You may have heard about some new data protection legislation heading our way on the 25th May 2018, in fact, you may well have heard more than enough about it already. Well, so as not to feel left out, we at Tutorially™ would like to let you know where we are with the General Data Protection Regulations, or GDPR.
We provide primarily paid business to business (B2B) services, hence the majority of our customers are companies. Many of our clients are therefore not Data Subjects as they are companies/corporations, but we acknowledge that the data we hold, and as inputted by them, could be used identify a Natural Person. When a company (or, indeed, anybody else) signs up for our services whether paid or otherwise they are required to agree to our terms and conditions, and in so doing they will be explicitly consenting to our using the data they provide for the purpose of delivering a service.
The same applies to anybody contacting us by telephone or email. We will use any data that a company or individual may provide for the purpose of servicing their enquiry, and potentially assisting in their subscription to our service should they so instruct us. We will share data with our 3rd party suppliers as Data Processors in line with our terms and conditions. We reserve the right to send marketing material to potential customers, whilst providing them with the opportunity to ‘opt-out’ of receiving subsequent communications at any time.
When a Tutorially™ customer enters into a monthly paid subscription, they will provide their payment information to Stripe, who will store it for the purpose of collecting recurring payment. That payment information is never shared with or held by Tutorially™. Stripe are fully PCI compliant.
If a customer of Tutorially™ invokes their Right to be Forgotten, we have the capability to delete any and all data pertaining to that individual or company. We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as fraud. We may retain information as required or permitted by applicable laws and regulations, including to honour your choices, or for our billing or records purposes.
Tutorially™ subscribers provide services to their own customers, and in this circumstance, Tutorially becomes a Data Processor while the subscriber managing a Tutorially™ account becomes a Data Controller – specifically of the data they input themselves in relation to their tutors, students, lessons and so forth. Our technology partners are also Data Processors.
If a student or staff tutor wishes to invoke their Right to be Forgotten, the Tutorially™ subscriber will be able to use functionality provided by the Data Processor to delete all data as required. The responsibility and decision to enforce this right lies solely with the Tutorially™ subscriber or Tuition Company.
This article does not constitute legal advice – if you are at all concerned by GDPR you should seek professional advice, this is merely the Tutorially™ trademark no-nonsense interpretation. We have always been completely transparent in our dealings and have not used any user data for any means other than delivering the service to which they subscribed, and communications related directly to it.
We are Tutorially™. We use the data provided by our customers for the purposes of providing the service(s) to which they have subscribed. We also communicate with registered users, newsletter subscribers and any other party who has consented to our contacting them, notifying them of offers, changes and news related to our products and services, including Tutorially™. We do not require that subscribers provide any sensitive data, and although we share data with third parties for purposes related to Tutorially™ only, we do not share it with any organisation that does not live up to our information security values. Any information a subscriber may choose to make public, or that they share via social media, is, of course, their own individual decision.
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