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Privacy Policy
- Privacy Policy
Introduction
Daresne Ltd (“we”, “us”, or “our”) is committed to protecting the privacy and personal data of our users, tutors, and anyone interacting with our services. This Privacy Policy outlines how we collect, use, and safeguard personal information in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable laws.
Definitions
User: Refers to students, parents, legal guardians, or anyone managing a Daresne Student Account.
Data Controller: Daresne Ltd, responsible for determining the purposes and means of processing personal data.
Data Processor: Tutors engaged by Daresne Ltd to deliver lessons and who process limited personal data on our behalf.
Legal Basis for Processing Personal Data
We process personal data in accordance with the UK GDPR and the Data Protection Act 2018. The legal bases for processing are as follows:
Article 6(1)(b) – Contractual Necessity:
Processing is necessary for the performance of a contract to which the User (or their parent/legal guardian) is a party. For example:
Collecting and processing personal data to provide tutoring services.
Using contact details to schedule lessons and communicate with parents or guardians.
Article 6(1)(f) – Legitimate Interests:
Processing is necessary for the purposes of our legitimate interests, provided such interests are not overridden by the rights and freedoms of the data subject. Examples include:
Maintaining operational records to ensure service quality.
Evaluating tutor performance for quality assurance.
Using limited User information for marketing and promotional activities (e.g., via Meta platforms like Facebook and Instagram).
Article 6(1)(c) – Legal Obligations:
Processing is necessary for compliance with a legal obligation to which we are subject. Examples include:
Retaining payment records for tax and accounting purposes.
Collecting and storing enhanced DBS checks or equivalent for safeguarding compliance.
Article 6(1)(a) – Consent:
Processing is based on explicit consent provided by the data subject or their parent/legal guardian. For example:
Sending marketing communications via email or messaging platforms where consent is required.
Article 9(2)(g) – Substantial Public Interest (Special Categories of Data):
Where applicable, processing special category data, such as information about a student’s special educational needs, is carried out in accordance with Schedule 1, Part 2 of the Data Protection Act 2018, for safeguarding and educational purposes.
Information We Collect and Process
For Users:
Student Information: Name (displayed on the tutor dashboard), knowledge gaps, areas of improvement, exam boards, and special educational needs (if applicable).
Parent/Guardian Information: Name, phone number, and email address for communication purposes, including monitored WhatsApp groups.
Payment Information: Stored securely via third-party payment processors such as Stripe.
- Address: For sending awards, certificates, or for pursuing debt collection or legal action if necessary. We may also use this address if a User, Tutor, or anyone reports or reasonably believes that a child or vulnerable person is at risk. In such cases, law enforcement and related authority bodies will be notified.
For Tutors:
Personal Information: Name, contact details, a digital copy of an enhanced DBS check (or international equivalent with English translation), ID or passport picture, and lesson completion logs.
Performance Data: Subject quiz results and records of trial and regular lessons completed for evaluation purposes.
Operational Records:
Lesson logs, including date, time, and content delivered, for both Users and Tutors.
Relevant information required for operational, safeguarding, or contractual purposes.
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to improve user experience, analyse website traffic, and support marketing efforts. Users can manage cookie preferences through our cookie banner or browser settings. For more information, refer to our Cookie Policy.
Parental Consent for Minors
For Users under the age of 18, we require the explicit consent of a parent or legal guardian to collect, process, and use personal data. By creating a Daresne Student Account or enrolling a minor in our tutoring services, the parent or guardian confirms that they have read and agreed to this Privacy Policy. We take steps to verify parental consent, including requesting additional confirmation where necessary.
Safeguarding Measures
We prioritise the safety and well-being of minors using our services. Our safeguarding measures include:
DBS Checks: All tutors are required to undergo an enhanced DBS check (or an international equivalent with English translation) to ensure their suitability for working with minors.
Monitored Communication: All communication between tutors and students (outside of tutoring lessons) is facilitated through monitored WhatsApp groups, with parents or guardians included.
Mandatory Reporting: Tutors and staff are trained to report any safeguarding concerns in accordance with UK safeguarding laws.
Limited Access: Tutors only have access to information essential for providing personalised support, such as knowledge gaps, exam boards, and special needs information shared by parents or guardians.
How We Use Your Information
To provide personalised tutoring services tailored to the student’s needs.
To facilitate communication between parents/guardians and tutors via monitored WhatsApp groups.
To maintain operational records for quality assurance, safeguarding, and legal compliance.
To evaluate tutor performance and ensure the quality of services.
To pursue debt collection or legal action in cases of severe breach of our terms or applicable laws.
For marketing purposes via platforms like Meta (Facebook, WhatsApp, Instagram), Zoom LLC, or Google Meet, where applicable.
To analyse website traffic and optimise User experience using analytics tools such as Google Analytics.
Data Sharing
We may share personal data in the following circumstances:
With Tutors: Limited to the student’s name, educational details, and relevant information shared by the parent/guardian.
With Third-Party Service Providers: For payment processing (e.g., Stripe, GoCardless, Paddle) and lesson delivery platforms (e.g., Zoom LLC, Google Meet).
For Marketing: Through Meta platforms, subject to explicit consent where required.
With Hosting Providers: Our website and data are hosted on servers in the United Kingdom, managed by Hostinger Ltd.
For Debt Collection or Legal Action: With authorised agencies or legal representatives, if necessary.
Data Transfers Outside the UK
While our servers are located in the United Kingdom, some third-party service providers may process data outside the UK. In such cases, we ensure compliance with GDPR using safeguards like Standard Contractual Clauses (SCCs).
Data Retention
We retain personal data only for as long as necessary for operational, legal, and safeguarding purposes:
User data: Retained for the duration of the tutoring relationship and up to 6 years thereafter, in line with legal requirements.
Tutor data: Retained for the duration of their engagement and up to 6 years thereafter for audit and safeguarding purposes.
Cookie data: Retention periods vary depending on the type of cookie and User preferences.
Data Security
We take appropriate technical and organisational measures to protect personal data from unauthorised access, loss, or misuse. Payment information is stored securely via compliant third-party processors. Access to personal data is restricted to authorised personnel only. All data stored on our servers in the United Kingdom is encrypted and regularly monitored for security.
Rights of Users
Under the UK GDPR, Users have the following rights:
Right to Access: Request a copy of your personal data.
Right to Rectification: Correct inaccurate or incomplete personal data.
Right to Erasure: Request the deletion of personal data where it is no longer necessary for processing.
Right to Restrict Processing: Limit the use of your personal data under certain circumstances.
Right to Data Portability: Receive personal data in a structured, commonly used, and machine-readable format.
Right to Object: Object to the processing of personal data for legitimate interests or marketing purposes.
Right to Withdraw Consent: Withdraw consent at any time for processing based on consent.
Right to Lodge a Complaint: File a complaint with the Information Commissioner’s Office (ICO) if you believe your rights have been violated.
Automated Decision-Making and Profiling
We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on Users, Tutors or any relevant third-party.
Data Breach Procedures
In the event of a data breach, we will notify affected individuals and the ICO within 72 hours, as required by GDPR. Measures will be taken to contain and rectify the breach promptly.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Users will be notified of any significant updates via our website.
Contact Information
If you have any questions or concerns about this Privacy Policy or your personal data, please contact us at:
Daresne Limited
Registered in England and Wales | Company Number: 16039038
Registered Office: 85 Great Portland Street, First Floor, London, W1W 7LT, United Kingdom
We respect the privacy of all our Users, Tutors, and third parties and are committed to protecting personal information with the highest standards of professionalism and compliance. By accessing our Website, you acknowledge and agree to the practices outlined in this Privacy Policy.
Complaints and ICO Details
If you are unhappy with how we handle your data or would like to escalate a concern, you may contact the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Last updated on: January 7th, 2025
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