Privacy Policy
WizAcademy.co.uk, herein referred to as WA has created this privacy statement ("Statement"™) in order to demonstrate our firm commitment to the privacy of the details that you provide to us when using this website.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
Unless otherwise indicated all definitions in the Terms and Conditions shall apply to this policy. In this Statement, references to "You" and "Your" are references to the user of www. WizAcademy.co.uk (the Site) regardless of whether you are a Client or a Tutor or other user. When you use the Site, you are consenting to the practices set forth in this Statement. It applies to information we collect about Users of our Site and amongst other things, this Statement describes what personally identifiable information "Personal Information” we collect from you, how and when it is used, how we protect it and who has access to it. This Statement incorporates our Cookie Policy.
This Policy
WA, recognizes the importance of confidentiality and the protection of personal information. Personal information means information about an identifiable individual or information that permits an individual to be identified. This privacy policy explains how we use and protect the personal information we hold, whether it relates to our students, parents, tutors, potential tutors, its staff, consultants and third party service providers in connection with our business and has been developed to comply with the EU’s General Data Protection Regulation (GDPR) and UK’s Data Protection Act 1998 (DPA).
We reserve the right to modify this Statement at any time without notice by posting the changes on this page. We may provide you with additional notice (such as sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
What information is collected?
We only collect and process personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information and will delete all provided information within 6 years of the termination of the usage of our services, save for information required for tax and regulatory purposes for a longer period of limitation.
WA processes personal data as a necessary part of entering into and performing our contract with you, which is governed by our Terms and Conditions. As part of the process of using the Site and the Services, we require you to give us certain Personal Information which we need to provide our Service. Without this information we may not be able to fulfil our contract with you. This information includes:
• Account information: to enable us to create an account for you on the Site. Depending on whether you register as a parent, student, or tutor, this information can include your name, email, telephone number, postal address, and date of birth.
• Tutor application details: so we can process your application to become a tutor. These details include your educational background and qualifications, your tutoring subjects, your profile picture, your gender and date of birth, your resume, the prices you charge, your availability and your DBS certificate (Disclosure and Barring Service).
• Communication history: to enable communication with other users of the website and with the WA team, we store details about your communication history including user messages, requests you have made, and your interactions with the WA team (including occasional call recordings).
• Booking history: to facilitate tutorials including information on booking requests, status of bookings, booking subjects and levels, results of your set-up tests whilst using the lesson space and recordings of your bookings (bookings include tutor interviews, free meetings, lessons and written sessions.)
• Promotions you redeemed: we record details of referral codes shared, redeemed and other promotions you interact with to be able to apply rewards to your account.
• Identity verification information: when you apply as a tutor we ask for verification that you study at the university you claim to, have a valid ID card and a clean DBS check. We also ask for information to demonstrate that you have the right to work in the UK.
• Financial information: We may require you to provide us with Financial Information to authorise or process payment and bill you or pay you for the Services. These details include for tutors: your nominated bank account, your invoices and your payment history, and for customers your payment history and payment card details. The Financial or Personal Information may be passed on to third parties (such as credit card companies and banks) necessary to process your transactions with us, for fraud protection and credit risk reduction. Except as provided above, we will not share Financial Information with third parties without your prior consent.
Our reason for collecting personal information about tutors, students, parents, staff and consultants is to establish and maintain our contractual or other business relationship with that individual.
The purpose for collecting personal information about tutors and students is primarily to facilitate the provision of educational tutoring services online, including to allow students to quickly and easily assess the professional and educational background of tutors, as well as allowing us to communicate effectively with tutors, students and parents and to maintain mailing lists. We may also use your personal information to:
· Respond to your comments, questions and requests and provide customer service.
· Communicate with you about services, offers and promotions and provide news and information we think will be of interest to you. We will seek separate consent for marketing and promotional emails as required by GDPR regulation.
· Manage your account and send you technical notices, updates, security alerts and support and administrative messages.
· Monitor and analyse trends, usage and activities.
· Link or combine with information we get from others to help understand your needs and provide you with better service.
· Carry out any other purpose for which the information was collected.
As appropriate, WA will ask for specific consent to collect, use and disclose personal information. Such a request, and your consent to such request, may be given in writing, orally or through the online platform. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.
DPA and GDPR permit WA to disclose personal information to certain third parties without the affected parties knowledge or consent to certain parties. Accordingly, we may share personal information about you as follows:
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Generally, personal information supplied to us is confidential and we do not disclose the information to unconnected third parties except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.
WA may use third party service providers from time to time to carry out certain functions for us such as printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by WA.
WA recognizes that the European Union (EU) and Switzerland have implemented omnibus data protection regimes established pursuant to the GDPR, European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively. Among other things, these laws require an "adequate level of protection" for the transfer of certain individually identifiable data about individuals in EU member countries and Switzerland to WA' operations.
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our website or services. The source of the usage data is Google Analytics, Mix Panel, Smartlook and Facebook. This usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is the legitimate interest of our platform and website, namely the monitoring and improvement of our website and services.
We may process information needed to set up and maintain an account with WA, in order to provide you with our services (account data). This account data may include your name, phone number and email address. The source of the account data is the information you provide. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is to allow the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information to be included in your personal client profile on our website (profile data). This profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, educational details and employment details. Profile data may be processed for the purposes of enabling your use of our services. The legal basis for this processing is to allow the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process your personal data that are provided in the course of the use of our services (service data). This service data may include information about your classes, academic performance and any factors relevant to this, your current, past or future academic institutions, your availability for tuition sessions, your preferred tuition location, and your experience or qualifications. We gather this information directly from you. Service data may be processed for the purpose of effectively providing our services. The legal basis for this processing to facilitate the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information that you post for publication on our website or through our services (publication data). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
We may process information contained in any enquiry you submit to us regarding our services (enquiry data). Enquiry data may be processed for the purposes of offering or providing relevant services to you. The legal basis for this processing is the legitimate interest of our platform, namely to respond to enquiries concerning our services and to make our services available to potential clients.
We may process information relating to our customer relationships, including customer contact information (customer relationship data). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to customers. The legal basis for this processing is the legitimate interest of our platform, namely the proper management of our customer relationships.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (transaction data). Transaction data may include your contact details, details of the payment method used, including details of specific payment cards, your billing address, and the details of the transaction itself. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
We may process information that you provide to us for the purpose of subscribing to our email notifications (notification data). The notification data may be processed for the purposes of sending you the relevant notification. The legal basis for this processing is the legitimate interests of our platform, namely the need to inform clients of relevant developments in relation to their use of our services, for example any charges to be levied in respect of those services.
We may process information contained in or relating to any communication that you send to us and/or other users (correspondence data). The correspondence data includes the communication content, video recordings, phone recordings and message transcripts and metadata associated with these communications. Our website will generate the metadata associated with communications made using the website. The correspondence data may be processed for the purposes of communicating with you, dispute resolution and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and protecting the integrity of our platform and brand.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, reporting misconduct or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risk.
In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person's personal data to us, unless we prompt you to do so.
Protecting your personal information
We strive to maintain personal information in an accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected. We protect personal information by security safeguards appropriate to the sensitivity of the personal information, regardless of format. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies.
You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us, or to or from our online Services. You accept that WA cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential information which you do not wish to communicate by email, please contact WA by telephone or post to arrange an alternative method of communication. You transmit all such information at your own risk. However, once we receive your transmission, we use our best efforts to ensure its security on our systems.
The Site has security measures in place to protect the loss, misuse and alteration of the information under our control. We use 128-bit industry standard Secure Server Software (SSL) for your transactions with us. It encrypts all your Personal Information, including credit card number, name, and address, so that it cannot be read as the information travels over the Internet.
We may disclose your personal data to our insurers and/or professional advisers in so far as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose enquiry data, profile data, service data or correspondence data to another or multiple clients of our platform in so far as reasonably necessary to affect an introduction between tutor and student for the purposes of arranging tuition, and to facilitate and administer that relationship, and to assist in the performance of the contract between tutor and student. The legal basis for this is the legitimate interest of our platform, namely the provision of our services.
Financial transactions relating to our website and services may be handled by our payment services providers, Stripe and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices on their websites.
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, connected companies, our ultimate holding company and all its subsidiaries) in so far as reasonably necessary for the purposes, and on the legal basis, set out in this policy.
In addition to the specific disclosures of personal data set out in this, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Information we collect automatically
We automatically collect certain information about you when you access or use our website or transact business with us, including:
Our website uses cookies, which are identifying technologies that your computer receives when you visit certain websites. Most browsers can be set to reject all cookies but features of our website may not work as intended if that option is chosen. We use permanent cookies to analyse website usage and improve our services. We use temporary (session based) cookies to improve performance and to determine web trends. Temporary cookies disappear when you close your browser window. We use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is used to help identify you for the purposes of gathering broad demographic information.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
The cookies that we use relate to authentication, status, personalisation, security, advertising (Google, Facebook, Bing) and analysis.
Our advertising service providers use cookies and those cookies may be stored on your computer when you visit our website. We primarily make use of Google to analyse the use of our website and Google Ad words to monitor our marketing performance. Google gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
Analytical cookies generated by Google, help us track the number of visits to our website, tell us how often you visit our website and how you use it. That may include which pages you’ve viewed, what journeys are taken from one page to the next, content you may have downloaded, your IP address and what devices are used to access our website. This helps us to ensure users find what they are looking for, and understand how web users engage with our content, so we can improve it over time to ensure users have a better experience. We also collect other marketing cookies generated by third parties, namely social media platforms and Google Ads. We use this information to identify content you’re most interested in and share more relevant information with you through advertising campaigns on other websites and social media, or email campaigns if you have submitted a contact form. For example, you may see some relevant WA adverts on various websites after your visit to our website. Additionally, if you have submitted a contact form or requested a demo, and subscribed to our mailing list, by using these cookies we’ll be able to send you emails tailored to your interests.
WA site may contain links to other websites. WA is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, and so you should be careful to read and understand those website policies independently.
Transfer of your personal information and financial information outside of the EEA
We may transfer personal data to entities outside of the EEA including in the United States, which countries may not have data protection laws as strict as those in the EEA. Where we transfer your information outside the EEA we will either undertake an assessment of the level of protection in light of the circumstances surrounding the transfer or:
• Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA; or
• Ensure we have an agreement in place with the recipient under which they are under a duty to protect your data to the same standards as those in place in the EEA; or
• We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information; and
• In all cases where your information is transferred outside the EEA, you have a right to contact us for information on the measures we have put in place.
Data Retention
We will retain your personal data as follows:
Account data, profile data, service and customer relationship data will be retained for a minimum period of one year from the time of the receipt of this data, and for a maximum period of six years from the end of the period in which the client is in receipt of WA’ services.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
· The period of retention of correspondence, usage, transaction and notification data will be determined based on their likely relevance to future reviews of company processes, or legal proceedings.
· The period of retention of publication data will be determined based on the period of time for which this data is intended to remain in publication.
· The period of retention of enquiry data will be determined based on the likelihood of an enquiry resulting in the provision of services to the data subject.
Your Rights
Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your principal rights under data protection law are:
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting https://www.WizAcademy.co.uk/ and logging into your personal client account.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You may make such amendments yourself by visiting https:// www.WizAcademy.co.uk/ and logging into your personal client account.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is: consent; or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and freedoms of others. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your personal data by written notice to us, specifically via email to admin@wizacademy.co.uk, in addition to the other methods specified in this Section
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
Accessing your personal information
You may write to our Data Protection Officer at admin@wizacademy.co.uk to request access to personal information about you. WA will generally inform you if we are holding personal information about you, as well as details about the personal information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to personal information may be denied if required or authorized by law. If a request for access is denied, WA will provide an explanation of the reasons for the refusal.
If you choose to withdraw your consent to continued collection, use or retention of your personal information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of personal information about you in our custody and WA will amend personal information where appropriate.
Recourse
If you have a concern about the personal information handling practices of WA, a complaint, in writing, may be directed to our Data Protection Officer via email to admin@wizacademy.co.uk. Upon verification of your identity, we will act promptly to investigate the complaint and respond within 60 days.
Where our Privacy Officer makes a determination that a complaint is well founded, we will take the necessary steps to correct the offending information handling practice and/or revise the privacy policies and procedures of WA. Where our Data Protection Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.