not make their own recordings of lessons. We keep recordings for the period set out in section 3.3.

We may combine and de-identify information from lessons and lesson reports so that it can no longer identify you, and use it for analytics, benchmarking and to improve our Services (see section 5.2).

5. Disclosing your personal data

5.1 Disclosure with your consent

Except as stated in this Policy or as required or permitted by law, we will only disclose your personal data with your consent, and only the personal data covered by that consent.

5.2 Anonymised data

We may combine and anonymise the information we collect so that it no longer identifies any individual. We may use anonymised information for regulatory compliance, industry and market analysis, reporting, research, and improving our Services.

5.3 Service providers and transfers outside Singapore

We use trusted service providers to operate the Services. They process personal data on our behalf and only on our instructions. They include providers of:

• cloud hosting and databases (Google Cloud, in Sydney, Australia);
• payments (Stripe);
• website and product analytics (Google, Microsoft, Mixpanel);
• advertising (Google, Meta);
• video lessons, recording and transcription;
• AI tools used to produce lesson reports and support our team;
• phone, SMS, WhatsApp and email communications;
• customer relationship management and support tools; and
• identity verification.

Because Tutero is based in Australia and our providers operate internationally, your personal data will be transferred to, stored in and accessed from countries outside Singapore, mainly Australia and the United States. Our staff in Australia and elsewhere may access your personal data to provide the Services.

When we transfer personal data outside Singapore, we take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to give the data a standard of protection that is at least comparable to the protection under the PDPA. We do this mainly through contracts with our service providers, and in some cases by relying on certifications the recipient holds, as the PDPA and its regulations allow. You can contact our Privacy Officer for more information about these safeguards.

5.4 Other disclosures

We may disclose your personal data:

• to the tutor you engage, as described in section 4.3;
• to your child's school or teacher, where you use the Teacher Software with them and consent has been obtained;
• to our professional advisers, auditors and insurers;
• to a buyer or successor if all or part of our business is sold, merged or restructured, subject to confidentiality obligations; and
• to government authorities, regulators, courts or law enforcement agencies where required or permitted by law, including where there is a risk to a child's safety.

6. Accessing and correcting your personal data

You can view and update parts of your personal data by logging in to your account. You can also ask our Privacy Officer for access to the personal data we hold about you, and for information about how it has been used or disclosed in the past year.

We will respond to an access request as soon as reasonably possible. If we cannot respond within 30 days, we will tell you in writing within those 30 days when we expect to be able to respond. We may charge a reasonable fee to cover the cost of responding to an access request. If so, we will give you a written estimate before we proceed. We will ask you to verify your identity before we give you access.

In some cases, the PDPA allows or requires us to refuse access, for example where providing access could reveal personal data about another person, would be against the interests of a child, or relates to a dispute or investigation. If we refuse, we will tell you why, to the extent the law allows.

If you believe personal data we hold about you is inaccurate or incomplete, you may ask us to correct it. We will correct it as soon as practicable, unless we have reasonable grounds not to. If we do not correct it, we will note your requested correction on our records. Where we correct your data, we will also send the corrected data to organisations we disclosed it to in the past year, where the PDPA requires.

Please keep your information up to date so that we can continue to provide the Services to you.

To make a request, contact our Privacy Officer (see section 8).

7. Your rights and responsibilities

7.1 Your responsibilities

You must keep your username and password safe and tell us promptly if your account has been accessed without permission.

7.2 Your rights

You have the right to:

• withdraw your consent to our collection, use or disclosure of your personal data at any time, by giving us reasonable notice. We will tell you the likely consequences of withdrawing (for example, that we may no longer be able to provide lessons). Withdrawing consent does not affect our right to keep and use personal data where the law allows us to without consent;
• ask us to delete your personal data, subject to the retention exceptions in section 3.3;
• opt out of marketing, as described in section 4.4. You cannot opt out of administrative and transaction messages while your account is active;
• ask for access to, or correction of, your personal data, as described in section 6; and
• if you are a student or a parent, ask us not to share the student's data between Services (for example, between the Tutoring Platform and the Teacher Software).

To exercise any of these rights, contact our Privacy Officer (see section 8).

8. Contact us

8.1 Privacy Officer

Our Privacy Officer is responsible for making sure Tutero complies with the PDPA (our Privacy Officer is our data protection officer under the PDPA). You can contact them with any questions, requests or complaints about this Policy or our handling of your personal data:

Privacy Officer: support@tutero.com.au

8.2 Complaints

If you have a concern about how we have handled your personal data, please tell us so we can address it.

We take our privacy obligations seriously and will treat your complaint confidentially. Our Privacy Officer will acknowledge your complaint within a reasonable time, discuss your concerns with you and explain how they may be resolved. We aim to resolve complaints in a timely manner.

8.3 Personal Data Protection Commission

If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore at https://www.pdpc.gov.sg. You may also be able to contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au.

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