Tutor Group Limited ("we", "our", "us" or "iTutorGroup") respects the privacy rights of users and visitors ("you" or "your") of the iTutorGroup website (at www.itutorgroup.com) and/or iTutorGroup mobile application and services provided via these (together, "iTutorGroup Platform").
For the purposes of the General Data Protection Regulation of the European Union ("GDPR"), the data controller (being a responsible party as defined in terms of applicable data protection laws) of your personal data (which includes reference to "personal information" as defined in terms of applicable data protection laws) is Tutor Group Limited, whose registered address is Flat/Rm A 12/F Kiu Fu Commercial Bldg 300 Lockhart Road Wan Chai, Hong Kong.
- Collecting personal data
- Using your personal data
- Sharing your personal data
- International data transfers
- Retaining your personal data
- Automated decision-making
- Links to other websites
- Referral of friends
- California's "Shine the Light" law (Cal. Civ. Code § 1798.83)
- Your data subject rights
- Contact us
- For California Residents
1. Collecting personal data
1.1 Personal data we collect from you
When you create an account on the iTutorGroup Platform and apply to be a consultant, you will be required to provide your name, email address, mobile phone number, password, gender, nationality, current country of residence, education history and qualifications, teaching experience and teaching certificate and spoken languages and any other information you may provide in connection with your application.
When engaged as a consultant, you may also be required to provide your current address, identity verification, bank account or other payment details, a photograph, an introductory video and a written biography. You may also be required to upload your teaching materials onto the iTutorGroup Platform.
We may also collect special categories of personal data (known as sensitive personal data or special personal information in some jurisdictions), including your voice, speech patterns, mannerisms and facial images. In some jurisdictions where applicable under data protection laws, our collection of such data is subject to us having lawful bases for processing such data. Please see Appendix A below for further information.
You do not have to provide personal data to us, but if you choose not to provide personal data indicated as mandatory (e.g. on our application form), we may not be able to provide our services or otherwise engage or communicate with you.
If you are a California resident, please also refer to Appendix C.
1.2 Personal data we collect about you
1.2.1 Interview records
If you attend any online interview with iTutorGroup via video conferencing, we may record all or part of such interviews.
1.2.2 References and background checks
We may collect information about your employment history and qualifications, and subject to applicable legal restrictions, background and criminal records checks, from third party or publicly available sources and we will obtain your consent to such background checks where required by applicable law.
1.2.3 Recordings and content
If and to the extent permitted by applicable law, we may collect recordings and content from you if you require our troubleshooting support on live chats and/or emails.
1.2.4 Log records
When you log into the iTutorGroup Platform, we automatically receive and record information from your device, including device ID or IP address, and account's log information, such as the applications from which you entered the iTutorGroup Platform, the applications to which you head when you leave the iTutorGroup Platform, the amount of time you spend on the iTutorGroup Platform, as well as your behaviors on the iTutorGroup Platform.
We also work with third party ad networks to display more relevant advertising on our iTutorGroup Platform and to manage our advertising on third party sites, mobile apps and online services. For more information about cookies and other tracking mechanism as well as your choices please refer to Appendix B.
Our Site does not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed in Appendix B (e.g., by disabling cookies).
1.2.6 Other sources
We may also collect your personal data from:
- third party social media platforms (e.g. through Facebook or Google sign-in functions) or hardware/software functions;
- our background and criminal records checks service providers;
- our recruitment agency partners in some local jurisdictions (where applicable); and
- your family and friends through our "Referral" function on the iTutorGroup Platform.
2. Using your personal data
We will use and otherwise process your personal data for the following business and commercial purposes:
2.1 Application processing
- Process your application as a consultant;
- Verify your identity;
- Identify re-applications; and
- Conduct background and criminal records checks.
2.2 Managing your engagement as a consultant
- Managing and administering your engagement as a consultant, including without limitation arranging class scheduling, feedback and payment for your services;
- Display your profile, experience and credentials to students you may tutor via, and users of, our services and platforms;
- Facilitate classes with students you may tutor via, or users of, our services and platforms. This may include providing recorded tutoring sessions to users, as set out in your consultancy agreement; and
- Update your profile when requested by you or otherwise required by applicable law.
2.3 Communications, marketing and advertising
- Communicate with you in respect of the services we provide via the iTutorGroup Platform or when you otherwise engage with us via the iTutorGroup Platform;
- Send you communications (including personalized content, but other than by way of unsolicited electronic communications where we are required to obtain your consent in terms of applicable laws) from or about us or our Affiliates in relation to our products and services (including but not limited to newsletters, events, announcements and updates);
- Send you communications by unsolicited electronic communications from or about us or our Affiliates in relation to our products and services (including but not limited to events, announcements and updates). Where required under applicable laws, we will give you the opportunity to specifically consent to the receipt of such communications at the point that you register to use the iTutorGroup Platform and on each occasion thereafter that you receive such communications by electronic communications from or about us or our Affiliates. Should you already be considered an existing user of iTutorGroup who receives such communications by unsolicited electronic communications from us in relation to the same or similar products and services, we will give you the opportunity to opt-out of the communications on each occasion thereafter that you receive communications from or about us. You can also change your preferences at any stage by contacting us. If you are resident in the US, please note that it may take up to ten (10) business days for us to process opt-out requests; and
- Enable selected third parties to send marketing communications (and where required by applicable laws, only with your consent) which are related to their products or services which we think may be of interest to you.
2.4 Management of the iTutorGroup Platform
- Enable us to operate the iTutorGroup Platform;
- Check whether your devices meet the technical and operational requirements of the iTutorGroup Platform;
- Carry out support and maintenance functions;
- Provide you with necessary assistance in case of any technical issues;
- Conduct data analysis and research;
- Further develop and enhance the functionality and features of the iTutorGroup Platform; and
- Deploy security measures for the iTutorGroup Platform.
2.5 Business Operations
- Carry out our internal business functions such as quality control, headcount planning, reporting management;
- Carry out data migration activities where required for internal operation purposes;
- Protect our intellectual property and other rights;
- Enforce our internal policies and/or contractual rights;
- Conduct necessary investigations and disciplinary actions; and
- In the context of any merger, sale or acquisition of a company or business in which we (or any of our Affiliates) are involved and in order to manage such transaction.
2.6 Compliance purpose
- Comply with applicable laws, regulations, legal process (such as a court order or subpoena), governmental request, our internal policies and procedures, and other ethics, anti-corruption and compliance reporting tools;
- Protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, health and safety compliance, regulatory, investigative, grievance and disciplinary purposes;
- Detect, prevent or address fraud, security or technical issues; and
- Protect us and you, and our, your or others' rights, property or safety, or the public against harm, as required or permitted by law.
- Verify your identity and run background checks; and
- Detect potential imposters or fraudsters who may be using our services and platforms fraudulently or illegally.
We will use and otherwise process your special categories of personal data for the following purpose:
3. Sharing your personal data
We may share some or all of your personal data with the following:
- our affiliates within the iTutorGroup group of companies, including (but not limited to) TutorABC Limited, iTutorGroup Inc., TutorABC Inc., Shanghai Ping An Smart EduTech Co., Ltd, and the Ping An group of companies (collectively, "Affiliates");
- students you may tutor via, and users of, our services and platforms;
- our (and/or our Affiliates') service providers who support our provision and promotion of the iTutorGroup Platform, our services and our business, such as providers of IT and analytics services, software development kits, payment services, insurance, background checks, certification services and training, and our professional advisors (such as lawyers and accountants);
- Government, enforcement or regulatory authorities in any applicable jurisdiction;
- outside parties involved in a merger, acquisition or due diligence exercise; and
- anyone you authorise.
4. International data transfers
In order to operate the iTutorGroup Platform and to provide our services, we may need to transfer your personal data to locations outside the jurisdiction in which you live, including but not limited to Hong Kong SAR, Mainland China, Taiwan and the United States of America.
These jurisdictions may not provide a level of protection consistent with the laws and regulations of the jurisdiction in which you live. If that is the case, we will put in place reasonable measures to ensure that your personal data will be protected to a standard that is comparable to those laws and will comply with applicable data protection laws in relation to the transborder flows of personal data.
Your personal data may therefore be accessible to law enforcement and/or regulatory authorities in such foreign jurisdictions according to the applicable laws of such jurisdictions.
If you are based in the UK or the EU, we will only transfer your personal data out of the UK or the European Economic Area ("EEA") (as the case may be) if:
- the destination jurisdiction has been deemed to provide an adequate level of protection for personal data by the European Commission; or
- where legally required, we enter into data transfer arrangements based on the European Commission's Standard Contractual Clauses or equivalent means required by applicable laws. You are entitled to receive a copy of any documentation showing that appropriate safeguards have been taken to protect your personal data regarding the disclosures and transfers mentioned by making a request (see "Contact us" below).
Where South African data protection laws apply, to the extent that we transfer any special personal data or personal data relating to children to third parties located in jurisdictions that do not have adequate data protection laws as provided for under the jurisdiction in which you live, we shall do so only with the requisite prior authorisation of the data protection authority, in circumstances where required.
5. Retaining your personal data
It is important to let us know if there are changes to your personal data (e.g. if you move house). Please see "Contact Us" below.
We keep personal data of applicants during the application and selection process, and for two years afterwards for unsuccessful candidates or for such longer period as may be permitted or required by applicable law.
We keep personal data of consultants for the duration of the consultancy engagement and thereafter for as long as is necessary for the purposes for which the personal data was collected or used or for such longer period as may be permitted or required by applicable law.
We keep personal data of other users of the iTutorGroup Platform for as long as is necessary for the purposes for which it was collected and used (or a directly related purpose) or for such longer period as may be permitted or required by applicable law.
We are committed to keeping the personal data provided to us secure and we have implemented measures to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, no data security measures can guarantee security.
7. Automated decision-making
We may use automated decision-making, if it is authorized by legislation, if you have provided an explicit consent or if it is necessary for the performance of a contract. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you.
8. Links to other websites
The iTutorGroup Platform may contain links to other sites whose information practices may be different from ours. You should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
9. Referral of friends
10. California's "Shine the Light" law (Cal. Civ. Code § 1798.83)
California residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (so, requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a California resident and would like to make such a request, please submit your request in writing by emailing us at email@example.com, using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.
Our Services are not targeted to children (under eighteen (18) years of age or, in the US, under thirteen (13) years of age) and we do not knowingly collect personal information from children. If we discover that a child has provided us with personal information, we will promptly delete such personal information from our systems.
12. Your data subject rights
You may have the following rights in relation to the personal data we hold about you, and we will respond to such requests, in accordance with applicable laws:
- right to access your personal data, and in some cases information about how your personal data has been used;
- right to correct your personal data;
- right to withdraw consent to processing of your personal data;
- right to erase or delete your personal data in certain circumstances;
- right to restrict or object to processing of your personal data in certain circumstances;
- right to data portability;
- right to opt-out of sale of your personal data; and
- right to lodge a complaint with the relevant supervisory authority.
In respect of the South African Information Regulator, you may contact the office at: complaints.IR@justice.gov.za and at 27 (0) 10 023 5200 or 33 Hoofd Street Forum III, 3rd Floor Braampark, South Africa, Braamfontein, Johannesburg.
13. Contact us
15. For California Residents
If you are a California Resident, the following section also applies:
CONSENT (if you are not resident in the UK or the EU)
CONSENT LANGUAGE FOR BIOMETRIC DATA (if you are resident of Illinois, Washington and Texas)