Version 3.0. Last revised 8th June 2020
In-Tuition Networks Ltd takes your privacy very seriously and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit one of our websites or web systems or as a Customer of In-Tuition Networks Ltd and tells you about your privacy rights and how the law protects you.
Who we are
In-Tuition Networks Ltd (company number: 4401131) Registered in England & Wales registered office: 41 Walsingham Road, Enfield, EN2 6EY
collectively referred to as “In-Tuition”, “we”, “us” or “our” in this privacy notice.
Purpose of this privacy notice
This privacy notice aims to give you information on how In-Tuition collects and processes your personal data through your use of this website; our Control Panel and any other related websites; and whilst you are an In-Tuition Customer.
Our products and websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice may be referenced in an Agreement in which case it will form part of such Agreement.
In-Tuition is the controller and is responsible for your personal data.
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us.
We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk).
Our ICO Registration Number: Z1699546
If you have a data protection complaint, you may register it with the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date mentioned at the top of the page. Historic versions can be obtained by contacting us. If you are a Customer, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You should do this by logging into our Control Panel where you can edit your account information.
Our websites and online systems may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The type of personal information we collect
Personal identifiers, contacts and characteristics (for example, your name and contact details).
Billing records relating to the services we supply to you.
Technical data such as the internet protocol (IP) address which may be associated with your username.
Marketing and Communications data which includes your preferences in receiving marketing from us and your communication preferences.
Our staff may get to know your your date of birth during the course of our business relationship with you and they may store it as a reminder so that they can wish you happy birthday, although this is not company policy and your date of birth is not used for anything else.
Our analytics data for this website is collected using Plausible Analytics who do not collect any personally identifiable information. All the site measurement is carried out absolutely anonymously. Cookies are not set and no personal data is collected. All data is in aggregate only.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we get the personal information and why we have it
Most of the personal information we process is provided by you directly, such as when you:
- Purchase our products or services; or
- create an account on our website; or
- subscribe to our service or publications; or
- request marketing to be sent to you; or
- enter a survey; or
- provide some feedback.
We may also receive personal information indirectly, from the following sources in the following scenarios:
- Corporate credit reference agencies (for example if your business applies for a credit account with us); or
- your profile photo from public databases such as Linkedin or Gravatar.com which may be automatically associated with your contact record by our contacts software.
We use your personal information in order to:
- Provide the goods or services you or your organisation have purchased from us;
- Inform you about service changes or technical updates to the services you or your organisation subscribe to;
- Send you marketing related information about new products and services (which you can opt out of at any time);
- 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 or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing from such marketing.
We may share your personal data with the parties set out below for the purposes set out in the table in “How we use your personal data”:
- Staff, contractors, officers and shareholders of In-Tuition;
- Service providers [acting as processors] who provide services to In-Tuition.
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. Note that where information is passed to these advisers outside of the UK, this will be with your express consent in advance and as part of a specific contractual arrangement.
- HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom who require reporting of processing activities in certain circumstances. Note that where information is passed to authorities outside of the UK, this will be with your express consent in advance and as part of a specific contractual arrangement.
Where possible, all processing is conducted using In-Tuition controlled and hosted systems, even if the third party is based remotely. In any case, we require all third parties to respect the security of your personal data and to treat it in accordance with the law and to maintain terms and processes for privacy and security that are at least as rigorous as our own. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We maintain a list of all In-Tuition suppliers and we audit our contractual relationship with them and their terms and processes for data protection.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- Performance of Contract. Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest. Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
- Comply with a legal or regulatory obligation. Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Your consent. You are able to remove your consent at any time. You can do this using our Control Panel
Purposes for which we will use your personal data
We have set out below a description of all the ways we expect to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To perform our services to you including: Manage payments, fees and charges; collect and recover money owed to us||Identity Contact Financial Transaction Marketing and Communications||Performance of a contract with you.
Necessary for our legitimate interests (to recover debts due to us)
Necessary to comply with a legal obligation.
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to complete a survey||Identity Contact Profile Usage Marketing and Communications||Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and our systems (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Contact Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity Contact Technical Usage Profile||Necessary for our legitimate interests (to develop our products/services and grow our business|
To date, we have not conducted any third party marketing activities. In the unlikely event we ever consider doing so, we will get your express opt-in consent before we share your personal data with any company outside In-Tuition or it’s immediate group for marketing purposes.
Opting out of marketing messages
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
There are various essential notifications we need to send in order to perform our obligations of a contract with you and you may not be able to opt-out of receiving those, although you may be able to provide an alternate contact.
How we store your personal information
Your information is securely stored in our data base and collaboration systems. For more details, please review our security and compliance page. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Accounting and invoicing information is stored in the xero.com accounting system. If you opt to pay by credit card, your personal information will be stored with stripe.com – we do not store any credit card data. If you opt to pay by direct debit, your personal information will be stored with GoCardless who handle our direct debit instructions.
As a general principle, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Your Customer account is managed online using our Control Panel. From this portal you can view, edit and delete your personal information. When you do this, we may also automatically update other systems (including third party systems when necessary) to keep your personal information in sync and to ensure that we can perform the necessary activities to fulfil our Agreement with you such as billing and payment collection. If you use the Control Panel to delete your account, the personal information held there will be deleted immediately from the primary database. The primary database is backed-up continuously and these backups are encrypted and then transferred to a backup storage location where they are kept for 31 days. We will retain our accounting records, which may also contain your personal information, for an indefinite period.
During your business relationship with us, you may have set-up a recurring payment with one of our payment processors such as GoCardless or Stripe. Although our systems will keep a track of the association between your account with either one of these suppliers and with us, we do not control your account and you may wish to edit or delete any personal information associated with those accounts using the GoCardless or Stripe services directly.
If you delete your email account the mailbox is removed permanently from the primary systems within 24 hours. However, encrypted backups of the original mailbox are retained for up to 45 days.
Exercising your legal rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
If you wish to exercise any of the rights, please do so using our Control Panel. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.