Privacy policy

1. Introduction

This Privacy Policy explains how Gravitas Tutors Limited collects, uses, stores and protects personal information.

Gravitas Tutors Limited provides online tutoring services to families in the UK and internationally. In order to do that properly, we need to collect and use certain personal information about parents, guardians, pupils, prospective pupils, tutors, tutor applicants, website visitors and other people who contact us.

We take privacy seriously. Tutoring often involves information that is personal, educational and sometimes sensitive. This policy explains what we collect, why we collect it, who we may share it with, how long we keep it, and what rights you have.

For the purposes of UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018, the data controller is:

Gravitas Tutors Limited

Company number: 14516842

Registered address: C/O Accounts and Legal, 81 King Street, Manchester, Greater Manchester, M2 4AH

Email: arthur@gravitastutors.com

This policy applies to our website, our enquiry and consultation process, our tutoring arrangements, our tutor recruitment process, and our ordinary communications with families, tutors and prospective tutors.

2. The information we collect

The information we collect depends on your relationship with us.

2.1 Parents, guardians, prospective clients and clients

When you enquire about tutoring, book a consultation, speak to us, complete a form, or arrange tutoring, we may collect:

• your name;

• your email address;

• your telephone number or WhatsApp number;

• your location and time zone;

• your child’s name;

• your child’s age, year group and school;

• details of the subjects, examinations or schools you are interested in;

• information about current academic performance, targets, strengths and difficulties;

• information about availability, scheduling and preferred lesson arrangements;

• notes from consultations, calls, emails, WhatsApp messages and other correspondence;

• billing and payment information;

• records of tutoring arrangements, including tutor matches, lesson history and administrative notes.

Parents or guardians may also choose to provide information about a child’s learning needs, health, confidence, anxiety, special educational needs, disability, examination access arrangements, or other circumstances relevant to tutoring. We only ask for this where it is relevant to arranging appropriate support, and in many cases the information is volunteered by the parent or guardian.

2.2 Pupils

We do not seek to collect information directly from children through our website.

However, in order to provide tutoring, we may process information about pupils that is provided by parents or guardians, tutors, schools, or the pupils themselves during the course of tutoring. This may include:

• name, age, year group and school;

• academic subjects and examination goals;

• information about academic performance and areas for development;

• lesson notes, progress updates and tutor feedback;

• information relevant to matching the pupil with an appropriate tutor;

• information about learning needs, confidence, educational background or examination arrangements, where relevant.

We expect parents and guardians to provide information about their child only where they are entitled to do so and where it is relevant to the tutoring support being considered or provided.

2.3 Tutors and tutor applicants

If you apply to work with us as a tutor, or if you provide tutoring through Gravitas Tutors, we may collect:

• your name;

• email address;

• telephone number or WhatsApp number;

• location and time zone;

• educational history;

• qualifications;

• subjects and levels taught;

• teaching and tutoring experience;

• CV, application materials and covering information;

• interview notes;

• references and referee details;

• information relevant to safeguarding and suitability;

• DBS or equivalent background-check information where applicable;

• right-to-work or identity information where applicable;

• profile information, biography, photograph or other material used to present you to families;

• availability and scheduling information;

• payment details and records of payments made to you;

• correspondence and administrative notes.

Tutors working with Gravitas Tutors do so as self-employed contractors, not as employees.

2.4 Website visitors

When you visit our website, we may collect certain technical and usage information, including:

• IP address;

• browser type and version;

• device type;

• pages visited;

• approximate location;

• referring website or campaign;

• interactions with forms or pages;

• analytics and advertising data.

We may collect this through cookies and similar technologies. Our use of cookies is addressed separately in our Cookie Policy.

2.5 Communications

If you contact us by email, form, WhatsApp, telephone, video call, or another channel, we may keep a record of that communication and any information you provide in it.

Consultations and tutor interviews may sometimes be transcribed or summarised. We do not record or transcribe ordinary tutoring lessons as a matter of course.

3. How we collect information

We collect personal information in several ways, including:

• when you complete an enquiry form or contact form;

• when you book a consultation;

• when you correspond with us by email, WhatsApp, telephone or video call;

• during consultations with parents or guardians;

• during tutor applications and interviews;

• from tutors providing lesson updates or progress notes;

• from payment, accounting, scheduling and administrative systems;

• from website analytics and advertising tools;

• from publicly available sources, where relevant to tutor recruitment or due diligence.

Most information is provided directly by you. Some information about pupils may be provided by a parent, guardian, tutor or, where relevant, a school or educational professional.

4. How we use personal information

We use personal information for the following purposes.

4.1 To respond to enquiries

We use parent and prospective client information to:

• respond to enquiries;

• understand what kind of tutoring support may be appropriate;

• arrange consultations;

• answer questions;

• recommend next steps;

• follow up where appropriate.

4.2 To provide tutoring services

We use client, parent, pupil and tutor information to:

• match pupils with suitable tutors;

• brief tutors properly;

• arrange trial sessions and regular lessons;

• manage scheduling;

• monitor progress;

• support communication between parents, tutors and Gravitas Tutors;

• deal with changes, concerns, cancellations or handovers;

• provide a professional tutoring service.

4.3 To manage tutor recruitment and tutor relationships

We use tutor and tutor applicant information to:

• assess applications;

• conduct interviews;

• check suitability;

• take references where appropriate;

• create tutor profiles;

• match tutors with suitable families;

• manage availability, communications and payments;

• maintain appropriate standards across the tutor network.

4.4 To process payments and manage accounts

We use relevant information to:

• issue invoices;

• process payments;

• keep financial records;

• pay tutors;

• manage accounting, bookkeeping and tax obligations;

• deal with payment queries or disputes.

4.5 To improve our services and website

We may use information to:

• understand how people find and use our website;

• improve website content and user experience;

• assess the effectiveness of advertising;

• improve our enquiry, consultation and tutor-matching process;

• maintain internal records and operational systems.

4.6 To send marketing communications

We may in future send occasional marketing communications, such as updates, articles or information about our services. We will only do this where we have a lawful basis to do so, and where required we will ask for consent.

You can opt out of marketing communications at any time.

We will not sell your personal information to third parties.

4.7 To meet legal and safeguarding obligations

We may use personal information where necessary to:

• comply with legal obligations;

• keep appropriate business and accounting records;

• respond to lawful requests from authorities;

• protect the safety and wellbeing of pupils, tutors, clients or others;

• investigate complaints or concerns;

• establish, exercise or defend legal claims.

5. Our lawful bases for processing

Under UK data protection law, we must have a lawful basis for using personal information. Depending on the circumstances, we rely on one or more of the following lawful bases.

5.1 Contract

We process personal information where it is necessary to enter into or perform a contract with you. This includes arranging and providing tutoring services, managing tutor agreements, processing payments and administering lessons.

5.2 Legitimate interests

We process personal information where it is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests include:

• running and administering a tutoring business;

• responding to enquiries;

• matching pupils with suitable tutors;

• managing client and tutor relationships;

• improving our services;

• maintaining appropriate business records;

• promoting our services in a proportionate way;

• protecting our business, clients, pupils and tutors.

5.3 Legal obligation

We process personal information where necessary to comply with legal obligations, including accounting, tax, company, safeguarding and regulatory obligations.

5.4 Consent

We may rely on consent in certain circumstances, for example:

• where you opt in to certain marketing communications;

• where non-essential cookies or tracking technologies require consent;

• where we ask for specific permission to use certain photographs, testimonials or profile materials.

You can withdraw consent at any time, although this will not affect processing that has already taken place.

5.5 Special category information

Some information provided to us may be special category data under data protection law. This may include information about health, disability, special educational needs, mental health, religious or cultural needs, or other sensitive personal circumstances.

We may process this information where:

• it has been provided by a parent or guardian because it is relevant to arranging appropriate tutoring support;

• it is necessary for safeguarding or the welfare of a child;

• we have explicit consent where required;

• it is necessary for legal claims;

• another condition under data protection law applies.

We use this information carefully and only where it is relevant to the support being considered or provided.

6. Children’s information

We provide services relating to children and young people, but we do not seek to collect personal information directly from children through our website.

Information about children is usually provided by parents or guardians. We use that information to understand the child’s educational needs, recommend appropriate support, brief tutors and manage tutoring arrangements.

Because tutoring can involve sensitive educational and personal information, we ask parents and guardians to provide only information that is accurate, relevant and appropriate.

Where information about a child is shared with a tutor, we share only what the tutor reasonably needs in order to provide suitable support.

7. Sharing information with tutors

Where we match a pupil with a tutor, we will share relevant information with that tutor. This may include:

• parent or guardian contact details;

• pupil name, age, year group and school;

• subject, examination and academic goals;

• scheduling information;

• relevant educational background;

• relevant notes from consultations or previous tutoring;

• learning needs or other circumstances relevant to tutoring.

Tutors are self-employed contractors. They are expected to handle personal information responsibly, use it only for the purpose of providing tutoring through Gravitas Tutors, and keep it confidential.

8. Other third parties we use

We use trusted third-party service providers to help us run the business. These may include:

• Notion, for internal records and operational systems;

• Gmail / Google Workspace, for email, documents and communications;

• Google Meet, for online consultations, interviews and meetings;

• Stripe, for payment processing;

• Xero, for accounting and bookkeeping;

• Accounts and Legal, for accountancy and related professional services;

• Calendly and/or TidyCal, for scheduling;

• WhatsApp, for communications;

• Fillout and/or Typeform, for forms;

• Google Analytics, for website analytics;

• Google Ads, for advertising and conversion measurement;

• Meta Pixel, for advertising and measurement;

• LinkedIn Insight Tag, for advertising and measurement;

• Framer, for website hosting and publishing.

These providers process information in accordance with their own terms, privacy policies and data protection obligations. Where appropriate, we take steps to ensure that providers process personal information securely and only for the purposes for which we use them.

We may also share information with professional advisers, insurers, legal advisers, accountants, regulators, authorities, or other parties where necessary for legal, regulatory, safeguarding, accounting or business reasons.

9. International transfers

Gravitas Tutors Limited is based in the United Kingdom. We may work with families and tutors in other countries, including Germany, Switzerland, Hong Kong and Singapore.

Some of the service providers we use may process or store personal information outside the United Kingdom. Where personal information is transferred internationally, we take steps intended to ensure that it remains protected in accordance with applicable data protection law. These steps may include using providers that rely on adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or other appropriate safeguards.

Where we share information with a tutor or family outside the UK because it is necessary to arrange or provide tutoring, we do so only to the extent reasonably necessary for that purpose.

10. Payments

Payments may be made by Stripe or by bank transfer where agreed.

We do not store full card details ourselves. Card payments are handled by Stripe. Stripe may collect and process payment card information, billing details and transaction data in accordance with its own privacy policy and legal obligations.

We may keep records of invoices, payments, outstanding balances, refunds, disputes and related correspondence for accounting, tax and business purposes.

11. Website analytics, advertising and cookies

We use website analytics and advertising tools to understand how people find and use our website and to measure the effectiveness of advertising.

These may include:

• Google Analytics;

• Google Ads;

• Meta Pixel;

• LinkedIn Insight Tag.

These tools may collect information about your device, browser, approximate location, pages visited, interactions with the website and how you arrived at the site. They may use cookies or similar technologies.

Our use of cookies and similar technologies is explained in our separate Cookie Policy.

Where required by law, we will ask for your consent before setting non-essential cookies or using certain tracking technologies.

12. Marketing

We may use your contact details to send you information about our services, articles, updates or other material that may be relevant to you.

We will only send marketing communications where we have a lawful basis to do so. This may include consent or, in some circumstances, our legitimate interest in keeping existing or prospective clients informed about relevant services.

You can opt out of marketing communications at any time by contacting us at arthur@gravitastutors.com or by using any unsubscribe link provided in the communication.

We will not sell your personal information or share it with third parties for their own direct marketing purposes.

13. Transcripts and notes

Consultations with parents and interviews with tutors may sometimes be transcribed or summarised to help us keep accurate records, assess needs, brief tutors properly and manage tutor recruitment.

We do not transcribe ordinary tutoring lessons as a matter of course.

Where transcripts or summaries are created, they may contain personal information and, in some cases, sensitive information. We treat them as confidential business records and use them only for appropriate Gravitas Tutors purposes.

14. How long we keep information

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide services, maintain records, comply with legal obligations, resolve disputes and protect our legitimate interests.

Because tutoring relationships and educational enquiries can develop over time, and because we may need records for accounting, safeguarding, legal or administrative reasons, retention periods may vary.

As a general guide:

• enquiry records may be kept for as long as reasonably necessary to manage follow-up and maintain appropriate business records;

• client and pupil records may be kept for a reasonable period after tutoring ends in case further support is requested, queries arise, or records are needed for legal, safeguarding, accounting or administrative reasons;

• tutor application records may be kept for a reasonable period for recruitment, safeguarding, reference and business purposes;

• tutor records may be kept for as long as necessary to manage the tutor relationship and thereafter for legal, accounting and administrative purposes;

• financial and accounting records will usually be kept for at least six years, or longer where required by law;

• safeguarding-related records may be kept for longer where appropriate or legally required.

When information is no longer needed, we will delete it, anonymise it, or archive it securely.

15. How we protect personal information

We take reasonable technical and organisational steps to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These steps may include:

• using reputable service providers;

• restricting access to information where appropriate;

• using password-protected systems;

• keeping internal records in controlled systems;

• limiting the information shared with tutors to what is relevant;

• maintaining appropriate confidentiality expectations with tutors and service providers.

No system can be completely secure. If we become aware of a personal data breach that creates a risk to individuals, we will take appropriate steps, including notifying affected individuals and/or the Information Commissioner’s Office where legally required.

16. Your rights

Under data protection law, you may have the right to:

• request access to the personal information we hold about you;

• ask us to correct inaccurate or incomplete information;

• ask us to delete your information in certain circumstances;

• ask us to restrict how we use your information;

• object to certain uses of your information;

• ask for a copy of certain information in a portable format;

• withdraw consent where we rely on consent;

• complain to the Information Commissioner’s Office.

These rights are not absolute. For example, we may need to keep certain information for legal, safeguarding, accounting or legitimate business reasons.

If you wish to exercise your rights, please contact us at arthur@gravitastutors.com.

We may need to verify your identity before responding to a request.

17. Complaints

If you have a concern about how we handle personal information, please contact us first so that we can try to resolve it.

You can contact us at:

arthur@gravitastutors.com

You also have the right to complain to the UK data protection regulator, the Information Commissioner’s Office:

Information Commissioner’s Office

Website: https://ico.org.uk

Telephone: 0303 123 1113

18. Changes to this policy

We may update this Privacy Policy from time to time. The latest version will be posted on our website with the date of the most recent update.

If we make material changes, we may take additional steps to bring them to your attention where appropriate.

19. Contact

If you have any questions about this Privacy Policy or how Gravitas Tutors Limited handles personal information, please contact:

Gravitas Tutors Limited

C/O Accounts and Legal

81 King Street

Manchester

Greater Manchester

M2 4AH

Email: arthur@gravitastutors.com