Privacy Policy

1. Introduction

MarkUp Tutors Ltd ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the MarkUp Tutors Platform.

We are registered with the Information Commissioner's Office (ICO) in the United Kingdom. This Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data Controller

The data controller for personal data collected through the Platform is MarkUp Tutors Ltd, registered in England and Wales. You can contact us regarding data protection matters at hello@markuptutors.com.

3. What Data We Collect

3.1 Data You Provide

• Name, email address, and password when you register an account.
• Profile information including photograph, biography, subjects, curriculum levels, and qualifications (Tutors).
• Educational background, certificates, and supporting documents submitted during Tutor verification, and, where voluntarily provided, background check certificates (e.g. DBS or equivalent).
• Payment information — processed securely by Stripe. We do not store full card details.
• Communications sent through our Platform messaging system.
• Reviews and ratings you submit.
• Referral codes and associated activity.
• Any correspondence you send to us directly including support requests.

3.2 Data Collected Automatically

• IP address, browser type, and device information.
• Pages visited, time spent on the Platform, and clickstream data.
• Session booking history and Platform activity logs.
• Cookies and similar tracking technologies as described in our Cookie Policy.

4. How We Use Your Data

We process your personal data on the following legal bases:

4.1 Performance of Contract

• Creating and managing your account.
• Processing bookings and payments.
• Facilitating communication between Students and Tutors.
• Reviewing Tutor applications and verifying credentials.
• Processing refunds and resolving disputes.

4.2 Legitimate Interests

• Improving and developing the Platform.
• Preventing fraud and ensuring Platform security.
• Sending service-related notifications and updates.
• Analysing Platform usage to enhance user experience.

4.3 Legal Obligation

• Complying with applicable laws and regulations.
• Responding to lawful requests from regulatory authorities.
• Maintaining financial records for tax and accounting purposes.

4.4 Consent

• Sending marketing communications where you have opted in.
• Placing non-essential cookies on your device.

You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

5. Data Sharing

We do not sell your personal data. We share data only in the following circumstances:

• Stripe — for secure payment processing and paying Tutors directly. Stripe's privacy policy governs their handling of payment data.
• Supabase — for authentication, database, and file storage services underlying the Platform.
• Netlify — for hosting the Platform.
• Google (Google Meet) — for powering video Sessions between Tutors and Students. Google processes meeting data in accordance with its own privacy policy.
• Other Users — Tutor profile information is visible to Students. Student names and basic information are visible to Tutors for booked Sessions.
• Law enforcement or regulators — where required by law or court order.
• Professional advisors — solicitors, accountants, and insurers under confidentiality obligations.

All third-party processors are contractually bound to process your data only as instructed and to maintain appropriate security measures.

6. International Data Transfers

Some of our service providers operate outside the UK and European Economic Area. Where personal data is transferred internationally we ensure appropriate safeguards are in place including Standard Contractual Clauses approved by the ICO or equivalent mechanisms.

7. Data Retention

We retain personal data only for as long as necessary for the purposes set out in this Policy:

• Account data — retained for the duration of your account plus 7 years following closure for legal and tax purposes.
• Payment and transaction records — 7 years from the date of transaction in accordance with HMRC requirements.
• Session records — 3 years from the date of the Session.
• Communications — 2 years from the date of the communication.
• Tutor application documents — 1 year from the date of application decision.

Following the applicable retention period data is securely deleted or anonymised.

8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to erasure — request deletion of your data in certain circumstances.
• Right to restrict processing — request that we limit how we use your data.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interests or direct marketing.
• Rights related to automated decision-making — not to be subject to solely automated decisions that significantly affect you.

To exercise any of these rights please contact hello@markuptutors.com. We will respond within one month. You also have the right to lodge a complaint with the ICO at www.ico.org.uk.

9. Cookies

We use cookies and similar technologies to operate and improve the Platform. Essential cookies are necessary for the Platform to function and cannot be disabled. Non-essential cookies including analytics and preference cookies are only placed with your consent.

You can manage cookie preferences through your browser settings at any time.

10. Children's Privacy

The Platform welcomes Students under the age of 18 ("Minor Students"), whose accounts must be registered and held by a parent or legal guardian in accordance with clause 3.1 of our Terms and Conditions. We do not knowingly allow a Minor Student to independently create an account or provide personal data to us without a Guardian's account in place. If you believe a Minor Student has provided data to us other than through a Guardian's account, please contact us immediately at hello@markuptutors.com so we can investigate and, where appropriate, delete that data.

In line with the Information Commissioner's Office Age Appropriate Design Code, accounts belonging to or created for a Minor Student default to the most privacy-protective settings available, we collect only the data reasonably necessary to provide tutoring services to a Minor Student, and we do not use a Minor Student's data for profiling or targeted advertising.

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include encrypted data transmission, secure authentication, access controls, and regular security reviews.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms we will notify you and the ICO as required by UK GDPR within 72 hours of becoming aware of the breach.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or Platform notification. The date of the most recent revision is displayed at the top of this Policy.

13. Contact

For any questions, concerns, or requests regarding this Privacy Policy or our data practices please contact our data protection contact at hello@markuptutors.com.