Privacy Policy

Introduction

Welcome to Twelve Oaks Tuition's privacy notice.

Twelve Oaks respects your privacy and is committed to protecting your personal data as users of our website and otherwise as our parent and child users, tutors and business contacts. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit those from) or otherwise engage with us and it tell you about your privacy rights and how the law protects you.

Please use the Glossary at the end of this policy document to understand the meaning of some of the terms used in this privacy notice.

1.                      Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Twelve Oaks collects and processes your personal data through your use of this website or when you engage with our services to:

-         Seek courses and tutors

-         To be a tutor

-         To provide and supply services and products to us

We only collect personal data about children (under 18 years old) where their parent or lawful guardian has signed them up with us to be provided with a tutor. The parent or lawful guardian remains our contractual client and they give consent for their children’s data to be processed through our website.

It is important that you read this privacy notice together with any other privacy notice or policy or fair processing policy 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 supplements other current or future notices and privacy policies and is not intended to override them, except when stated otherwise.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

·                   Used lawfully, fairly and in a transparent way.

·                   Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

·                   Relevant to the purposes we have told you about and limited only to those purposes.

·                   Accurate and kept up to date.

·                   Kept only as long as necessary for the purposes we have told you about.

·                   Kept securely.

Controller

Twelve Oaks Tuition is the controller and responsible for your personal data (referred to as "Twelve Oaks” "we", "us" or "our" in this privacy notice). Twelve Oaks Tuition is a trading name of 12 OT LLP. Our company number is OC458313 and we have our registered office at The Four Columns, Broughton, Skipton, BD23 3AE.

We have appointed a data privacy manager who 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 set out below, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:

Trading name of controller: Twelve Oaks Tuition

Name of data privacy manager: Catherine Robinson

Email: info@twelveoakstuition.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. You can find our contact form here: https://www.twelveoakstuition.co.uk/contact and changes to the law will soon require that you must raise your complaint with us before taking your complaint to the ICO.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. Historic versions can be obtained by contacting us.

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.

Third-party links

Our website may include links to third-party website or mobile apps, 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 website or mobile apps and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or mobile app you visit.

2.                      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:

·                   Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

·                   Contact Data includes billing address, delivery address, email address and telephone numbers.

·                   Financial Data includes bank account and payment card details where relevant to individuals engaging with us.

·                   Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or from tutors on our website, to the extent that might be relevant to any individual engaging with us.

·                   Technical Data 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 website.

·                   Profile Data includes your photograph (if used by you), username and password, purchases or orders or job applications made by you, your interests, preferences, feedback and survey responses and any social media tags or personal data you share with us via social media or otherwise.

·                   Usage Data includes information about how you use our website, products and services.

·                   Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

·                   Lesson data includes the recording of both audio and video of the lesson, lesson plans and lesson notes.

·                   Tutor Recruitment Data includes, but only where you are a tutor using or who has used our services for work finding purposes, data in connection with your registration on our systems and which may include the following categories of personal information about you:

o   The information you have provided to us in your registration with us and in any documents you attach with your registration or otherwise send to us, such as your curriculum vitae and any covering letters or in any job application form including name, title, address, telephone number, personal email address, date of birth, gender, employment history and current roles, skills, languages spoken, qualifications and approvals and certifications with regulatory bodies, and salary/role/opportunity expectations and current remuneration details.

o   Any information ex-employers or other non-relatives might provide to us such as references and confirmation of job history data or biography or image data on their website.

o   Information about your race or ethnicity and right to work in the UK or any other applicable jurisdiction, religious beliefs, sexual orientation and political opinions, where it is appropriate for us to process such data.

o   Information about your health, including any medical condition, health and sickness records, where it is appropriate for us to process such data.

o   Information about criminal convictions and offences, where it is appropriate for us to process such data.

o   Information (including any opinions about you and your suitability for a role) provided to us by parents or students you are applying to or which we/you are in communications with about a role or potential role (i.e. tutoring opportunity).

o   Information provided by contacts of yours who referred us to you and any opinions provided by such persons or opinions of other referees for you.  

o   Information made available by authorities about you where that is relevant for us to process, such as information provided by any relevant local authority or HM Revenue & Customs (or similar authorities or regulators in other jurisdictions).

o   Information about your interactions with and payments from Clients, where it is appropriate for us to process such data.

·                   Student Data includes all data provided by parents/students to Twelve Oaks including names, email addresses, phone numbers, subjects, achievement level, target grades, learning conditions, and disabilities.

We also collect, use and share aggregated data of our users such as statistical or demographic data for any purpose. Such aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Except in appropriate circumstances in respect of Tutor Recruitment Data or Student Data 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). Except in appropriate circumstances in respect of Tutor Recruitment Data, we do not collect any information about criminal convictions and offences.

Where we process Special Categories of Personal Data and criminal records data of tutors or students for reasons related to the field of employment (ie to provide the requested recruitment service for employment purposes in accordance with the Employment Agencies Act 1973 and related legislation), we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. This is the main reason and lawful basis used for processing Special Categories of Personal Data of tutors and students along with consent if that is needed.

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 tutors with effective recruitment services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3.                      How is your personal data collected?

We use different methods to collect data from and about you including through:

·                   Direct interactions. You may give us your Student Data, Identity, Contact, Financial, Marketing and Communications and Tutor Recruitment Data by registering with us, filling in forms or by corresponding with us by LinkedIn post, phone, email or otherwise or directing us to your website or mobile app or social media accounts. This includes personal data you provide when you:

·                    Register for and use our services;

·                    subscribe to our publications;

·                    request marketing to be sent to you;

·                    enter a competition, promotion or survey; or

·                    give us feedback or contact us.

·                   Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

·                   Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

o  Tutor Recruitment Data from our parent clients who you engage with and also your current and ex-employers, as well as potentially authorities and regulators in the countries in which you operate

o   Technical Data from analytics providers

o   Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

o   Identity and Contact Data from data brokers or aggregators such as the Department for Education.

o   Identity and Contact Data from publicly available sources such as Companies House

4.                      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 (including students where parents enter the contract on their behalf).

·                   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 obligation.

Please see the explanation of "Lawful Basis” in the Glossary at the bottom of this privacy notice to find out more about the types of lawful basis that we will rely on to process your personal data.

We do not generally rely on consent as a legal basis for processing your personal data (save for processing special category data where required and we have no other Article 9 UK GDPR lawful basis to rely on) although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan 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. Please note that where parents or guardians sign up children under their care to be a student, generally we will need to process the child’s data for the performance of a contract with the parent/the child or where we have a legitimate interest to do so, and so the below table applies to data about child students also.

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.

 Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile and Tutor Recruitment Data and Student 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 or job opportunities 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 goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, we will still hold and process personal data about you in accordance with this privacy notice.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when website or mobile apps set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy below.

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.

Automated Decision Making

We have an matching service which uses the information provided by a tutor user to match them to potential engagements requested by parent/student users to offer options for the parent/student to consider proceeding with. We do not consider that this produces any significant effect for either of those users, however, if either user has any concerns or questions they may contact our DPM at the contact details above for further information or to challenge any suggestions made by our matching service.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

·                   Internal Third Parties as set out in the Glossary.

·                   External Third Parties as set out in the Glossary. We do not sell your data to any such third parties. Any transfers are necessary and/or lawful for the purposes set out in this privacy notice.

·                   Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

5.                       Integration of Google Services

5.1                  Google Login Data:

When you choose to log in using your Google account, we collect certain information provided by Google. This may include your name, email address, and profile picture. This data is used solely for the purposes of authentication and to personalise your experience on our platform. By using Google Login, you acknowledge and agree that some of your information will be shared with Google. For more information on how Google handles your data, please refer to Google’s Privacy Policy: https://policies.google.com/privacy

5.2                Google Calendar Data:

Twelve Oaks Tuition offers calendar integration to help users track scheduled lessons and sessions. When you connect your Google Calendar, we request access to sensitive scopes in order to create and manage calendar events on your behalf. This allows us to automatically sync confirmed lessons and send reminders for upcoming sessions.

We do not access or alter existing events in your calendar unless they were created through our platform. Any events created via our system will include relevant lesson details and links for online access.

We do not use your calendar data for any purposes beyond session tracking and scheduling, and we do not share calendar data with any third parties.

5.3                Data Sharing and Third-Party Involvement: 

By utilising our Google integration features, you understand that some of your data will be processed by both our service and Google. We do not sell or share your data with any third parties, except where required to comply with applicable laws or where explicitly stated. Any sharing of your data with Google is subject to their policies as detailed in Google’s Privacy Policy: https://policies.google.com/privacy

5.4                User Consent and Control: 

Before accessing your Google account or calendar data, you will be prompted to provide explicit consent by granting the necessary permissions. You retain full control over your data:

5.5                Revoking Access:

You may disconnect your Google account from our service at any time, either via our platform’s settings or directly through your Google account settings.

5.6                Data Deletion:

If you decide to terminate your account, you may request the deletion of your personal data in accordance with our data retention policies.

5.7                Data Security and Retention:

We implement industry-standard security measures to safeguard the data accessed through Google integrations. Your information is stored securely and is retained only for as long as necessary to fulfil the purposes described in this policy or as required by law.

6.                      International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

·                   We may transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data by the UK government. For the avoidance of doubt, the UK and EU have agreed reciprocal arrangements about such matters.

·                   We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us via the details provided in the contact details above. Contact details can also be found here: https://www.twelveoakstuition.co.uk/contact

·                   We may transfer personal data to our service providers located outside the UK, including to India, where our platform developer (FATbit Technologies) is based. These transfers are necessary to provide technical support and ensure the proper functioning of our platform. We have entered into the UK International Data Transfer Agreement (IDTA) with FATbit Technologies to ensure that your data is protected to UK GDPR standards.

·                   Any other relevant safeguards and derogations that may be available from time to time for specific international data transfers.

Please contact us if you have any questions about international transfers.

7.                      Data security

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 or their mandatory legal requirements 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.

8.                      Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, and often that is for 6 years given limitation periods on legal and tax matters. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data will be made available on request.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.                      Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below under "Your Legal Rights” to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact our data privacy manager.

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 could 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 could 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.

10.                  Glossary

LAWFUL BASIS

Consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her, or in the case of our parent clients, their children.

Legitimate Interest 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Any other companies in our corporate group from time to time. At present there are no such other companies.

External Third Parties

·                   These might include others users to provide our matching service, our third party processors, such as our service providers, advisors, HR and Applicant Tracking technology providers and on LinkedIn (as a user of LinkedIn they will already be aware of its privacy notice) and our e-mail and IT provider from time to time and minimal identification data may be shared on any third party accounting system we use from time to time.

·                   Web hosting service providers and third party facility providers embedded on our website.

·                   Professional advisers acting as processors or joint or independent controllers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance, marketing, and accounting and other professional services.

·                   HM Revenue & Customs, regulators and other authorities acting as independent controllers who require reporting of processing activities in certain circumstances, or similar in EEA countries as applicable.

YOUR LEGAL RIGHTS

You have the right to:

·                   Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

·                   Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·                   Request erasure of your personal data.This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·                   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:

o       If you want us to establish the data's accuracy.

o       Where our use of the data is unlawful but you do not want us to erase it.

o       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.

o       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.

11.                  Cookie Policy

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

·                   Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website will not work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.  

·                   Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

·                   Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

·                   Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on those more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):

·                   Strictly necessary cookies    ALWAYS ACTIVE

·                   Analytical or performance cookies    OFF

·                   Functionality cookies    OFF

·                   Targeting cookies    OFF

You can also choose to "Reject All" cookies in the cookie banner.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

If you have any questions or concerns about our use of cookies, please send us an e-mail at info@twelveoakstuition.co.uk

12.                  Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your data subject rights, please contact us at:

info@twelveoakstuition.co.uk

Twelve Oaks Tuition

Last updated: 20/10/2025