Version 2.0. Last revised 17th May 2018
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
- Registered in England & Wales registered office: 41 Walsingham Road, Enfield, EN2 6EY
- Company number: 4401131
- VAT number: GB 791 3633 15
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 customer portal 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.
Our Data Protection Officer is Adriano Cataluddi. He 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 Adriano using our normal contact methods or by email to privacy@ our domain name. If you send email to that address, a copy will also be sent to our Managing Director.
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 administrator portal 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 data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Includes first name, last name, username (which may be an email address) or similar identifier.
Includes address, email address and telephone numbers.
Includes details about payments to and from you, and other details of the services you use from us.
Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and services.
Includes your username and password, preferences, feedback and survey responses.
Includes information about how you use our websites, products and services.
Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Lawful basis for collection of your data
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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
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.
How is your personal data collected?
We use different methods to collect data from and about you, these include:
You may give us your Identity / Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services
- create an account on our website
- subscribe to our service or publications
- request marketing to be sent to you
- enter a survey
- give us some feedback.
Automated technologies or interactions
Third parties or publicly available sources
We may receive personal data about you from various third parties, including technical data from the following parties:
- analytics and advertising providers such as Google
- corporate credit reference agencies (for example if your business applies for a credit account with us)
How 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
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:
|To manage our relationship with you which will include:
|To enable you to complete a survey||
|To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
To date, we have not conducted any third party marketing. If we consider doing so, we will get your express opt-in consent before we share your personal data with any company outside In-Tuition for marketing purposes.
Opting out of marketing messages
You can ask us or third parties 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.
Change of purpose
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 reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to 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, some of whom are based outside of the UK.
- Service providers [acting as processors] based in the EU who provide IT and system administration services.
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services. Note that where information is passed to these advisers outside of the EU, 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 EU, 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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Further, detailed information about In-Tuition’s data security practises can be found on our Security and Infrastructure page.
In-Tuition’s policy is to select suppliers who are able to provide their service or hosting from the UK or the EEA.
In order to provide its services, In-Tuition owns and manages its own switches, routers, servers and other computer equipment which it hosts in two highly secure UK data centres in Manchester and London.
In-Tuition also makes use of the public cloud for hosting an increasing number of its services. These public cloud providers are selected based on strict criteria for sovereignty, security and privacy controls. Currently, In-Tuition make use of Amazon Web Services (UK and Ireland) and Interoute (UK).
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.
Exercising your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please do so using our administrator portal:
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
Your Customer account is managed online using our administrator portal. From this portal you can print, 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 everything 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 administrator portal 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.
As part of becoming a Customer you may have set-up a recurring payment with one of our payment processors such as GoCardless or Stripe. We don’t control your account with them and you may need to update or remove any personal data which was related to an account you are editing or deleting at In-Tuition.
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.
Object to processing of your personal data
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.
Request restriction of processing of your personal data
This enables you 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.
Request the transfer of your personal data to you or to a third party
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you make a Subject Access Request
Where you are not able to update, transport or delete your personal data using our administrator portal, you may submit a formal request to us using our normal contact methods. This is known as a Subject Access Request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.