This privacy notice was last updated on 9 September 2020.

This privacy notice sets out the basis on which we collect and process your personal data through the use of our website, our digital applications, and other marketing activities either in person or online.

Any future changes we make to this policy will be posted here so please check this page regularly.

Who We Are

Bespoke Tuition Ltd is the Data Controller responsible for your personal data within the context of the data you choose to directly pass to us through our website, digital applications, marketing activities, by email, phone or face to face.

Bespoke Tuition Ltd will sometimes be referred to in this notice as “we” or “us” or Bespoke Tuition or Bespoke Tuition IOM. By Data Controller, this means Bespoke Tuition Ltd determines the purposes and way in which any personal data are, or will be, processed.

Our registered office is at 88 Cronk Cullyn, Colby, Isle of Man, IM9 4PS and we are a limited company incorporated in the Isle of Man registered number 133282C.

If you have any questions about this privacy notice, the use of your personal information, your dealings with our website or our digital applications, you can contact us at hello@bespoketuitionIOM.com

Our Principles of Data Protection

Bespoke Tuition is committed to safeguarding the privacy of our website visitors and service users and complying with the General Data Protection Regulation and the Data Protection Act 2018.

Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you the best user experience.

We have published this notice to help you understand

• how and why Bespoke Tuition collects information from you;

• who we share your information with, why and on what basis; and

• what your rights are.

What information we collect and why?

a) Information you provide to us directly:

When you visit or use some parts of our website and/or services we might ask you to provide personal data to us. For example we ask you for your contact information when you submit an enquiry, student educational data when discussing objectives and your CV if applying for a tutor role, give feedback.

Where you are requested to fill in a form (either online or offline), it is your choice as to which fields to complete and with what data.

If you do not want to provide us with your personal data you do not have to but it might mean you cannot use some parts of our website or service.

b) Information we collect automatically:

We collect some information about you automatically when you visit our website or use our services, like your IP address and device type. We also collect information when you navigate through our website and digital applications such as what pages you looked at and what links you clicked on. This information is useful as it helps us get a better understanding of how you use our website and services so that we can continue to provide the best experience possible.

When you visit our website we may place cookies on your computer to help us make the website better and to help you navigate its pages. Cookies are small text files that are placed on your computer or mobile phone by websites that you use. Most web browsers allow some control of most cookies through browser settings. Please be aware, however, that without cookies you may not be able to use the full functionality of the site. You consent to our use of cookies by using our website. We are not responsible for the content or reliability of any website that we may link to. 

c) Information we get from third parties:

The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publically available materials. We may use this information to supplement the personal data we already hold on you, in order to better inform, personalise and improve our services and to validate the personal information you provide.

How do we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

• Contract - your personal information is processed in order to fulfil a contractual arrangement

• Consent – where you agree to us using your information in this way

• Legitimate Interests - this means the interests of Bespoke Tuition in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Parties in order to deliver you the requested service

• Legal Obligation – where there is a statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

Who we share your information with and why

There may be times when we need to share your data with third parties. We will only disclose your personal data to:

• Third party providers and partners who assist and enable us to use the personal data to support delivery of services or functionality of services or to market services and products to you

• Regulators, law enforcement, government agencies, courts or other third parties where we think its necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights

• An actual or potential buyer and or its advisers in connection with a purchase, merger or acquisition of any part of our business

• Other people where we have your consent

• Payment processors

• Sub processors who are vetted for GDPR compliance

• Debt Recovery, Credit Checking Services and Fraud Prevention Services

Transfers to third countries

Bespoke Tuition operates internationally.

Some of the information you provide to us may be transferred outside the Isle of Man.

Bespoke Tuition works with suppliers and partners who may make use of cloud and/or hosted technologies. We ensure that these partners conform to appropriate accreditations.

Your Rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

For more information or to exercise your data protection rights, please contact us at hello@bespoketuitionIOM.com.

You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

Keeping in touch with you

We want to keep you up to date with information about new services and improvements to our website and existing services and may communicate the information by email.

Bespoke Tuition will not share your information with companies outside of those listed in “Who we share your information with and why”.

If you decide you do not want to receive marketing information you can request that we stop by emailing hello@bespoketuitionIOM.com.

You may continue to receive mailings for a short period while your request is dealt with.

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under ‘How do we use your information’ above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;

• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or

Security

Security is a priority for us when it comes to your personal data. We are committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.

What are your rights

You are entitled to request the following from Bespoke Tuition, which are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

• Right of access – to request access to your personal information and information about how we process it

• Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed

• Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased.

• Right to restriction of processing – to restrict processing of your personal information

• Right to data portability - to electronically move, copy or transfer your personal information in a standard form

• Right to object - to object to processing of your personal information

If you have any general questions about your rights or want to exercise your rights please contact hello@bespoketuitionIOM.com

You have the right to lodge a complaint with the data protection regulator in the Isle of Man or the UK. The contact details are www.inforights.im and www.ico.org.uk respectfully. If you believe that your personal information has or is being used in a way that you believe does not comply with data regulation, however, we encourage you to contact us first and we will seek to resolve any issues or concerns.