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Privacy policy
1. About our policy
1.1 Introduction
Hello, we’re Tutero (we, us, Tutero, all of which refer to Tutero Pty Ltd). This Privacy Policy (Policy) is provided to ensure you understand your rights and obligations when you use any of the products and services offered by us, which include but are not limited to:
(a) the Tutero website through which you can access the Tutoring Platform;
(b) personalised online tutoring platform (Tutoring Platform);
(c) maths co-teacher software (Teacher Software); and
(d) any other new service released by us from time to time.
(together, referred to as Services)
Tutero respects the rights and privacy of all individuals and is committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), and other relevant privacy laws. This Policy describes how, and the purpose for which, Tutero collects, uses, stores and discloses your information, including personal information, in connection with your interaction and engagement with Tutero and your access to and use of the Services.
1.2 Your agreement to this Policy
By accessing the Services, you confirm that you have read and agree to the terms of this Policy and consent to your personal information being collected, stored, used and disclosed in accordance with this Policy. If you are under 18 years of age, or legally a minor in your relevant location, a parent or guardian must consent on your behalf. Please read this Policy carefully to understand our practices regarding your personal information.
If you do not wish to provide us with your personal information, then you are not required to do so. However, by deciding not to provide us with your personal information you may not be able to access / use the Services or effectively use the Services to the same standard as if you had provided the required personal information.
1.3 Changes to this Policy
Tutero may routinely review and update this Policy, including taking account of new or amended laws, new technology and/or changes to operations. All personal information held by Tutero will be governed by the most recent updated Policy.
If changes are made to this Policy, we will upload the revised Policy to the Tutero website and/or the Service. If we make any significant changes which may reduce your rights under the Policy, we will provide prominent notice by posting a notice on the Services and/or notifying you by email with reasonable notice.
If you disagree with the revised Policy, you may terminate your agreement with Tutero (in accordance with the terms of the relevant agreement), cease using the Services and deactivate your account. Your continued use of any of the Services following the effective date of the revised Policy will constitute your acceptance of any changes.
If we make material changes to the types of personal information we collect from a student, or how we use it, we will notify parents in order to obtain parental consent or provide schools with necessary information about those changes where they have obtained parental consent.
1.4 Personal information
When used in this Policy, the term “personal information” has the meaning given to it in the Privacy Act. Accordingly, “personal information” includes any information or opinion that identifies or can be used to identify, contact, or locate you. This may include, but is not limited to, your name, date of birth, address, gender, contact details (including phone numbers and email addresses) and possibly financial information, including your credit card or direct debit account information.
2. What information does Tutero collect?
2.1 Types of personal information from different users
We may collect personal information about you from the following people or places (below is a non-exhaustive list):
From you or your parents: name, date of birth, contact details (including telephone number, address and email address), education background, personal interest, gender, language preference.
From your teacher (if the parental consent is obtained for the purpose of the Teacher Software): name, historical assessment information, email address, education background, gender, language preference.
From your use of the Services:
1. For the Tutoring Platform: information including but not limited to your curriculum understanding, frequency of platform usage, any tutoring schedules that are formed, any notes and comments created, the details of your tutoring engagements, any homework tasks that are set, and recordings of your video tutorials.
2. For the Teacher Software: information including but not limited to your curriculum understanding, frequency of platform usage, any notes and comments created, the details of your learning engagements, any homework tasks that are set.
From you: your name, email address, past academic performance, education background, your working rights and background checks you: your name, email address, past academic performance, education background, your working rights and working with children checks.
From your use of the Tutoring Platform: frequency of platform usage, any tutoring schedules that are formed, any notes and comments created, the details of your tutoring engagements, any homework tasks that are set, and recordings of your video tutorials.
From you: your name, job and title, school name and address, email address and contact number
From your use of the Teacher Software: teaching materials, teaching curriculum, platform usage information, updates to lesson plans.
We may collect your email address, name, and details of which student is your child, address, and payment information.
2.2. Information we automatically collect from you
When you use any of our Services, Tutero automatically collects certain information from you, including personal information.
(a). Usage information
Tutero collects information about your activities during your use of the Services, such as the pages or content you viewed, your searches, and other actions you take while using the Services.
(b). Communication records
If you contact Tutero by telephone, email, post via the Services (e.g. online chat) or in person we automatically record any information, including personal information that you provide to us.
When you communicate with other users (where applicable) via the relevant Service, we monitor, record and store those communications and any information you choose to provide to other users.
(c). Log Data and Device Information
We automatically collect log data and device information when you access and use the Services. That information includes, among other things, a recording showing how you used the Services, your clicks, scrolls and activities, 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 have viewed or engaged with before or after using the Services. We use this type of information to provide the Services and to analyse trends.
(d). Cookies
When you use our Services, Tutero may obtain information using technologies such as cookies, tags, web beacons, and navigational data collection (log files, server logs, and clickstream data) to better understand your experience. For example, Tutero may collect information like the date, time and duration of visits and which webpages are accessed.
Tutero collects some anonymous information about how you use a Service by setting and accessing cookies on your computer. A cookie is a small text file that allows our system to identify and interact more effectively with your computer or device. We use cookies to measure traffic patterns, to determine which areas of our website has been visited, and to measure transaction patterns in the aggregate. We use this to research, to monitor user habits to improve our online services. You can configure your web browser to restrict or disable cookies, however, this may cause some parts of the Services not to have full functionality.
Tutero may also log IP addresses (the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track user movements, and gather broad demographic information.
(e). Payment Transaction Information
Tutero collects information related to your payment transactions when you access or use our Services, including the payment instrument used, payment dates and times, payment amounts, your billing postcode, address and other related transaction details. This information is necessary for the adequate performance of the agreement between you and Tutero (where applicable).
2.3. Information we collect from third parties
Tutero may collect personal information about you, including sensitive information, from third parties. We do not control, supervise and are not responsible for how those third parties process your personal information. Any information request regarding the disclosure of your personal information by a third party to us should be directed to such third parties.
(a). Third Party Services
If you link, connect, or login to the platform of relevant Service or your account through a third-party service (e.g. Google, Apple, Facebook) the third party service may send us information such as your profile information from that service. This information varies and is controlled by that third party service or as authorised by you via your privacy settings with that third party service. The use of these technologies allows those third-party services to evaluate your use of the Services and other websites, deliver customised advertising content, measure the effectiveness of their advertising, and provide other services relating to website activity and internet usage.
Tutero makes no representations or warranties in relation to the privacy practices of any third-party service providers and we are not responsible for the privacy policies or the content of any third party service provider.
(b). Advertising Services
If you click on an online Tutero advertisement (e.g. ads on Google) the third party service hosting that advertisement will collect certain information and will provide that information to us to allow us to measure the effectiveness of our advertising.
(c). Your References
If someone has provided Tutero with a reference about you, such information will be held and stored by Tutero
3. How do we hold your personal information and where do we store your personal information?
All the data collected by us is stored in Council Bluffs, Iowa by Google’s data centres. Tutero will retain the personal information that is collected from and about you for as long as it is needed to provide the Services to you.
We take reasonable steps to delete the personal information we collect if you no longer use our Services and you ask us to delete your information.
Tutero may however retain and use personal information as necessary to comply with legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytics purposes and for product and service improvement.
If we suspect any misuse, loss of, or unauthorised access to your personal information, we will inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your personal information. In the event of a significant breach, we will notify you within a reasonable timeframe, as required by U.S. law. If we determine that the breach is likely to result in serious harm to you and we are unable to mitigate the risk with remedial action, we will take further action in accordance with the Privacy Act.
4. How will we use your personal information?
Information about how we use your personal information is below. This list is not exhaustive and there may be other third parties to whom we give your personal information (for example, professional advisors or insurers) where required or permitted by law.
4.1. General purposes
We may use your personal information to build, operate and improve the Services and as necessary for the adequate performance of our agreement with you.
Below is a non-exhaustive list of the general purposes for which we may use your personal information. We may use your personal information to:
- verify or authenticate information provided by you and your identity;
- conduct necessary checks to verify the information you have provided as part of the registration process;
- enable you to access and use the Services;
- enable you to create and update your personal profile;
- enable you to create and update your tutoring company profile;
- maintain and update our records;
- operate, protect, improve, and optimise the Services and customers’ experiences;
- operate, improve, and optimise related services, such as by performing analytics and conducting research;
- assist us to provide effective customer service;
- process, manage and administer account payments, billing issues and payroll transactions;
- send you support messages, updates and account notifications;
- where you have consented to the use or disclosure;
- complete internal accounting and administration; and
- facilitate any authorised payments.
The primary purpose for which we collect information about you is to enable Tutero to perform its business activities and functions and to provide you with the best customer experience.
4.2. Purposes for different users
In addition to the above, we will use your personal information for different purposes depending on what type of user you are.
For the purpose of providing personalised tutoring and learning experience for you.
We will use the information that we have collected about you to:
1. provide you with the Services;
2. build up your personal knowledge graph which may be linked with one or more Services you are using;
3. maintain a record of your tutoring progress; and
4. help your study by sharing your progress with your teachers and tutors.
Depending on which Service(s) you have signed up with us, we may share your account information with your parents, teacher and school administrator.
We will use the information that we have collected about you to:
1. verify the tutor profile information provided by you;
2. enable you to access the Tutoring Platform; and
3. perform our contracts with you.
We will use the information that we have collected about you to:
1. verify the teacher profile information provided by you;
2. enable you to access the Teacher Software; and
3. perform our contracts with you or your school.
We will use the information that we have collected about you to:
1. keep you updated about your child’s performance on our Services; and
2. for payment purposes.
4.3. Sharing of your personal and platform information with tutors
If you engage a Tutero affiliated tutor for tutoring services, this constitutes as consent to share your information with that tutor. As such, we may share the personal and platform usage information we collect from you with that tutor. An account can be linked with an individuals tutor’s account if they invite you to join the platform, or if you utilise the account linking functionality for your existing account.
4.4. Use of your personal information for marketing and advertising purposes
We may use your personal information to undertake and direct advertising and marketing activities that we consider may be of interest to you. These communications may be sent in various forms in accordance with applicable US marketing laws, such as the CAN-SPAM Act and the California Consumer Privacy Act (CCPA)..
Below is a non-exhaustive list of the purposes for which we may use your personal information. We may use your personal information to:
- send promotional messages, marketing, advertising, and other information to you via telephone, email, online and other means;
- contact you by telephone or text message solely in connection with the services we provide and only if you have provided us with your phone number;
- conduct product and market research; and
- personalise, measure, and improve our advertising and marketing.
Communications may also be received from other companies with whom we hold a relationship for the purpose of providing the Services.
You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
California residents may have additional rights under the CCPA, including the right to opt-out of the sale of their personal information for advertising purposes. To exercise this right, please email [email protected]
4.5. Use of financial information
If you would like to proceed with using our Services, Tutero may collect information about the purchase or transactions. This includes, payment information, such as your credit card or debit card number (stored securely), billing details and other account and contact information (Financial Information).
Tutero will only collect your Financial Information from you with your prior knowledge.
Tutero may use your Financial Information solely to process payments for the Services you request or purchase. We only use and retain your Financial Information to complete payments you initiate. Any Financial Information that is collected is solely for the purpose of transaction approval and the transfer of funds.
Tutero provides data encryption throughout the payment process and only shares your Financial Information with your credit card provider, third party payment processor, and financial institution, to process payments. The Financial Information we collect from you is strictly confidential and held on secured servers in controlled facilities.
We may use third party agents to manage online payment processing. Any third-party agent used by us is not authorised to use your Financial Information in anyway other than to process payments and is required to keep any Financial Information it uses or collects confidential.
Tutero retains Financial Information for as long as necessary to process payments and comply with legal and regulatory obligations, such as record-keeping for tax or auditing purposes. Financial Information is securely stored by our third-party payments provider, and Tutero cannot directly access or use your payment details. You may remove your Financial Information by logging into the Tutero platform and managing your account settings. Alternatively, you can contact Tutero customer support to request the deletion of your payment details, subject to applicable legal requirements
Tutero makes no representations or warranties in relation to the privacy practices of any third party agent and we are not responsible for the privacy policies or the content of any third party agent.
5. Disclosing your personal information
5.1. Disclosure with your consent
Except as may be stated in this Policy, where you have provided your express consent for specific parts of your personal information to be disclosed, we will only disclose and share your personal information that is held by us as at the time of receiving your consent.
5.2. Unidentified data sharing
Tutero may combine and de-identify the information collected from you. This anonymised information may be used for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
6. Accessing your personal information
You may access and amend parts of your personal information by logging into your account and making changes at any time. Alternatively, you have a right to request access to your personal information at any time by contacting our Privacy Officer.
Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information. If you make an access request, we will ask you to verify your identity.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
We request that you keep your information as current as possible so that we may continue to improve our service to you.
To request access or to amend your personal information, please contact our Privacy Officer (contact details in Section 5.1).
7. Your rights and responsibilities
7.1. Your responsibilities
You must ensure that your username and password are kept safe and tell us when your account has been accessed without permission.
7.2. Your rights
You have the right to ask us to:
- stop collecting your personal information and remove your personal information from our records. Please note that as a result of such a request, you may not be able to access or use the Services;
- stop sending you marketing communications or targeted advertising from us. Please note you cannot opt-out of receiving administrative and transaction related emails from us unless you deactivate your account;
- keep your data anonymous, or stored under a pseudonym; and
- if you are a Student or a Parent, not share the data of the Student from one Service to another Service (e.g. no data sharing between the Tutoring Platform and the Teacher Software).
Please contact our Privacy Officer for any of your requests above.
8. Contact us
8.1. Feedback
If you have any feedback or questions about this Privacy Policy or any of our privacy-related practices, please contact our Privacy Officer at [email protected].
8.2. Complaints
If you have a concern about how we have handled your personal information, please let us know so we can address the problem.
We are genuinely committed to our privacy obligations detailed in this Policy and we aim to ensure that your requests or complaints are treated confidentially. Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Last updated 18 September 2024