Privacy Policy
At Number One Tutor, we are committed to protecting your Personal Data and to providing clear and
transparent disclosures about the types of information we collect and how we use it.
For your further visits to our website and your use of our services, we would like to inform you about data collection, processing and use when visiting and using our website and services. As well as objection, revocation, and other rights to which you are entitled as a person affected by data collection and use.
We would like to ask you to read this policy along with our Cookie Policy and if you are under the age of 16, please read our Privacy Policy for Children.
For your further visits to our website and your use of our services, we would like to inform you about data collection, processing and use when visiting and using our website and services. As well as objection, revocation, and other rights to which you are entitled as a person affected by data collection and use.
We would like to ask you to read this policy along with our Cookie Policy and if you are under the age of 16, please read our Privacy Policy for Children.
General Information
a) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an
identified or identifiable individual. This includes, for example, your name, date of birth, e-mail
address, postal address, or telephone number as well as online identifiers such as your IP address. In
contrast, information of a general nature that cannot be used to determine your identity is not Personal
Data. This includes, for example, the number of users of a website.
b) What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data,
whether or not by automatic means. The term is broad and covers virtually any handling of data.
c) What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection
laws, in particular the EU`s General Data Protection Regulation (“GDPR”) and Bulgaria`s Data
Protection Act (“DPA”), and only as described in this Privacy Policy.
d) Responsible for data processing
Responsible for data processing is Number One Tutor Ltd. of 48 Vitosha Blvd., 1000 Sofia, Bulgaria
(“Number One Tutor”, “we”, “us”, or “our”). We act as the data controller and ask you to direct all
questions about your Personal Data directly to us. You can reach us per WhatsApp on +447722
477150, through our Contact Form or per email using info@numberonetutor.com.
a) Purpose and legal basis of processing
In accordance with the DPA and GDPR we need to have both a purpose and a legal basis to process
Personal Data. The purposes are:
- providing the website and shop and their functions and contents,
- responding to contact requests and communicating with our customers,
- providing our services, and
- security measures.
Of course, we can only do that if we have at least one of the following legal bases or in other words
lawful reasons to do so. Unless specifically described below, we typically link the above purposes to
one of the following:
- consent,
- to fulfil our services and carry out contractual obligations,
- to fulfil our legal obligations, and
- to protect our legitimate interests.
General Principles
a) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the
transmission of confidential content, such as orders, login data or contact requests that you send to us.
You can recognise an encrypted connection if the address line of your browser contains a “https://” instead of a “http://” and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.
Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
You can recognise an encrypted connection if the address line of your browser contains a “https://” instead of a “http://” and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.
Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
b) Minors
We will not knowingly collect, use or disclose personal information from minors without first
obtaining consent from a legal guardian through direct contact.
c) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any
human involvement. Automated decision-making including profiling does not take place.
d) Do Not Sell
We do not sell your Personal Data.
e) Special Category Data
Unless specifically required when using our services and consent is obtained for that particular
service, we do not process special category data.
f) International Transfer
We may transfer your Personal Data to other companies and/or business partners as necessary for the
purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so
called third countries. In order to provide adequate protection for your Personal Data when it is
transferred, we have contractual arrangements regarding such transfers. We take all reasonable
technical and organisational measures to protect the Personal Data we transfer.
g) Storage and retention
Your personal data will be stored by us only for as long as is necessary to achieve the purposes for
which the data was collected or – if statutory retention periods exist that go beyond this point and for
the duration of the legally prescribed retention period. We then delete your personal data. Only in a
few exceptional cases is your data be stored beyond this period, e.g., if storage is necessary in
connection with the enforcement of and defence against legal claims against us.
h) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a)
necessary for the performance of our services, b) you have consented to the disclosure, c) or if we are
legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal
investigations or other legal investigations or other legal proceedings; as required by law or regulation; if Number One Tutor (or a part of Number One Tutor) is sold to or merged with another
company; or proceedings at home or abroad or to fulfil our legitimate interests.
Data we collect automatically
a) Collection of access data and log files
We also collect data on every access to our website. The access data includes the name of the website
accessed, file, date and time of access, amount of data transferred, notification of successful access,
browser type and version, the user’s operating system, referrer URL (the previously visited page), IP
address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website
b) Hosting
To provide our website, we use the services of GoDaddy.com, LLC who process all data to be
processed in connection with the operation of our website on our behalf. The legal basis for the data
processing is our legitimate interest in providing our website.
c) Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your
respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information
please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our
legitimate interest.
Data from third party sources
We may obtain data about you from third-party sources, such as our marketing partners, social
networks, and other third parties. We may use this data to better analyse your user behaviour to
improve our ability to provide you with relevant marketing information and services, and to prevent
and combat fraud.
Data we collect directly
a) General
We may ask you for Personal Data when you:
- use our website,
- request tutoring, services, support, or information,
- participate online or otherwise in marketing activities,
- interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
- contact us.
Categories of Personal Data we collect may include:
- contact data (e.g., names, e-mail, telephone numbers),
- content data (e.g., text entries, messages),
- Identity data (e.g., including name, date of birth, pictures, and videos), and
- contract data (e.g., booking information, lecture details, payment confirmations),
b) Contacting us
Personal Data is processed depending on the contact method. In addition to your name and e-mail
address, IP address or telephone number, we usually collect the context of your message which may
also include certain Personal Data. The Personal Data collected when contacting us is to handle your
request and the legal basis is both your consent and Contract.
We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.
We are present on social media (currently, Facebook, Instagram and YouTube) on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.
We are present on social media (currently, Facebook, Instagram and YouTube) on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
c) When using our services
Whilst we are offering our services to Children, the protection and safety of Children using our
services is our priority. Parents or legal guardians must register, any minor wishing to use our must do
so only through their Parents or legal guardians.
We process your data in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Accordingly, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.
In order to provide our services and support, we may also engage other service providers and third parties (in particular Zoom or Google Meet) and provide access to our employees and independent contractors who are involved in providing the services.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and child protection safeguards strictly.
We process your data in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Accordingly, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.
In order to provide our services and support, we may also engage other service providers and third parties (in particular Zoom or Google Meet) and provide access to our employees and independent contractors who are involved in providing the services.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and child protection safeguards strictly.
d) Payment Data
If you make a purchase your payment will be processed via the payment service provider currently
Revolut Bank. Payment data will solely be processed through Revolut Bank and we have no access to
any Payment Data you may submit. The legal basis for the provision of a payment system is the
establishment and implementation of the user contract for the use of the service.
e) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our operations,
financial accounting and compliance with legal obligations, such as archiving. In this regard, we
process the same data that we process in the course of providing our contractual services. The purpose
and our interest in the processing lies in the administration, financial accounting, office organisation,
archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our
tasks and provision of our services.
f) Marketing
Insofar as you have also given us your consent to process your Personal Data for marketing and
advertising purposes, we are entitled to contact you for these purposes via the communication
channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.
Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.
Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.
Your Rights and Privileges
a) Privacy rights
Under the DPA and the GDPR, you can exercise the following rights:
- The right to access – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete
- The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you have any questions, please contact us.
b) Updating your information
If you believe that the information, we hold about you is inaccurate or request its rectification,
deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
d) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to
requests regarding access and correction as soon as reasonably possible. Should we not be able to
respond to your request within thirty (30) days, we will tell you why and when we will be able to
respond to your request. If we are unable to provide you with any Personal Data or to make a
correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority
responsible for data protection. The Commission for Personal Data Protection is the principle national
supervisory authority in Bulgaria. www.cpdp.bg. The supervisory authority in the UK is the
Information Commissioner`s Office (ICO), which is located at Wycliffe House, Water Ln, Wilmslow
SK9 5AF, UK www.ico.org.uk
Changes
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or
materially change our use of your Personal Data, we will revise the Privacy Policy accordingly.
Questions?
If you have any questions or comments about our Cookie Policy or wish to exercise your rights under
applicable laws, you can reach us per WhatsApp on 07722 477150, through our Contact Form or per
e-mail using info@numberonetutor.com.
e-mail using info@numberonetutor.com.
Effective Date
This Privacy Policy was last updated on Saturday, 25 February 2023
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