Privacy Policy

TUTORONBOARDER - PRIVACY POLICY - YOUR INFORMATION AND DATA PROTECTION

1 ABOUT THIS US AND THIS POLICY

(1) This Policy applies to TutorOnboarder

This Privacy Policy applies to TutorOnboarder (the website/platform and all of the Services and content which we provide on TutorOnboarder together with all subdomains, mobile applications, any other media, location, application, which we own, manage or operate).

(2) Who we are

We are Total Onboarder Ltd, who own and operate TutorOnboarder. We are a Company Registered in England and Wales, company number 15864805. Our Registered office is Flat 2, 1 Archway Mews, London, England, SW15 2PE. Our main email is hello@totalonboarder.com.

(3) Why we have a privacy policy

(a) As an organisation we comply with the UK Data Protection Act 2018 and the seven key principles as follows:

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality (security)
• Accountability

We also comply with the Data (Use and Access) Act 2025 (DUAA).

(b) Your privacy is important to us and this Privacy Policy is an overview to explain how we process (collect, use and hold) personal data (any information that identifies, or could reasonably be used to identify you such as your name, email address and support queries) and comply with our legal obligations. This Privacy Policy won’t apply if you can’t be identified, for example, when personal data has been aggregated and anonymised

(c) Please read through the policy carefully and if you have any queries, please email hello@totalonboarder.com or look at section 2 below to find alternative ways to contact us.

(d) We also use cookies on TutorOnboarder - see our separate Cookie Policy on our website.

(4) Making changes to this Privacy Policy

(a) This policy was last updated on June 2026.

(b) We may make changes to the policy (for example to keep up with changes in the law or have any changes in categories of data which we process or change the purposes for processing or third-party access or sharing, retention rules or user rights or restrictions) so we advise you to check the policy as you use TutorOnboarder. However, if we make a significant (material) change (for example use your personal data in a way which you wouldn’t expect) then we will actively let you know, for putting a notice on the Home page or by emailing you, using your last email address which you provided in TutorOnboarder.

2 CONTACTING US

(1) Who do I contact about personal data or change my mind about how you can use it?

The person responsible for our data protection is Matthew Curnier (he, him, his) whom you can contact if you need any help or information about this policy or about how we collect and use personal data

By Post/mail: Total Onboarder Ltd, Flat 2, 1 Archway Mews, London, England, SW15 2PE

By Email: hello@totalonboarder.com

3 COLLECTING PERSONAL DATA

Personal data

Personal data is any information which identifies or could reasonably be used to identify you, including your name, address and email address and IP address. Special category data is more sensitive, such as information about health or ethnic origin. Depending on how you use TutorOnboarder and anything which we provide to you, we collect a range of personal data from you, including your name and contact information (such as your address, telephone number and email) as well as other information which you choose to give us as you use TutorOnboarder.

About Data Controllers and Data Processors

• A Data Controller decides why personal data is collected and how it is processed.
• A Data Processor processes data on behalf of and on the instructions of a Data Controller.

So, when TutorOnboarder collects personal data from its users (TutorOnboarder Users) in order to provide the TutorOnboarder service (for example, the TutorOnboarder User’s name, address etc), we are a Data Controller for that data.

However, when a TutorOnboarder User uploads any personal data relating to them/their business onto the TutorOnboarder platform (for example, personal data relating to employees or tutors they work with), they are the Data Controller for that data because that individual TutorOnboarder User decides why they are collecting it and how they intend to use it. It means that when we handle or process the personal data that a TutorOnboarder User uploads to the platform, we act as a Data Processor on their behalf because we are processing their data to provide the TutorOnboarder User with our platform and services.

You may wish to read our FAQs for further information about the roles of Data Controllers and Data Processors.

(1) What personal data do you collect?

(a) Data we collect

As a Data Controller, we collect different types of personal data (any information that could identify you) but on the basis that we collect the minimum amount of data that we need. We may collect your personal data from you in the following ways:

• Identification and contact information – such as your name and contact details (address, email, telephone number) and information when you register on TutorOnboarder, become an Affiliate, and additional information which you give us when you apply for a job with us or start to work with us.
• Optional Information which you choose (consent) to give us and allow us to use so we can provide you with our Tutoring Services. This may include Special Categories of personal data (such as health information).
• Additional information you give to us, such as, for example, when you subscribe to a newsletter or take part in a survey or competition. This could be using TutorOnboarder directly or through social media, for example, if we run a Facebook survey (when the social media platform’s privacy policy will also apply).
• Customer Service Information you give to us when you ask us for any help and support.
• Accounting and transaction data relating to what you buy from us and the running of our business and paying taxes (financial information is often anonymised – for example, we do not receive card details when you use one to pay us).
• Information from others which you ask or authorise them to provide to us. For example, from your employer where we provide TutorOnboarder to your organisation.
• Marketing information and preferences.
• Technical and TutorOnboarder use information such as IP (Internet Protocol) address, log-in data, browser information (type and version), location and time-zone settings, operating system and platform data, as well as data on how you use TutorOnboarder and access third parties, including partner websites, products, and services and error reporting. Please also see our Cookie Policy.
• Technical use information such as IP (Internet Protocol) address, log-in data, browser information (type and version), location and time-zone settings, operating system and platform data, as well as data on how you use TutorOnboarder and access partner websites, platforms, products, and services and error reporting. We collect some of this information using tracking technology and cookies and please also see our Cookie Policy.
• Statistical information such as information that forms part of the aggregate information. So, for example, we may combine (aggregate) information about how you use TutorOnboarder and use it to share with our partners so we can bring the best discounts and offers to TutorOnboarder.
• Publicly available data such as information you share on social media.

If you choose not to provide us with personal data, we may be unable to provide some or all of TutorOnboarder services to you. For example, without your email address you will not be able to use TutorOnboarder because, for example, we will need to contact you about important changes.

If you don’t use TutorOnboarder but you think that someone who uses TutorOnboarder (a TutorOnboarder User) has entered your personal data onto TutorOnboarder please contact that TutorOnboarder User directly for information about your personal data, including if you want to access any data protection rights (for more information about UK Data Protection rights see https://ico.org.uk/your-data-matters/

(b) Children

TutorOnboarder is not aimed at anyone who is under 18 and we don’t knowingly collect any personal data from under 18 years old. Anyone who is under 18 must have the consent of their parent, guardian or someone with parental responsibility before they can use TutorOnboarder.

(c) For California Residents

For the purposes of the California Consumer Privacy Act 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), during the last 12 months, we have collected the following categories of Personal Information:

• Identifiers – for example, your name, email address, address, and email.
• Commercial/ Customer Record information – for example information about your purchase and/or use of TutorOnboarder.
• Professional or Employment-Related Information
• Internet or other network or device activity details – including technical data about how you use TutorOnboarder.
• Geolocation data – including such as your approximate location based on IP address;
• Financial information – including payment Information
• Protected Classification Characteristics – only if you provide them to us directly (e.g., as part of your profile or communications).
• Other Personal Information – for example, information you give us when you communicate with us.
• Inferences drawn from any of the above information.
• We do not use or disclose sensitive personal information as defined in the CCPA.

We retain this Personal Data for as long as is needed for the purpose(s) for which it was collected which varies according to our business, legal and regulatory needs. This is never longer than is relevant and reasonably necessary

(d) Data collected by TutorOnboarder Users

(i) TutorOnboarder allows an “Institute” meaning the business person or organisation that takes out a Subscription Plan to TutorOnboarder to invite Colleagues (members of an Institute’s business team or agents acting on their behalf who can access and use TutorOnboarder in their role as an Owner, Admin or as a Team Member on the Institutes’ behalf), Tutors (meaning someone who has already been approved to provide their services as a tutor to the Institute and has their own account as part of the Institute’s Subscription Plan to provide and receive information about those tutor services) and Tutor Applicants (meaning someone who is in the process of or has applied to provide their services as a tutor to an Institute and who does not yet have their own account but has been authorised by the Institute to input and upload Content as part of the Institute’s Subscription Plan) to access and use TutorOnboarder. We use the term Users to include Owners, Colleagues and Tutors. This means that TutorOnboarder users store and use (processes) personal data and other information in an electronic form. This personal data and other information belongs to the Owner and/or User, and they are the Data Controller within the meaning of the Data Protection Act 2018 and the European Union’s General Data Protection Regulation (GDPR). Users should check the Privacy Policy/Notice of the Institute(s) that they register with.

(ii) We are NOT a Data controller of any TutorOnboarder User’s data, including any data uploaded onto TutorOnboarder and we only process it on behalf of TutorOnboarder Users. This means that we do NOT own, control, or decide on why or how any TutorOnboarder User collects and processes any TutorOnboarder User’s data. Other than our responsibilities as a Data Processor while a TutorOnboarder User is subscribed to and using the TutorOnboarder service, we are not responsible for the security or privacy of any other data that the TutorOnboarder User may hold or process separately from our platform.

Only a TutorOnboarder User (which includes anyone whom they authorise to do so) is entitled to store, access, direct the use of or retrieve their own TutorOnboarder User data. You may wish to read our FAQs for clarification about the role of Data Controllers and Data Processors.

(iii) As part of using TutorOnboarder all relevant Users (when we process data as a Data Processor) will enter into a Data Processing Agreement (A DPA) with us. If you have any queries or need to discuss the personal data which is processed by a TutorOnboarder Users, please contact the TutorOnboarder User directly.

(2) How do you collect personal data?

We may collect your personal data from you in the following ways:-

• Information you provide to us when you buy from us or ask us to provide TutorOnboarder or any other associated products and/or services to you.
• Forms you complete, such as when you register with us.
• The information you provide when you communicate with us.
• Information you provide when using TutorOnboarder (such as when you ask us to help or provide support or give us feedback) or social media (for example, you may comment on one of our blogs or social media posts).
• Any surveys or feedback requests which you choose to complete or competitions which you choose to enter.
• Information we receive when you visit TutorOnboarder from another website/platform or from social media.
• If one of the people who work for us give us your contact details as their referee or emergency contact.
• Automated information about your visits to TutorOnboarder which will include (but are not limited to) your IP address, online tracking such as location, browser and type of device you use, as well as automated technology which collects technical information about your equipment and internet use (please also see our Cookie Policy).

4 USING (PROCESSING) AND SHARING PERSONAL DATA

(1) How do you use personal data?

We collect and use personal information in a variety of ways, including when we:

• Supply you with TutorOnboarder or any other products and/or services to you have asked us for, including when you become an Affiliate and to fulfil our contractual obligations to you.
• Send you any information which you have asked for or which may interest you, where you have consented to this happening, or information we need to tell you about.
• Manage our relationship and communicate with you, including letting you know about important changes and getting feedback.
• Interact and respond to you on social media.
• Market to you.
• Carry out a credit check where you have specifically agreed that we can.
• Support you such as when we deal with any request for help or answer your queries and customer support generally.
• Give you the best user experience and to enable you to participate in any interactive features of TutorOnboarder.
• Ask third parties to provide services to us including professional advisors, IT (including cloud providers), marketing, and outsourced services to help run our business properly and efficiently.
• Have your consent where applicable (for example, any marketing where your consent is required).
• Fulfil our contractual obligations to suppliers and other third parties.
• Assess your ability and suitability if you wish to work with or for us.
• Comply with regulations and legislation.
• To monitor, analyse and report how TutorOnboarder is used and to help us to administer it (including security and fraud detection) and to run our business generally.
• Manage our business properly and efficiently including managing marketing, segmenting users and monitoring usage trends
• Have other legitimate interests to do so.

(2) What is the lawful basis for processing my personal data?

The law says that we cannot process (collect, use or store) your information unless we have a lawful basis for doing so. There are several lawful bases which we rely on, including:-

• Consent - when you agree that we can use your personal data in a particular way. You can withdraw your consent at any time by emailing hello@totalonboarder.com if you change your mind).
• Contractual obligations – to fulfil our contractual obligations to you or because you have asked us to do something before we enter into a contract together.
• Legal obligation – when the law says that we must, such as for tax reasons and
• Legitimate Interest - Sometimes we will process your data when, for example,
• It is in our legitimate interests to do this and
• These interests are not overridden by your data protection rights.

(3) Who do you share personal data with?

(a) There may be times when we must share your personal data with others, for example, where the law requires us or to enforce our rights or protect others. We may also share your data to:-

• Allow TutorOnboarder Users to use it

Allow authorised third parties who are providing services to us and supporting us to provide TutorOnboarder. For example, IT Service Providers (including developers, testing platform providers, those providing technical support and customer services/chatbot, organisations who host TutorOnboarder, so they stay online and are secure, and organisations who provide us with email services so we can send and receive email), Social media providers, Advertising Organisations, Organisations who provide us with emails campaigns and newsletters, Organisations who provide us with analytics, Affiliates, Payment Providers, Credit Reference and Fraud Prevention Agencies and those who help us comply with Money Laundering obligations, Professional Service and other business and individuals who perform functions on our behalf. For more information please email Matthew Curnier at hello@totalonboarder.com or look at section 2 above to find alternative ways to contact us.

• Meet our legal and regulatory obligations such as to HMRC for taxation purposes.
• When selling our business or carrying out associated business activities.

Otherwise, we will only share your personal information if you have consented to this.

(b) Where relevant, we take all steps required by law to protect personal data such as, for example, having written agreements with those third parties.

5 YOUR PERSONAL DATA RIGHTS

(1) Your Rights

(a) The law gives you certain rights in relation to your personal data and to exercise or discuss these rights please email contact Matthew Curnier at hello@totalonboarder.com.

(b) Your rights depend on our reason for processing your information but may include the following:

• Access your personal data and making a Subject Access Request
• Correct/Rectify your personal data if it is inaccurate or incomplete
• Ask us to erase your personal data and prevent processing in specific circumstances
• How we use your personal data (restrict processing) in certain circumstances
• Data Portability - obtain and reuse your personal data for your own purposes across different services
• Object to processing your personal data in certain circumstances
• Making a data protection complaint

(c) For more information about your rights you can visit the Information Commissioner’s website visit where you can find detailed information about each of those rights https://ico.org.uk/your-data-matters/

(d) If you are a California Resident, please also see section 5(3) following.

(2) Exercising Your Rights

(a) We will deal with all personal data requests as soon as we are able and usually within one month of receipt. If there is going to be a delay (which could be up to 3 months) in dealing with your request or there is a reason why we can’t comply with your request, we will let you know and explain why within one month of receiving your request.

(b) We will ask you for some information first (primarily identification and clarification).

(c) You also have the right to lodge any data protection complaints with the Information Commissioner's Office (ICO), the UK’s supervisory authority. Visit ico.org.uk for more information including how to access their helpline.

(3) California Residents Rights

(a) Under the California Consumer Privacy Act 2018 (“CCPA”) if you a California Resident then you have the following rights:

• Right to know
• Right to delete
• Right to opt-out of sale or sharing
• Right to correct inaccurate data
• Right to limit use and disclosure of sensitive personal information
• Right to Non-Discrimination
• Right to be notified.

(b) For more information about your rights you can visit the website for the State of California Department where you can find detailed information about each of those rights https://oag.ca.gov/privacy/ccpa.

(4) To exercise or discuss these rights contact Matthew Curnier at hello@totalonboarder.com or look at section 2 above to find alternative ways to contact us.

6 DATA RETENTION - HOW LONG DO WE KEEP PERSONAL DATA FOR?

Unless you have specifically agreed otherwise, we will only keep your personal data for as long as it is

• Necessary for the purposes for which the personal data are processed
• To enable us to comply with our legal obligations, for example for tax purposes

Retention depends on our relationship with you and please see below:

7 PERSONAL DATA SECURITY

(1) What we do

We’re committed to keep personal data secure. We have implemented appropriate technology and operational security, including policies and measures to protect personal information under our control including from unauthorised access, improper use, alteration, unlawful or accidental destruction, and accidental loss on a “privacy by design and default” basis. This includes:-

• Encrypting data where possible
• Anonymising or pseudonymising data wherever this is possible
• Storing personal data in our internal systems and on secure servers that are not accessible by third parties without our express permission.
• Adhering to appropriate safeguards in accordance with UK Data Protection law if personal data is transferred from the UK and/or from the EEA – see section 8, Transferring of Personal Data To and From the UK section
• Providing internal policies, procedures and training about data protection to, as relevant, our employees and those who work with us
• Regularly reviewing how we process
• Restricting access to personal data to those who need it
• Physical security of our premises and our equipment
• Ensuring that we have procedures in place to deal with any data breach and/or security issues.

(2) Your Role

(a) Please ensure that

• your personal data is accurate and up to date
• you take reasonable care and safety when using your devices and the internet
• if you have a TutorOnboarder account, you use strong passwords which you regularly change and keep your log-in details secure
• you contact us immediately if you think or know your personal data and/or TutorOnboarder account has been used, compromised, or accessed without your express permission or if you have any other such concerns

(b) For more information please email hello@totalonboarder.com or look at section 2 above to find alternative ways to contact us.

8 TRANSFERRING OF PERSONAL DATA TO AND FROM THE UK

(1) Receiving Personal Data from the EEA

The UK left the EU on the 31st of December 2020. Anyone in the EEA who sends personal data outside the EEA must comply with the relevant GDPR rules. When we receive personal data from the EEA, we take steps to support compliance with those rules and to help protect the privacy and security of that data, including where required under the DUAA.

(2) Transferring Data from the UK

We may transfer personal data outside the UK or EEA (to countries that may not have the same level of data protection). Where we do this, we ensure that appropriate safeguards are in place to protect your personal data and to comply with UK Data Protection Law and any obligations that apply under the DUAA. These safeguards may include:

• the UK International Data Transfer Agreement (IDTA),
• the Addendum to the EU Standard Contractual Clauses, or
• other legally recognised transfer mechanisms.

Users should also refer to our Data Processing Agreement, which forms part of our Terms of Use, for further details about international transfers and DUAA-related obligations.

(3) Queries About International Transfers

If you have any queries about transferring personal data to and from the UK, please email hello@totalonboarder.com or look at section 2 above to find alternative ways to contact us.

9 EXTERNAL WEBSITE LINKS AND SOCIAL MEDIA

You may visit or leave TutorOnboarder by clicking a link to or from another website or platform operated by others (third parties) and we are not responsible for those websites or platforms – for example, you may use social media icons (such as X). If you do this, please also take the time to read the relevant privacy information provided by other websites/platforms because they may be different. Your information will only be shared where you have agreed to allow this.

10 NON-PERSONAL INFORMATION

(1) We also collect information which does not identify you (non-personal information). This includes the type of internet browser you use or the website from which you linked to TutorOnboarder.

(2) We may also aggregate information which you have submitted to us (for example, your age and the town where you live) which is anonymous - you cannot be identified from this information. We share this aggregate information with third parties to help us run TutorOnboarder and business effectively.

(3) We use cookies – please read our Cookie Policy

11 GOOGLE ADS

(1) TutorOnboarder may use Google Ads (formerly Google AdWords) remarketing service to advertise on third party websites (including Google) to previous visitors to our site.

(2) Using Google Ads means that we can advertise to previous visitors who have begun but not completed an action on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party sellers, including Google, use cookies to serve ads based on someone’s past visits to TutorOnboarder. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policies (you can find Google’s Privacy policy here https://policies.google.com/privacy?hl=en&gl=uk

12 COMPLAINTS AND DISPUTE RESOLUTION

(1) Contacting us

If you have any concerns about how we collect, use, or process your personal data, please contact us in the first instance so that we can try to resolve the issue quickly and fairly. You can contact us/Matthew Curnier

By Post/mail: Total Onboarder Ltd, Flat 2, 1 Archway Mews, London, England, SW15 2PE

By Email: hello@totalonboarder.com

We will acknowledge your complaint and aim to respond within a reasonable timeframe. If your complaint relates to data we process on behalf of a TutorOnboarder User (where we act as a Data Processor), we may need to refer your complaint to that User, as they are the Data Controller for that data.

(2) Contacting the Information Commissioner's Office

If you are not satisfied with our response, or you believe that we are not processing your personal data in accordance with data protection law or our obligations under the DUAA, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) who are the UK supervisory authority. You can visit https://ico.org.uk/ for more information about how to raise a concern, including the best ways to contact them.

You do not need to contact us first, but we would appreciate the opportunity to address your concerns before you approach the ICO.