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Privacy Policy

1 About our Policy

1.1 Introduction

Hello, we’re Tutero (we, us), an entity wholly owned by Math Gaps Pty Ltd (ACN 647 042 251) (Tutero). This Privacy Policy (this Policy) is provided to ensure you understand your rights and obligations when you access, navigate and use the Tutero Software, Website, Applications, and Services (the Platform).

Tutero respects the rights and privacy of all individuals and is committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), and other relevant privacy laws. This Policy describes how, and the purpose for which, Tutero collects, uses, stores and discloses your information, including personal information, in connection with your interaction and engagement with Tutero and your access to and use of the Platform.

1.2 Your agreement to this Policy

By accessing the platform, or any other alternatively branded platform that is powered by Tutero, you confirm that you have read and agree to the terms of this Policy and consent to your personal information (including, your sensitive information) being collected, stored, used and disclosed in accordance with this Policy. If you are under 18 years of age, or legally a minor in your relevant location, a parent or guardian must consent on your behalf. Please read this Policy carefully to understand our practices regarding your personal information.

1.3 Changes to this Policy

Tutero may routinely review and update this Policy, including taking account of new or amended laws, new technology and/or changes to operations. All personal information held by Tutero will be governed by the most recent updated Policy.

If changes are made to this Policy, we will upload the revised Policy to the Platform. Changes to this Policy will come into effect immediately upon such changes being uploaded on the Platform. Your continued use of the Platform following such upload will constitute your acceptance of any changes.

If you disagree with the revised Policy, you may terminate your agreement with Tutero (in accordance with the terms of the relevant agreement), cease using the Platform and deactivate your Account.

1.4 Employee records exemption

Where applicable, Tutero will rely on the "employee records exemption" in the Privacy Act and any other applicable exemptions in the Privacy Act or other relevant legislation. The employee records exemption means that, in many cases, Tutero is not bound by the requirements of the Privacy Act in relation to personal information it holds about its current or former employees (relating to their employment).

2 Types of information we collect

2.1 Your engagement with Tutero

There are many ways that you can engage with Tutero, its Representatives or the Platform including (but not limited to):

a)  As a customer utilising the platform;

b)  As customers utilising a platform under another brand that is powered by Tutero;

c)   As a user utilising the Tutero platform;

d)  As user utilising a platform under another brand that is powered by Tutero;

e)  As a tutor utilising the Tutero platform;

f)   As a tutor utilising a platform under another brand that is powered by Tutero;

g)  As a tutoring company administrator utilising the Tutero platform; or

h)  As a tutoring company administrator utilising a platform under another brand that is powered by Tutero.

Depending on how you engage with Tutero and its Representatives and use any Tutero Platform, we may ask you to share, or may collect your ‘personal information’.

2.2 Personal information

When used in this Policy, the term “personal information” has the meaning given to it in the Privacy Act. Accordingly, “personal information” includes any information or opinion that identifies or can be used to identify, contact, or locate you. This may include, but is not limited to, your name, date of birth, address, gender, contact details (including phone numbers and email addresses) and possibly financial information, including your credit card or direct debit account information.

2.3 Consent

Your consent to this Policy is the legal basis upon which we cancollect, use, store, process and disclose your personal information. Youacknowledge and accept that by using our Platform, you are consenting toproviding us with your personal information and agree to your personalinformation being collected, used, stored, processed and disclosed inaccordance with this Policy.

If you do not wish to provide us with your personal information, thenyou are not required to do so. However, by deciding not to provide us with yourpersonal information you may not be able to access the services provided by Tutorsor Tutoring Companies or effectively use the services offered through thePlatform either to the same standard as if you had provided the requiredpersonal information or not at all.

In the case that you are under 18 years of age, or legally a minor inyour relevant location, a parent or guardian must consent on your behalf.

2.4 Types of information

The types of information that we collect from you depends on your dealings with Tutero. For example, the information that we collect from Students, Parents, Tutors and Tutoring Companies will vary. Below is a non-exhaustive list of the general categories of information we collect.

2.4.1 Information you give us

We generally collect the following personal information, and usage information, from you through the Platform, or via telephone, email, post or in person.

2.4.1a Personal Information

We may ask for and collect your:

a)  first name;

b)  last name;

c)  date of birth;

d)  residential and postal address;

e)  email address;

f)    telephone number;

g)  education background;

h)  personal interests;

i)    gender;

j)    language preferences;

k)   credit/debit card details; and

l)    any additional information relating to you that you provide to Tutero through the website, by phone, email, surveys, or in person, or information you have provided indirectly through use of the Website or online presence.

 

2.4.1b Information collected from application usage

As you use the Tutero platform, we may collect information related to your platform usage. The information collected may include, but is not limited to:

a)  information regarding mathematical understanding;

b)  information regarding frequency of platform usage;

c)  any tutoring schedules that are formed;

d)  any notes and comments created;

e)  the details of your tutoring engagements;

f)   any homework tasks that ares set;

g)  recordings of your video tutorials;

h)  device information; and

i)    location information.

 

2.4.1c Communications with Tutero

When you communicate with Tutero or use the Platform to communicate with other Users, we monitor, record and store those communications and any information you choose to provide to Tutero and other Users.

 

 

2.4.1d Information received from a Tutoring Company

If a Tutoring Company intends to provide Tutero with personal information (including sensitive information) about any other person they must obtain the relevant person’s consent before providing us with that information.

2.4.2 Information we automatically collect from you

When you use the Platform, Tutero automatically collects certain information from you, including personal information.

2.4.2a Usage information

Tutero collects information about your interactions with the Platform, such as the pages or content you view, your searches, and other actions you take on the Platform.

2.4.2b Engagement records

If you contact Tutero on the Platform, by telephone, email, post or in person we automatically record any information, including personal information that you provide to us.

2.4.2c Log Data and Device Information

We automatically collect log data and device information when you access and use the Platform. That information includes, among other things, a recording showing how you used the Platform, your clicks, scrolls and activities on the Platform, your IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you have viewed or engaged with before or after using the Platform. We use this type of information to administer the Platform and to analyse trends.

2.4.2d Cookies

When you use the Platform or website, Tutero may obtain information using technologies such as cookies, tags, web beacons, and navigational data collection (log files, server logs, and clickstream data) to better understand your experience. For example, Tutero may collect information like the date, time and duration of visits and which webpages are accessed.

Tutero collects some anonymous information about how you use the Platform by setting and accessing cookies on your computer. A cookie is a small text file that allows our system to identify and interact more effectively withyour computer or device. We use cookies to measure traffic patterns, to determine which areas of our website has been visited, and to measure transaction patterns in the aggregate. We use this to research, to monitor user habits to improve our online services. You can configure your web browser to restrict or disable cookies, however, this may cause some parts of the Platform not to have full functionality.

Tutero may also log IP addresses (the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track user movements, and gather broad demographic information.

2.4.2e Payment Transaction Information

Tutero collects information related to your payment transactions through the Platform, including the payment instrument used, payment dates and times, payment amounts, your billing postcode, address and other related transaction details. This information is necessary for the adequate performance of the agreement between you and Tutero.

2.4.3. Information we collect from third parties

Tutero may collect personal information about you, including sensitive information, from third parties (such as distributors or resellers). We do not control, supervise and are not responsible for how those third parties processyour personal information. Any information request regarding the disclosure of your personal information by a third party to us should be directed to such third parties.

2.4.3a Third Party Services

If you link, connect, or login to the Platform or your Account through a third-party service (e.g. Google, Facebook) the third party service may send us information such as your profile information from that service. This information varies and is controlled by that third party service or as authorised by you via your privacy settings with that third party service. The use of these technologies allows those third-party services to evaluate your use of the Platform and other websites, deliver customised advertising content,measure the effectiveness of their advertising, and provide other services relating to website activity and internet usage.

Tutero makes no representations or warranties in relation to the privacy practices of any third-party service providers and we are not responsible for the privacy policies or the content of any third party service provider.

2.4.3b Advertising Services

If you click on an online Tutero advertisement (e.g. ads on Google) the third party service hosting that advertisement will collect certain information and will provide that information to us to allow us to measure the effectiveness of our advertising.

2.4.3c Your References

If someone has provided Tutero with a reference about you, it will beheld and stored by Tutero.

2.5 Dealing Anonymously or By Pseudonyms

If you choose to use the Tutero platform and would prefer for your data to be anonymous, or stored under a pseudonym, Tutero can provide you with the ability to make this request. Please contact the privacy officer to discuss this request. The relevant contact details for the privacy officer can be found at the bottom of this document.

 

3 How we hold and store your personal information

Tutero will retain the personal information that is collected from and about you for as long as it is needed to provide access to the Site or to manage your account.

We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your information.

Tutero may however retain and use personal information as necessary to comply with legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytics purposes and for product and service improvement.

If we suspect any misuse or loss of, or unauthorised access to, your personal information we may inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your personal information. If we determine that the breach is likely to result in serious harm to you and we are unable to prevent the likely risk of serious harm with remedial action, we will take action in accordance with the Privacy Act.

 

4. How we use your personal information

Information about how we use your personal information is below. This list is not exhaustive and there may be other third parties to which we give your personal information (for example, professional advisors or insurers) where required or permitted by law.

4.1 Use of yourpersonal information for the Platform

We may use your personal information to build, operate and improve the Platform and as necessary for the adequate performance of our agreement with you.

Below is a non-exhaustive list of the purposes for which we may use your personal information. We may use your personal information to:

a)  verify or authenticate information provided by you and your identity;

b)  conduct necessary checks to verify the information you have provided as part of the Registration Process;

c)   enable you to access and use the Platform;

d)  enable you to create and update your personal Profile;

e)  enable you to create and update your tutoring company Profile;

f)    maintain and update our records;

g)  operate, protect, improve, and optimise the Platform and our Customers’ experiences on the Platform;

h)  operate, improve, and optimise related services, such as by performing analytics and conducting research;

i)    assist us to provid eeffective customer service;

j)    process, manage and administer account payments, billing issues and payroll transactions;

k)   send you support messages, updates and account notifications;

l)    where you have consented to the use or disclosure;

m) complete internal accounting and administration; and

n)  facilitate any authorised payments.

 

The primary purpose for which we collect information about you is to enable Tutero to perform its business activities and functions and to provide you with the best customer experience.

4.2 Sharing of your personal and platform information with tutors and tutoring companies

If you utilise a Tutero powered platform that features branding for a third-party tutoring company, or if you purchase a premium subscription to the Tutero platform with a unique discount code provided to you by a third-party tutoring company, or if you link your account with a tutor that works for a tutoring company, this constitutes as consent to share your information with the associated tutoring company. As such, we may share the Personal and Platform Usage information we collect about you with the associated tutoring company.

If you engage a Tutero tutor for tutoring services, this constitutes as consent to share your information with that tutor. As such, we may share the Personal and Platform Usage information we collect from you with that tutor. An account can be linked with an individuals tutors account if they invite you to join the platform, or if you utilise the account linking functionality for your existing account.

4.3 Use of your personal information for marketing and advertising purposes

We may use your personal information to undertake and direct advertising and marketing activities that we consider may be of interest to you. These communications may be sent in various forms in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth).

Below is a non-exhaustive list of the purposes for which we may use your personal information. We may use your personal information to:

a)  send promotional messages, marketing, advertising, and other information to you via telephone, email, online and other means;

b)  contact you by telephone or text message solely in connection with the services we provide and only if you have provided us with your phone number;

c)   conduct product and market research; and

d)  personalise, measure, and improve our advertising and marketing.

 

Communications may also be received from other companies with whom we hold a relationship for the purpose of fulfilling certain services available on the Platform.

 

You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications. Even if you do opt out of receiving marketing communications from us, you agree that we may still send you information relevant to the supply of any services arranged by us.

 

4.4 Use of financial information

If you use the Platform to make purchases or complete other financial transactions (such as payment of invoices for products or services you purchase from a third-party user or Vendor), Tutero may collect information about the purchase or transactions. This includes, payment information, such as your credit card or debit card number (stored securely), billing details and other account and contact information (Financial Information).

Tutero will only collect your Financial Information from you with your prior knowledge.

Tutero may use your Financial Information solely to process payments for products or services you request or purchase. We only use and retain your Financial Information to complete payments you initiate. Any Financial Information that is collected is solely for the purpose of transaction approval and the transfer of funds.

Tutero provides data encryption throughout the payment process and only shares your Financial Information with your credit card provider, third party payment processor, Vendor, and financial institution, to process payments. The Financial Information we collect from you is strictly confidential and held on secured servers in controlled facilities.

We may use third party agents to manage online payment processing. Any third-party agent used by us is not authorized to use your Financial Information in anyway other than to process payments and is required to keep any Financial Information it uses or collects confidential.

Tutero makes no representations or warranties in relation to the privacy practices of any third party agent and we are not responsible for the privacy policies or the content of any third party agent.

 

5. Disclosing your personal information

5.1 Disclosure withyour consent

Except as may be stated in this Policy, where you have provided your express consent for specific parts of your personal information to be disclosed, we will only disclose and share your personal information that is held by us as at the time of receiving your consent.

5.3 Unidentified datasharing

Tutero may also share information about our Customers that has been aggregated or combined so that it no longer identifies an individual Customer. This anonymised information may be used for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

6. Changes to this Policy

Tutero may change this Policy by uploading a revised Policy onto its website (www.Tutero.com.au). Unless stated otherwise, the change will apply from the date that the revised Policy is uploaded.

Contact us

If you have any questions about this Policy or our privacy practices, you can contact us at hello@tutero.com.au

7. Accessing your personal information

You may access and amend parts of your personal information by logging into your Account and making changes at any time. Alternatively, you have a right to request access to your personal information at any time by contacting our Privacy Officer.

Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information. If you make anaccess request, we will ask you to verify your identity.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate,then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

We request that you keep your information as current as possible so that we may continue to improve our service to you.

To request access or to amend your personal information, please contact our Privacy Officer using the following details.

Email: hello@tutero.com.au

Phone +61 425 405 770

8. Your Choices

You may opt-out of receiving marketing communications or targeted advertising from us at any time, by using the link in promotional and marketing emails or by contacting us directly on hello@tutero.com.au. Please note you cannot opt-out of receiving administrative and transaction related emails from us unless you deactivate your Account. These are emails that relate to your Account and/or your activity on the Platform.

9. Contact Us

9.1 Feedback

If you have any feedback or questions about this Privacy Policy or any of our privacy-related practices, please contact our Privacy Officer at hello@tutero.com.au.

9.2 Complaints

If you have a concern about how we have handled your personal information, please let us know so we can address the problem.

We are genuinely committed to the rules, ethos and intent detailed in this Policy and we aim to ensure that your requests or complaints are treated confidentially. Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaintis resolved in a timely and appropriate manner.

Please contact our Privacy Officer at hello@tutero.com.au.

 

Last updated 07 September 2021.