Privacy Notice

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The Privacy Notice below describes how your data is collected and used.

**Note added on 23rd January 2019: The Privacy Notice below relates to Private Tuition only. The Privacy Notice for Art Sessions varies slightly and can be found by clicking here.**

Over time the Privacy Notice has been updated. I only update the Privacy Notice when I feel that wording could be improved to make things more transparent or where a new service is introduced on the website (or where the law changes).

I will never change the Privacy Policy retrospectively to retain more data. Please check this page regularly, as changes may be made over time.

Who I am (The Data Controller)

Adam Wardle,

43 Miller Drive,

Fareham,

Hampshire PO16 7LY

Who I hold information on

I hold personal data on:

  • People who contact me
  • Customers
  • People who visit my website
  • People who use contact me via my social media pages (Facebook. Twitter, etc.)
  • People who communicate with me through Skype (or other chat service)
  • People/Companies I use for business services (e.g. advertising)

How I receive your information

Information I have about you comes from you getting in contact with me somehow. Normally this is by you emailing me with an enquiry or booking tuition, but it could be by you phoning me or booking tuition through a third party website.

You could alternatively provide me information through the live chat service, one of my social media pages (Facebook, Twitter, etc.), your use of Skype (or other chat service) or your use of this website.

What kind of information I may hold about you

For the majority of customers the only personal information I hold is name, address, email address, telephone number and the subject being taught.

Please note that depending on how you pay me your details can appear on my bank statements against your payments (e.g. if you pay by bank transfer your name/account details may appear on my statements).

I may hold additional information from your use of the website (or where you contact me or leave information on one of my external Social Media pages). Please see:

  • ‘Cookies/Website’
  • ‘Information relating to the (new) Live Chat service’;
  • ‘Information relating to social media sites’; and
  • ‘Information relating to Skype (and other chat services)’

all of which are below.

Why I collect this information

The personal data is necessary for me to:

  • deal with customer enquiries (e.g. someone emails about tuition, so I email back with a quote);
  • provide my services to you under the terms of our contract (e.g. book appointments etc.);
  • comply with my legal obligations, for example tax (e.g. I write down your name and address on my accounts against a payment you make me, as the tax authorities require me to record who I receive any payments from); and
  • deal with enquiries in relation to payments

Where you wish for a written quotation, I cannot do so without your basic contact details (e.g. an email).

Without your name and address I cannot provide you with tuition.

The legal basis for processing your information

I need to process information for the following reasons:

  • The performance of the contract with you or for me to take steps for me to enter into a contract
    • This covers situations such as where someone makes an enquiry with a view to booking tuition, I may use their email address to email back with a tuition offer.
    • With the live chat option, you may provide details on there, such as an email, asking me to reply to you with a quote, which hopefully will lead to a contract between us.
    • This also covers situations such as where someone with an existing contract emails me about tuition and I email back.
    • This also covers things such as me booking appointments.
  • The perfomance is in compliance with a legal obligation, such as providing information to a tax or other authority
    • This covers situations, such as where I record personal details on my accounting records to show where payments have come from. Like any other business I am required by law to keep full detailed accounts. This includes providing details on who I receive payments from as well as details of any refunds I make.
    • HMRC requires me to retain details relating to payments received and refunds made to prove the authenticity of my accounts (for example correspondence in relation to refunds I make).
    • I also may need to provide copies of my bank statements to HMRC, which show payments in from you (and payments made to you, for example, in the event of a refund).
    • Although it is unlikely, I may possibly need to provide evidence to HMRC of cancellations, contract terms or other correspondence between us if required by them. In this event this may involve showing emails from customers to HMRC.
    • Regarding Coronavirus impact: Please note that HMRC has just announced that businesses making any claims relating to Coronavirus impact are required to retain evidence of Coronavirus impact. This does not make any difference to data being retained, but it means that HMRC may (possibly) ask for and require sight of customer correspondence, such as customer emails cancelling tuition because of the Coronavirus situation.
  • The performance is in relation to a legitimate interest:
    • I keep customer reviews (typically emails) so that their authenticity can be verified.
    • I store correspondence relating to contracts (e.g. cancellation emails) in case of a later query or complaint.
    • I keep live chat records and messages received via the service in case of a later query or complaint relating to what was said.
    • I may need to show an accountant doing services on my behalf accounts records, correspondence supporting any financial claim, etc.

I do not do mailing lists, etc.

I do not do mass marketing emails, etc.

Information relating to the (new) Live Chat service

Key points about the Live Chat service:

  • Please be aware that I may see anything you type into the chat even before you press ‘enter’.
  • I am the only one who responds to queries on the live chat service.
  • All communication on the chat is over a 128bit Secure Socket Layer and all data is housed on encrypted servers.
  • When you make contact with me by way of potentially personal information, the service by default tells me your approximate location (i.e. approximate city/town) and browser type, but I will not use this to try to identify you as an individual.
  • I have disabled your IP address being shown on the chat.
  • You do not need to provide your contact details before starting a chat or during a conversation.
  • I will only ask you for an email, for example, if you wish me to send you an offer or wish me to contact you by email.
  • If I am offline/not available, I only ask for your email, so that I can provide you with a reply to your enquiry.
  • Tawk.to keeps a record of communications for me using a google cloud host, but I will remove them from the storage at the latest every 90 days.
  • Tawk.to complies with Google’s terms and model contract clauses that cover compliance with UK and EU data protection law.
  • Tawk.to’s Privacy Notice is on https://www.tawk.to/privacy-policy/
  • Please note that I am emailed a copy of conversations and messages at the end of every conversation/upon a message being sent. These email records will be held with me:
    • for up to one year (where you do not book tuition at all); or
    • for up to six years and ten months (where you do book tuition, albeit at a later date)
      • These periods may be extended where required by law (e.g. a court order).

Information relating to social media sites

With the exception of private messages you send me through a social media account, my social media accounts are by their very nature public. Consequently when you submit any information, ‘like’ a page/article/comment or leave a comment, etc. on any of my social media accounts, by its very nature you are making that information/action you take public. Usually such information stays on my public social media pages indefinitely (e.g. liking a page, leaving a review, commenting on a post I make, etc.).

As the social media services are public anyone can look at them, so any information or action you make public will be available for anyone to see. I cannot control how other people use that information. In short, if you are not happy for anything you do on the social media accounts to be made public, please do not do it in the first place.

Retention periods in relation to social media accounts

  • The individual social media services will have their own Privacy Policies which you should be aware of. I have no control over their Privacy Notices and their retention of data.
  • As regards notification emails, these fall into two groups:
    • Email notifications I receive giving details of customer reviews I may keep indefinitely. This is under the legal ground of legitimate interest, as I may need to prove the authenticity of reviews in the future.
    • Other social media notification emails will be deleted by me within a maximum of one year (with the exception of where I am required to retain them by law (e.g. court order), in which case they will only be kept for so long as the law requires me to do so).
  • As regards private messages received through a social media account:
    • These will be deleted within a maximum of one year with two exceptions:
      • 1. Where you book tuition within a year (or already have a contract with me), the message (and/or a copy of the message) may be kept by me for a maximum of six years and ten months. This is done under the ground of legitimate interest, as I may need to deal with queries or questions relating to what was said/agreed or to deal with a possible complaint.
      • 2. Where I am required to retain the private message for longer by law (e.g. court order).

Information relating to Skype (and other chat services)

Skype and any alternative chat services (if ever used) have their own Privacy Policy which you should consult. Their retention of data is subject to their individual Privacy Policies over which I have no control.

The only data I technically have control over on Skype is your username, which may or may not be personal data depending on the circumstances. Using your username is necessary for us to be able to chat to one another. This is likely to be the same for other chat services (if ever used).

Any information exchanged during Skype sessions is likely to be general in nature and related to, say, the language being learned, rather than personal data.

I will delete you from my contacts (and consequently any conversations my end if not done automatically) within a year of you completely finishing sessions. I keep these conversations for that one year on the grounds of legitimate interest. This is to enable me to deal with the unlikely event of a complaint.

Tax Deductible Expenses

This is unlikely to be of relevance to customers, but is included here for completeness. I am required by law to keep evidence of tax deductible expenses. I retain such documents for up to six years and ten months (unless required by law to retain them for longer e.g. court order, in which case I would not keep them longer than required by law).

How long I will retain your information

For details on the retention of i) live chat data ii) my social media accounts and iii) Skype (and other chat services) and iv) evidence of tax deductible expenses (unlikely to affect customers) please see the relevant sections above, but this section sets out the retention limits of all other data.

Where you do not book tuition at all, data (e.g. emails, etc.) in relation to your enquiry may be kept for up to one year from the date when you last contact me.

Where you do book tuition, albeit at a later date, (or where you have paid for my details through a third party website), data (e.g. email enquiries, email correspondence, accounts records, etc.) may be kept for a maximum of six years and ten months with the exception of:

  • Correspondence with people continuing tuition on an ongoing basis.
    • Where someone is receiving tuition on an ongoing basis, documentation (e.g. emails) relating to the terms of the ongoing contract may be kept. (It would be very unusual for someone to be receiving tuition under the same contract for such a length of time). All other documentation will be deleted.
  • Customer reviews
    • As regards customer reviews, I keep these indefinitely to prove the authenticity of these in the future.
  • Where required by law
    • This would cover the situation where I am required to keep documentation because of, for example, a court order.

Cookies/Website

My site does not use any unnecessary cookies, so the Cookies section is short.

Up to and including most of 1st June 2020 visitors to the site were asked their Cookie Preferences. A log of this with IP address was being kept to comply with the law. This will be kept for as long as the law requires. (At that time you would have been given the choice whether to accept or decline cookies by a banner when you first used the site). I have no interest in your preferences, so do not look at the log to try to identify individuals, etc.

Links to external Sites

If you click on links to certain services or external sites, you will be using their services and be subject to their Privacy Policies. These are the live chat, links to Facebook, Twitter, etc.

Analytics

On my website I use analytics which tells me whether you are a new or existing visitor to the website, your IP address, where in the world you are visiting from, how long you spend on the website, your browser and operating system as well as how you reached the website. This information is used to make sure that my website is attracting the right visitors (e.g. I want to see that all my visitors come from the UK and found my site by searching for terms that are relevant to my services), but I have no interest whatsoever in trying to identify any particular website user. I only want to make sure that my website visitors as a whole are the ones I want visiting my site.

Please note that I use a program on my website which allows me to block IP addresses of people who try to access unauthorised parts of my website. This is done to prevent unauthorised access to my website and to maintain the integrity of the site. I will not use the data to try to find out the identity of any particular user. Where attempts to do malicious activity is detected by the program, the IP address may be reported to an external database to prevent future unauthorised activities on this and other websites. I just want to stop people with malicious intentions from being prevented access to parts of this and other websites when they are not allowed to. If you are a legitimate user of the site, this should not affect you at all.

Security measures in place

– SSL

– Encryption

– On 5th October 2018 my website was changed from http to https

– Offline storage

Links to other sites/Booking tuition through other sites

Essentially:

  • Where my website has links to other websites, those sites are not covered by this Privacy Notice.
  • Where you book tuition through a third party site (e.g. Firsttutors) this Privacy Notice does not govern their retention of data provided by you on their site. (I cannot control what data an independent third party holds and how long they hold it for). In this scenario this Privacy Notice only governs data held by me (i.e. in my control).

Future changes to this privacy notice

It is possible that I will need to update this privacy notice in the future. In that event, I will update the Privacy Notice on this website. (Please be reassured that I will not increase time limits for retention of data retrospectively). Please look regularly for updates here, so that you are up to date on what information is collected and how it is used.

Your rights

You have the right to:

  • request your personal data;
  • object to processing of personal data that is likely to cause, or is causing, damage or distress;
  • have inaccurate personal data rectified;
  • request your information to be deleted or destroyed (Please note normally if I can I will, but I must keep certain records for legal reasons); and
  • claim compensation for damages caused by a breach of the Data Protection Regulations

If you are not happy with how your personal information is used, I would ask that you contact me on adam@farehamtutor.co.uk, but you have the right to complain to the Information Commissioner’s Office at www.ico.org.co.uk.

Contacting me

If you wish to contact me with any questions, feel free to contact me on adam@farehamtutor.co.uk.

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