Primary Tutor Project Privacy Policy

Last Updated: 11 June 2026

Privacy Policy Summary

This Privacy Policy explains how Primary Tutor Project collects, uses, stores and protects personal information.

What information we collect

Parent and guardian contact details.
Student information, including age, school year, learning goals and progress information.
Relevant SEND, medical or learning information where needed to support tuition safely and appropriately.
Booking, payment, website and communication information.

How we use information

To arrange and deliver tuition services.
To match students with suitable tutors.
To process bookings and payments.
To support safeguarding, quality assurance and service improvement.
To communicate with clients about lessons, services and relevant updates.

Recordings and safeguarding

Online lessons may be recorded for safeguarding, quality assurance, tutor support and complaint resolution.
Recordings are automatically deleted after 30 days unless they are required for safeguarding, legal, regulatory or complaint investigation purposes.

Your rights

You have rights under UK data protection law, including the right to access, correct, erase, restrict or object to the use of your personal information in certain circumstances.

Important: This summary is provided for convenience only. The full Privacy Policy below contains the complete wording and should be read in full.

Full Privacy Policy

1. Who We Are

1. Who We Are Primary Tutor Project ("PTP", "we", "us" or "our") is operated by Callie Moir, trading as Primary Tutor Project. Contact Details Primary Tutor Project 50 Belgravia Street Penzance Cornwall TR18 2BL Email: callie@primarytutorproject.com Website: www.primarytutorproject.com Telephone: +44 7361 806 786 For the purposes of UK data protection law, Primary Tutor Project is the Data Controller of the personal information described in this Privacy Policy.

2. The Information We Collect

2. The Information We Collect We may collect and process the following categories of personal information. Information About Parents and Guardians • Name • Email address • Telephone number • Billing address • Payment information • Booking history • Communications with us Information About Students • Name • Date of birth or age • School and year group • Academic history and attainment • Learning goals • Assessment results • Attendance records • Tutor feedback and progress notes Special Category Data Where relevant and voluntarily provided, we may collect information relating to: • Special educational needs or disabilities (SEND) including school reports, EHCPs, and SEND assessments • Medical or learning information relevant to tuition We only collect this information where necessary to provide suitable educational support, reasonable adjustments, safeguarding support, or to ensure that tuition is appropriate for the student. Website Information When you visit our website we may collect: • IP address • Browser information • Device information • Website usage information • Cookies and analytics data Further information can be found in our Cookie Policy.

3. How We Collect Information

3. How We Collect Information We collect information: • Directly from parents, guardians and adult students • Through booking forms and enquiry forms • Through our website • Through email, telephone, WhatsApp and messaging communications • Through lesson assessments and tuition activities • From schools or educational professionals where authorised by the parent or guardian • Through payment processors and booking systems

4. How We Use Personal Information

4. How We Use Personal Information We use personal information to: • Arrange and deliver tuition services • Match students with suitable tutors • Monitor student progress • Communicate with parents and students • Process bookings and payments • Provide customer support • Maintain safeguarding standards • Comply with legal and regulatory obligations • Improve our services • Prevent fraud and misuse of our services • Send service-related communications • Investigate complaints or concerns Where you have provided consent, or where otherwise permitted by law, we may also send marketing communications regarding our services, courses, workshops, events and educational resources.

5. Lawful Bases for Processing

5. Lawful Bases for Processing Under UK GDPR, we rely on the following lawful bases: Contract Processing necessary to provide tuition services, manage bookings, process payments and communicate with clients. Legitimate Interests Processing necessary for: • Tutor matching • Service administration • Quality assurance • Service improvement • Business management • Fraud prevention • Safeguarding activities • Handling complaints and disputes We carefully balance our legitimate interests against the rights and freedoms of individuals. Legal Obligation Processing necessary to comply with: • Safeguarding obligations • Tax and accounting requirements • Legal and regulatory obligations Consent Where consent is required, including certain marketing communications. Consent may be withdrawn at any time. Special Category Data Where we process SEND or health-related information, we do so only where necessary for educational support, safeguarding purposes, or with explicit consent where required by law.

6. Sharing Personal Information

6. Sharing Personal Information We only share personal information where necessary. Tutors We may share relevant information with self-employed tutors engaged by Primary Tutor Project who require access to information in order to provide tuition services safely and effectively. Tutors receive only the information necessary to deliver tuition and are required to treat such information confidentially. Service Providers We currently use trusted third-party providers including: • Stripe (payment processing) • Mailchimp (email communications and marketing) • Lessonspace (online tuition platform) • YoCoach (booking and client management platform) • Google Workspace and Google Drive (business communications and secure storage) We may replace or add service providers from time to time where necessary to operate our services. Professional Advisors We may share information with accountants, insurers, legal advisers, regulators and other professional advisers where reasonably necessary. Safeguarding Authorities Where necessary to protect a child or vulnerable person, or where required by law, information may be shared with schools, local authorities, police, social services or other safeguarding agencies.

7. International Data Transfers

7. International Data Transfers Primary Tutor Project serves families and students internationally. Personal information may be accessed by clients, tutors and authorised representatives located outside the United Kingdom where this is necessary to provide tuition services. Where personal information is transferred internationally, we take appropriate safeguards to ensure that personal information remains protected in accordance with UK data protection laws. These safeguards may include: • Adequacy regulations • Standard Contractual Clauses • Appropriate contractual protections • Secure cloud-based systems

8. Online Lesson Recordings

8. Online Lesson Recordings Online lessons may be recorded for: • Safeguarding purposes • Quality assurance • Tutor support and training • Resolving complaints, concerns or disputes Recordings are stored securely and access is restricted to authorised personnel. Recordings are automatically deleted after 30 days unless they are required for safeguarding, legal, regulatory or complaint investigation purposes.

9. Safeguarding

9. Safeguarding Protecting children is a fundamental part of our services. We may process personal information where necessary to: • Protect a child's welfare • Investigate safeguarding concerns • Comply with safeguarding obligations • Maintain safe tuition environments • Respond to concerns raised by tutors, parents or external agencies Where appropriate, information may be shared with relevant safeguarding agencies, schools or authorities.

10. Data Retention

10. Data Retention We retain personal information only for as long as necessary to fulfil the purposes for which it was collected. Typical retention periods include: Information Type Retention Period Client records Up to 6 years after tuition ends Financial records 6 years Communications Up to 6 years Tutor reports and progress records Up to 6 years Marketing contacts Until consent is withdrawn or the individual unsubscribes Lesson recordings 30 days unless retained for safeguarding, legal or complaint investigation purposes Safeguarding records As long as reasonably necessary to comply with safeguarding obligations Retention periods may be extended where required by law or for the establishment, exercise or defence of legal claims.

11. Data Security

11. Data Security We take appropriate technical and organisational measures to protect personal information. These measures include: • Password-protected systems • Restricted access to personal information • Secure cloud storage • Encrypted payment processing • Tutor confidentiality obligations • Secure business communication systems • Regular review of security practices While we take reasonable steps to protect information, no system can be guaranteed to be completely secure.

12. Marketing Communications

12. Marketing Communications We may send marketing communications to: • Individuals who have actively opted in to receive marketing communications; and • Clients who have registered for services through our platform where permitted by applicable law. Marketing communications may include information about: • Tuition services • Courses and workshops • Educational resources • Promotions and special offers • Events and webinars Individuals may unsubscribe at any time by: • Clicking the unsubscribe link contained within marketing emails; or • Contacting us directly. We will not sell personal information to third parties for marketing purposes.

13. Messaging Services

13. Messaging Services We may communicate with clients via: • Email • Telephone • SMS • WhatsApp • Other messaging platforms Such communications may be used for booking administration, lesson arrangements, safeguarding matters, customer support and other service-related purposes.

14. Your Rights

14. Your Rights Under UK data protection law, you have the right to: • Access your personal information • Correct inaccurate information • Request erasure of personal information • Restrict processing • Object to processing • Request data portability • Withdraw consent where consent is relied upon Requests should be sent to: callie@primarytutorproject.com We will normally respond within one month.

15. Children's Privacy

15. Children's Privacy Children under the age of 13 should not provide personal information directly to us without the involvement of a parent or guardian. Parents and guardians are responsible for providing information on behalf of children where appropriate.

16. Complaints

16. Complaints If you have concerns about how we use personal information, please contact us first: callie@primarytutorproject.com You also have the right to complain to the Information Commissioner's Office (ICO): Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 Website: https://www.ico.org.uk

17. Changes to This Privacy Policy

17. Changes to This Privacy Policy We may update this Privacy Policy from time to time. The latest version will always be available on our website and will show the date of the most recent update. Where significant changes are made, we may notify clients directly by email or through our website.