TUTORIALLY™ PRIVACY POLICY

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by Ortera® trading as Tutorially™. It applies to information we collect about:

• Visitors to our websites;
• Users of our applications and services;
• Individuals in relation to data protection or freedom of information enquiries; and
• People who use our services; i.e. subscribers to software services, or those who subscribe to our newsletters.

Contacting Us

If you have general questions about your account please contact our support team at http://www.tutorially.co.uk/contactus. For questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact us by email at [email protected]. You can also write to us at:

Information Governance department
Ortera® Limited
27 Old Gloucester Street
London
WC1N 3AX

The data controller of your personal information is Ortera® Limited which also provides the service to you. Please note that if you contact us to assist you, for your safety and ours we may need to record calls between us and authenticate your identity before fulfilling your request.

Collection of Information

We receive and store information about you such as:

Information you provide to us: We collect information you provide to us which includes:

• your name, email address, address or postal code, payment method and telephone number. We collect this information in a number of ways, including when you enter it while using our services, interact with our Customer Support Team, or participate in surveys or marketing promotions;
• winformation when you choose to provide reviews or ratings, account settings, set preferences in “Your Account”, or otherwise provide information to us through our service or elsewhere.

Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service (such as mobile devices, hardware such as VoIP Phones or desktop applications). This information includes:

• your activity on the Tutorially™ service, such as call history data, device and/or application authentication
• details of your interactions with our Customer Support team, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
• device IDs or other unique identifiers; device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, IP address (which may tell us your general location), browser and standard web server log information;
• information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on the availability and delivery of ads, the site URL, as well as the date and time).

Information from other sources: We might supplement the information described above with information we obtain from other sources, including from both online and offline data providers. Such supplemental information could include demographic data, interest based data, and Internet browsing behaviour.

Visitors to our websites

When someone visits Tutoriall™ we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons) for various reasons. For example, we use cookies and other technologies to make it easy to access our services by remembering you when you return, to provide and analyse our services, to learn more about our users and their likely interests, and to deliver and tailor marketing or advertising. We want you to be informed about our use of these technologies, so this notice explains the types of technologies we use, what they do and your choices regarding their use.

1. What are cookies?
   
   Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.
   Cookies are not the only types of technology that enable this functionality; we also use other, similar types of technologies. See below for more information and examples.
   Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
   To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
   
2. Why does Tutorially™™ use cookies?
   
   We and our Service Providers may use the following types of cookies:
   
   • Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we or our Service Providers may use these cookies to authenticate and identify our members when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms & Conditions, prevent fraud and maintain the security of our service.
   • Performance and functionality cookies: These cookies are not essential but help us to personalize and enhance your experience with Tutorially™. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors' use of the Tutorially™ service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies will result in limited functionality of our service.
   • Advertising cookies: These cookies may use information about your visit to this and other websites, such as the pages you visit, your use of our service or your response to ads and emails, to deliver ads that are more relevant to you. These types of ads are called "Interest-Based Advertising." Many of the advertising cookies associated with our service belong to our Service Providers.
3. How Does Tutorially™ use Web Beacons and other Technologies?
   
   Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. We and our Service Providers may use them for similar purposes as cookies, such as to understand and enhance the use of our service, improve site performance, monitor visitor traffic and actions on our site, and understand interactions with our marketing (including email and online ads on third party sites). Because web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness of web beacons.
   We use other technologies that are similar to cookies, such as browser storage and plugins. Like cookies, some of these technologies may store small amounts of data on your device. We may use these and various other technologies for similar purposes as cookies, such as to enforce our terms, prevent fraud, and analyse the use of our service. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more.

Use of Information

We use information to provide, analyse, administer, enhance and personalise our services and marketing efforts, to process your account creation, your orders and your payments, and to communicate with you on these and other topics. For example, we may use information to:

• determine your general geographic location, provide localised content, provide you with customised and personalised recommendations for movies, determine your Internet service provider, and help us quickly and efficiently respond to inquiries and requests;
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility);
• analyse and understand our customers, improve our service (including our user interface experiences) and optimise our product and its standard of quality;
• communicate with you concerning our service (for example by email, push notifications text messaging, and online messaging channels), so that we can send you news about Tutorially™, details about new features and content available on Tutorially™, and special offers, promotional announcements and consumer surveys, and to assist you with operational requests such as password reset requests. You can change your communications preferences in “Your Account”.

E-Newsletter

We use a third-party provider, Jack Enterprises, to deliver our newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.

Wordpress

We use a standard WordPress service to collect anonymous information about users' activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see Automattic's privacy notice.

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

• Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalise and optimise our service, to provide customer support, to analyse and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorise them to use or disclose your personal information except in connection with providing their services.
• Promotional offers: We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
• Protection of Tutorially™ and others: Tutorially™ and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Ortera® Limited (Trading as Tutorially™), its employees, users or the public, as required or permitted by law.
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection.

You may also choose to disclose your information in the following ways:

• While using the Tutorially™ service you will have opportunities to post reviews or other information publicly, and third parties could use the information you disclose;
• Certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device;
• Social plugins (including those offered by Facebook, Twitter, Pinterest, and Google) allow you to share information on those platforms.
• Social plugins and social applications are operated by the social network themselves, and are subject to their terms of use and privacy policies.

Access to Your Account and Profiles

• In order to provide you with ease of access to your account and to help administer the Tutorially™ service, we may use technology that enables us to recognize you as the account holder and provide you with direct access to your account without requiring you to retype any password or other user identification when you revisit the Tutorially™ service.
• Where possible, users of public or shared devices should log out at the completion of each visit. If you sell or return a computer or Tutorially™ ready device, you should log out and deactivate the device before doing so. If you do not maintain the security of your password or device, or fail to log out or deactivate your device, subsequent users may be able to access your account, including your personal information.
• If you share or otherwise allow others to have access to your account, they will be able to see your information (including in some cases personal information) such as your lessons and student history, ratings, reviews and account information (including your email address or other information in Your Account).

Your Choices

• If you no longer want to receive certain communications from us via email simply use the options in said emails to unsubscribe. Please note that you cannot unsubscribe from certain email correspondence from us, such as messages relating to your account transactions.
• To exercise choices regarding cookies set through our website, as well as other types of online tracking and Internet advertising, see the Use of Cookies section.

Children & their Parents

You must be 18 years of age or older to subscribe to Tutorially™. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age in order to use our service. While individuals under the age of 18 may use the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

A parent may register with Tutorially™ and subsequently enrol his or her child(ren) for the purpose of booking lessons and participating in the service. In so doing, the parent assumes responsibility for any data provided, as well as retaining all responsibility with regard to the conduct of the child(ren) within the service as the primary registered user.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information.

Other Websites, Platforms and Applications

The Tutorially™ service may be provided through and/or utilize features (such as VoIP Hardware and Software) operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access the Tutorially™ service through mobile devices, hardware such as VoIP Phones, desktop applications and a number of other Internet connected devices. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully. In addition, you may encounter third party applications that interact with the Tutorially™ service.

Data Processing

We do not sell, trade, or rent user or subscriber personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers. We may use third party service providers to help us operate our business or administer activities on our behalf. We may share your information with these third parties as part of our business operations.

We treat your end user data with the greatest respect and will never share it with another user of Tutorially™, with the exception of any data you may make publically available for the purposes of conducting your business. Individuals, be they tutors or students, can create Tutorially™™ accounts which they then use within the service as they see fit, therefore, these users may receive communications from different companies and individuals that are also using Tutorially™ A company or individual with a Tutorially™ account will only have access to the data within their own profile and lesson schedule, as well as contact information for any person with whom they may be connected, and any information that any user of Tutorially™ may have specified be publically available for the purposes of using the service.

Data Storage

Our Software services are Cloud Hosted within the EU, with Amazon Web Services (AWS) providing our underlying infrastructure. All our data is encrypted at rest, and traffic from an Internet browser is always HTTPS, providing encryption in transit. We take data security extremely seriously, and all Ortera® staff are UK based. Access to systems holding sensitive data is undertaken via systems that are kept up to date in terms of security patches and anti-virus software. Unless requested to remove customer data, we will retain it for up to five years.

Passwords

We do not know the passwords of users registering with our services, only providing a means to reset via a registered email address. It is the responsibility of the users of our services to set appropriately secure passwords, and to keep them secure. Ortera® will not be considered liable for any unauthorised access to a user application account by means of an insecure password.

Payment Processing

We use several third-party providers, including Swipe and PayPal, to manage payments. Ortera® and Tutorially™ do not gather, process or retain any data in relation to user payments, we simply facilitate the connection between the user and the payment company. You can read Stripe’s terms here, and PayPal’s here.

Social media

We use a third-party provider, Jack Enterprises to manage our social media interactions.

If you send us a private or direct message via social media the message will be stored by Jack Enterprises for three months. It will not be shared with any other organisations. Any comments on social media posts, or those resulting from shares of our posts, are the responsibility of the users making those interactions. Should you provide a review of our service, published anywhere on the Internet, you grant us permission to reuse it in full, or in part, at our discretion.

People who call us

When you call Ortera® or Tutorially™ we collect Calling Line Identification (CLI) information. We use this information to help improve efficiency and effectiveness.

People who email us

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government standards. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

People who use our Messaging service

If you use the Messaging service we will store the content of your messages as well as your user details. This information will be retained for two years and will not be shared with any other organisations.
You can request a transcript of your LiveChat sessions, though they remain available with the system you used to facilitate the messaging session.

People who make a complaint to us

Should we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the need to know principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

People who use our services

Ortera® offers various services to the public, of which Tutorially™ is one. We use a third party to deal with some publication requests, but they are only allowed to use the information to send out the publications.

We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

Reporting a breach

Public electronic communications service providers are required by law to report any security breaches involving personal data to the ICO. Ortera® are registered with the ICO, and comply with all relevant obligations.

If you suspect your data has been compromised, please change your password immediately and contact us as soon as possible. We will ensure your data is secure and investigate any matters brought to our attention. We will keep you informed throughout.

Your Information and Rights

• You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you.
• You can most easily do this by visiting the “Your Account” portion of our website, where you have the ability to access and update a broad range of information about your account, including your contact information, your professional details, and various related information about your account (such as lessons, students and payments). You must be signed in to access “Your Account”. You may also request that we delete personal information that we hold about you.
• To make requests, or if you have any other question regarding our privacy practices, please contact us at [email protected]
• 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 free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honour your choices, for our billing or records purposes and to fulfil the purposes described in this Privacy Statement.
• If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone or email.
• If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Information Governance department.

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Tutorially™ service after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this Privacy Statement, you may cancel your use of the Tutorially™ service.