Privacy Policy

Last updated: 1^st July 2024

This privacy notice tells you what to expect us to do with your personal information.

1. Contact details
2. What information we collect, use, and why
3. Lawful bases and data protection rights
4. Where we get personal information from
5. How long we keep information
6. Who we share information with
7. How to complain

1.  Contact details

Our email address: contact@learnfluid.com

2.  What information we collect, use, and why

We collect or use the following information for student education and welfare:

• Names and contact details for students/children
• Names and contact details for carers
• Gender
• Pronoun preferences
• Date of birth
• Payment details and financial information including transactions
• Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)
• Attendance and reason for absence data
• Account access information
• Exam results and qualifications
• Progress reports
• Information relating to compliments and complaints
• Exclusion, suspension and behavioural information

We also collect or use the following information for student education and welfare:

• Racial or ethnic origin

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Payment details
• Account login or user information
• Purchase or service history
• Call recordings
• Correspondence
• Special Educational Needs and Disabilities (SEND) or additional support information (includes reasonable adjustments and special educational needs and disabilities)
• Attendance and reason for absence data

We collect or use the following information for information updates or marketing purposes:

• Names and contact details
• Address
• Marketing preferences
• Alumni records

We also collect or use the following information for information updates or marketing purposes:

• Racial or ethnic origin

We collect or use the following information for archiving purposes:

• Names and contact details
• Addresses
• Alumni records

We collect or use the following information to comply with legal requirements:

• Identification documents

We also collect or use the following information to comply with legal requirements:

• Racial or ethnic origin

3.  Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure – You have the right to ask us to delete your personal information.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing – You have the right to object to the processing of your personal data.
• 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.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for student education and welfare are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • We use your information to optimize the tutoring needs for the student, e.g. to reassure the number of classes per month or the subjects the student takes with us are right for reaching the desired target of improvement in any subject.
• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
• We collect data on queries, complaints or claims to ensure that we can respond to these in the best interest of the customer.
• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • We collect data to further enhance our offering and can learn how we can enhance our customer satisfaction.
• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for archiving purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

4.  Where we get personal information from

• Directly from you
• Parents or carers

5.  How long we keep information

1. Customer Inquiry Data (Unconverted leads)
   1. Data: Name, email, phone number, WhatsApp number, subjects needed, grade level.
   1. Retention Period: 1 year from the date of last contact.
   1. Reason: Allows time for follow-up marketing while avoiding indefinite retention of data for unconverted leads.
2. Converted Customer Data (Active Students)
   1. Data: Name, email, phone number, WhatsApp number, student’s grades, grade level, contact details of parents, payment information.
   1. Retention Period: For the duration of the customer relationship + 3 years after termination.
   1. Reason: Necessary for ongoing service provision, record-keeping, and resolving disputes.
3. Tutor Assignment Data
   1. Data: Student and parent contact details, academic preferences, grade levels, subjects.
   1. Retention Period: For the duration of the tutoring relationship + 3 years after the tutoring ends.
   1. Reason: Necessary for continuity of tutoring services and to maintain records for reference.
4. Payment and Financial Data
   1. Data: Payment records, transaction history.
   1. Retention Period: 6 years after the transaction date.
   1. Reason: Compliance with UK tax laws (HMRC requires financial records to be kept for 6 years).
5. Marketing Data (Email lists, promotional materials)
   1. Data: Name, email, phone number, marketing preferences.
   1. Retention Period: Until consent is withdrawn or for up to 2 years after the last interaction.
   1. Reason: Compliance with GDPR regarding consent and the right to be forgotten.
6. Cookies and Tracking Data
   1. Data: Browsing data, analytics.
   1. Retention Period: Up to 2 years.
   1. Reason: Typical industry standard for analytics and improving user experience.
7. Employment and Internship Applications (Unsuccessful Candidates)
   1. Data: CVs, application forms, interview notes.
   1. Retention Period: 6 months after the recruitment process ends.
   1. Reason: To comply with employment law regarding equal opportunities and to maintain records for possible re-engagement.
8. Successful Internship or Employment Data
   1. Data: Contractual details, performance records, payroll information.
   1. Retention Period: Duration of employment + 6 years after the contract ends.
   1. Reason: Compliance with employment law for potential claims or disputes.
9. GDPR-related Requests (Access, Rectification, Erasure, etc.)
   1. Data: Records of requests and resolutions.
   1. Retention Period: 3 years after request resolution.
   1. Reason: To maintain records of compliance with GDPR obligations.

Data Disposal and Anonymization

• After the specified retention period, data will be securely deleted or anonymized. Financial data and records may be retained in anonymized form for research, statistical, or analytical purposes.

6.  Who we share information with

Data processors

UK based accounting firm to handle monthly billing

This data processor does the following activities for us: They manage debt, create invoices, and keep track of payments made for lessons conducted.

Others we share personal information with

• Parents and carers
• Legal bodies or authorities
• Organisations we’re legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media
• Debt collection agencies

7.  How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0044 (0) 303 123 1113

Website: https://www.ico.org.uk/make-a-complaint