# Privacy and personalisation notice
Updated 27 August 2026.
On this page
- At a glance
- Who is responsible for your information
- For young people
- Information we use and why
- Where information comes from
- Why we may use information
- Health, SEND and safeguarding information
- Who receives information
- International transfers
- How long we keep information
- How we protect information
- Cookies and information stored on your device
- How AI helps
- Marketing
- Your rights
- Questions and complaints
- Changes to this notice
This notice explains how TUTORS.GG LTD uses personal information about Payers, guardians, learners and website visitors. It includes a short explanation for young people, our cookie and device-storage information, and how we use AI. Tutors, markers and applicants receive role-specific privacy information at the point we collect their information.
At a glance
- TUTORS.GG LTD is responsible for the personal information described here.
- An adult Payer buys the service, but a learner keeps their own privacy rights.
- We use only the information needed to supply, protect and improve the service, meet legal duties and honour genuine choices.
- We do not sell personal information.
- We do not use child information for advertising.
- We do not use a child's information to train AI models.
- A person makes final safeguarding, money, guarantee and academic-claim decisions.
- Email privacy@tutors.gg to ask a question or exercise a privacy right.
Who is responsible for your information
TUTORS.GG LTD is the controller of the personal information covered by this notice.
Company number: 15313334
Registered office:
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Privacy contact: privacy@tutors.gg
We use a Privacy Lead. We do not claim to have appointed a statutory Data Protection Officer unless and until that appointment is formally made.
For young people
This part is for learners. You can read it yourself or ask a trusted adult to read it with you.
What we know about you
We keep information that helps us teach you, understand your work and keep you safe. This may include your name inside tutors.gg, the subject you study, your answers and work, lesson bookings, messages, recordings and progress evidence.
We do not need your home address, personal phone number, live location or social-media account to teach you. Do not put private information into a message or upload unless we have clearly asked for it.
Lesson recordings
Child lessons are recorded. You will see a clear signal when recording is on. We use recordings to protect people, check what happened when there is a concern and provide reliable evidence of delivery. We do not run a child lesson without recording.
Your Payer can see information about your lessons. Only authorised people can access a recording, and they must have a proper reason.
AI
Some features use AI to help organise information or draft an explanation. We tell you when AI is helping. AI can be wrong, so you can ask a person to check, explain or correct its work.
AI does not make the final decision about your safety, money, a guarantee or an academic claim. We use a code instead of your identity when information is sent to an AI provider. We do not send your name, contact details, date of birth, school, home address, health information or safeguarding notes to an AI model. We do not let AI providers train their models on your information.
Your choices and rights
You have privacy rights even though an adult pays for tutors.gg. You can ask what information we hold, ask us to correct it or ask us to delete it. Sometimes we must keep information to protect someone or follow the law. A person will explain the decision.
You can email privacy@tutors.gg or ask a trusted adult to help. We will explain the answer in a way you can understand.
Information we use and why
The table below maps each use to its source, lawful basis, normal recipients and retention rule. A provider receives only the information needed for its job. Where a provider processes information outside the UK, the transfer section below applies.
| Information and source | Purpose | Lawful basis | Normal recipients | Normal retention |
|---|---|---|---|---|
| Payer account, identity and contact details, provided by the Payer | Create the account, authenticate the Payer, communicate about the service and provide support | Contract; legitimate interests for account security | Authentication, hosting, email and support providers; authorised tutors.gg staff | Active account plus 12 months; contract evidence for six years where required |
| Guardian authority and family relationship, provided by a guardian and verified by us | Give the correct adult access and keep payment and consent authority with the Payer | Contract for the Payer; legitimate interests in safe family access for other people | Authentication and hosting providers; authorised support and privacy staff | Active account plus 12 months; disputed authority evidence for up to six years |
| Learner identity, subject, exam route, preferences and approved profile fields, provided by the family, learner and service activity | Deliver and personalise tutoring and learning support | Legitimate interests, balanced with the child's rights and best interests | Assigned tutor; hosting provider; authorised tutors.gg staff | Active service or account plus 12 months, unless valid deletion happens sooner |
| Answers, uploaded work, marks, feedback, recaps, reports and progress evidence, provided by the learner, family, tutor or marker | Deliver tutoring and marking; explain progress; keep an accurate learning record | Legitimate interests, balanced with the child's rights and best interests | Assigned tutor; pseudonymised marker; hosting and secure-storage providers; authorised tutors.gg staff | Active service or account plus 12 months; other identifiable working files for delivery plus 90 days |
| Lesson bookings, attendance and outcome, created through the service | Arrange and prove delivery; apply booking rules; resolve disputes | Contract for the Payer's booking; legitimate interests for learner delivery and service integrity | Assigned tutor; scheduling, hosting and support providers; authorised tutors.gg staff | Active service or account plus 12 months; longer only where needed as contract or complaint evidence |
| Raw child-lesson recording, collected during the lesson | Protect learners; review concerns; verify delivery | Legitimate interests in safe, reviewable delivery, balanced with the child's rights | Live-video and secure-storage providers; specifically authorised safeguarding or support staff; the Payer where appropriate | 90 days; necessary evidence may be isolated under a documented safety, complaint or legal hold |
| Raw lesson transcript, generated during the bounded recap process | Produce the lesson recap and proof-report draft | Legitimate interests in delivering the requested learning record, with data minimisation and human review | Bounded transcription and AI providers; authorised tutors.gg staff | Deleted when the bounded recap completes; not retained as learner-record data |
| Ordinary messages and support requests, provided by account users and our team | Deliver the service, answer questions and resolve problems | Contract for Payer service requests; legitimate interests for learner support and service administration | Hosting and support providers; assigned tutor where the message concerns their lesson; authorised tutors.gg staff | Active service or account plus 12 months; a formal complaint follows the complaint period below |
| Order, payment, refund, subscription and VAT records, provided by the Payer, payment provider and our systems | Take payment, manage plans and remedies, prevent fraud, keep tax and accounting records | Contract; legal obligation; legitimate interests in fraud prevention | Payment provider; finance, accounting and tax providers; authorised tutors.gg staff | Six years after the relevant contract or financial year ends, whichever is later |
| Security events, IP address, browser/device information and rate-limit records, generated by use of the service | Keep accounts and the service secure; prevent fraud and abuse | Legitimate interests in security and fraud prevention; legal obligation where applicable | Hosting, authentication and security providers; authorised tutors.gg staff | Rate-limit records for 24 hours; ordinary logs for 30 days; documented incidents for up to 12 months |
| Ordinary safeguarding report, held content and case decisions, provided by a reporter or generated through review | Protect a child or person at risk; investigate and report concerns | Legitimate interests, balanced with the child's rights; where the law requires a report or record, legal obligation | Named safeguarding staff; tightly restricted hosting/storage providers; police, social care, National Crime Agency or another authority where required | Until the learner's 25th birthday or ten years after closure, whichever is later; child-sexual-abuse cases until the learner's 75th birthday |
| Special-category or criminal-offence information in a safeguarding case | Protect a child or individual at risk and make a necessary safeguarding referral | Legitimate interests under Article 6; substantial public interest under Article 9 and the safeguarding-of-children-and-individuals-at-risk condition in Schedule 1 to the Data Protection Act 2018; criminal-offence information is handled under Article 10 and the same statutory safeguarding condition | Named safeguarding staff; tightly restricted hosting/storage providers; police, social care, National Crime Agency or another authority where required | The safeguarding-case period above |
| Information needed during an immediate threat to life or physical safety | Protect the person during the emergency | Vital interests under Article 6 and, for special-category information, vital interests under Article 9 where the person is physically or legally incapable of consent | Named safeguarding staff and emergency services | Added to the safeguarding case only where necessary; otherwise kept only for the incident record |
| Functional adjustment request that does not reveal health or disability information | Provide equal access or change how we deliver the service | Legal obligation to make reasonable adjustments; legitimate interests in accessible delivery | Assigned tutor and authorised support staff on a need-to-know basis; restricted hosting provider | Active service or account plus 12 months, unless valid deletion happens sooner or a shorter period is appropriate |
| Optional health, disability or SEND detail voluntarily provided by the Payer or competent learner | Tailor a requested adjustment where functional information alone is not enough | Consent under Article 6 and explicit consent under Article 9 | Assigned tutor and authorised support staff on a need-to-know basis; restricted hosting provider | Until consent is withdrawn, the adjustment ends or the active service/account plus 12 months period ends, whichever is sooner, unless a legal hold applies |
| Information needed to establish, exercise or defend a legal claim | Handle the specific claim and preserve necessary evidence | Legitimate interests under Article 6; establishment, exercise or defence of legal claims under Article 9 where special-category information is necessary | Authorised tutors.gg staff, legal advisers, insurers, courts or authorities | Only for the applicable claim and limitation period |
| Terms, privacy, consent and choice records, generated when a notice or choice is shown | Honour the choice and prove what applied | Contract; legal obligation; legitimate interests in accountable record-keeping | Hosting provider; authorised privacy, support and compliance staff | With the related contract or processing record; normally up to six years where it is legal or contract evidence |
| Adult marketing choice and contact details, provided by the adult | Send the marketing the adult chose and honour withdrawal | Consent | Email or messaging provider; authorised marketing staff | Until withdrawal or the purpose ends; a minimal suppression record is kept so the opt-out remains effective |
| Necessary cookie and device-storage data, generated by the browser or service | Maintain a requested session, secure the service and complete checkout | Legitimate interests and the PECR strictly-necessary exception | Hosting, authentication, security and payment providers | The duration shown in the live device-storage inventory |
We do not collect a child's live location, social-comparison data or lifestyle tracking. We do not keep raw lesson transcripts as learner-record data. We do not put results-slip images into database text, prompts, logs, email or analytics.
Where information comes from
We receive information:
- directly from the Payer, guardian, learner or website visitor;
- from activity inside tutors.gg, such as a lesson, message or completed task;
- from payment, identity, communications and video providers working for us;
- from public records where a legal or fraud check reasonably requires it.
If someone gives us information about another person, they must have authority to do so and should show that person this notice where appropriate.
Why we may use information
UK data-protection law requires a lawful basis for each purpose.
Contract
We use contract where processing the Payer's information is objectively necessary to provide what the Payer bought, manage the order or deliver an account feature they requested.
The learner is not a party to the Payer's contract. We do not automatically use the Payer's contract as the legal basis for the learner's information.
Legitimate interests
We use legitimate interests for necessary learner delivery, service security, fraud prevention, safety, limited service improvement and the reliable operation of tutors.gg where those interests are not overridden by a person's rights.
For a learner, we give the child's rights and best interests primary weight. We use high-privacy defaults, limit access and keep meaningful human oversight. A person can object to this use and ask us to reconsider it.
Our legitimate interest in recording child lessons is safe, reviewable delivery. Recording is a required feature of a child lesson, not an optional marketing choice. We explain it before booking and show the learner when it is happening. If recording cannot take place, the lesson does not run.
Legal obligation
We use information where necessary to meet tax, accounting, consumer, employment, online-safety, safeguarding, court or regulator duties.
Consent
We use consent for optional marketing, non-essential device storage and a genuinely optional feature where consent is the appropriate basis. Consent is not bundled into buying the service. It can be withdrawn as easily as it was given.
We never ask a child to consent to marketing. Withdrawing consent does not make earlier lawful use unlawful.
Vital interests
In an emergency, we may use information where necessary to protect someone's life or physical safety.
Health, SEND and safeguarding information
Information about health or disability is special-category information. SEND or safeguarding information may be special-category, criminal-offence or ordinary personal information depending on what it reveals. We collect it only where it is necessary for a specific adjustment, delivery need or safety purpose.
The purpose-by-purpose table above states the Article 6 basis and, where required, the Article 9, Article 10 or Data Protection Act 2018 condition. We do not use one blanket condition for all sensitive information.
We normally ask for the functional adjustment a person needs rather than a diagnosis. If optional health, disability or SEND detail is genuinely useful, we ask for explicit consent and restrict access. We do not send health, SEND or safeguarding information to an AI model.
Who receives information
Only people who need information for their role receive it. This may include:
- the Payer and authorised guardian;
- the learner, in an age-appropriate form;
- the tutor assigned to the learner;
- a marker receiving pseudonymised work;
- authorised tutors.gg safeguarding, support, finance, privacy and operations staff;
- service providers for hosting, authentication, payments, email, live video, secure storage, customer support and AI processing;
- professional advisers, insurers and auditors under confidentiality duties; and
- police, the National Crime Agency, social care, courts, regulators or other authorities where the law or immediate safety requires it.
A marker does not receive a learner's contact details or have access to lesson rooms or messages. Providers may use information only under our instructions and contracts unless the law makes them an independent controller for a specific activity.
We do not sell personal information or let another company use child information for its own advertising.
Our current core service providers are:
| Provider | What it does for tutors.gg |
|---|---|
| Cloudflare | Runs the website and application, protects traffic, queues background work and stores files in our EU R2 buckets |
| Neon | Hosts the PostgreSQL service database |
| Stripe | Processes family payments, subscriptions, refunds and tutor payouts |
| LiveKit | Carries live lesson audio and video and sends lesson-room events |
| Resend | Sends service and support email |
| PostHog EU Cloud | Receives pseudonymous server-side service and AI-cost events. On the public website, it receives only Grade Roadmap button clicks after a visitor accepts analytics. We send the broad page category and button position, but not the page address, query string, referring page, session or device details, automatic clicks, errors, recordings or form data. Declining or withdrawing sends no optional website analytics to PostHog. Server-side service and AI-cost events continue. |
| OpenAI API | Produces bounded AI-assisted drafts, recommendations and marking proposals from minimised or pseudonymised inputs |
These providers receive only the information needed for their job. Some act as independent controllers for limited purposes, such as Stripe's legal and fraud duties. Their own privacy information explains those uses.
International transfers
Some providers may process information outside the United Kingdom. Before a restricted transfer, we require an approved safeguard such as:
- UK adequacy regulations;
- the UK International Data Transfer Agreement;
- the UK Addendum to the EU Standard Contractual Clauses; or
- another transfer mechanism permitted by UK law.
We assess the transfer and apply additional technical or contractual measures where necessary. Email privacy@tutors.gg to ask about the safeguard used for a particular provider or transfer.
How long we keep information
We delete or anonymise information when its approved period ends unless a specific legal, safeguarding, complaint or court hold requires us to isolate part of it for longer.
| Information | Normal maximum period |
|---|---|
| Rate-limit records | 24 hours |
| Ordinary security logs | 30 days; up to 12 months for a documented incident |
| Anonymous start answers and unconverted enquiries | 90 days after last activity |
| Remembered guest personalisation | 90 days after the person asks us to remember it; otherwise the current session only |
| Contract, order, payment, refund and tax records | Six years after the relevant contract or financial year ends, whichever is later |
| Learner profile, ordinary messages and learning evidence | While the service or account is active, then 12 months, unless valid deletion happens sooner |
| Confirmed results-slip image | For the report lifetime: while the service or account is active, then 12 months, unless valid deletion happens sooner |
| Other identifiable papers and working files | Until delivery is complete, then 90 days, unless valid deletion happens sooner |
| Raw lesson recording | 90 days; only necessary evidence is isolated for a documented safety, complaint or legal hold |
| Raw lesson transcript | Until the bounded recap completes, then deleted; it does not become the learner record |
| Safeguarding case | Until the learner's 25th birthday or ten years after closure, whichever is later; child-sexual-abuse cases are kept until the learner's 75th birthday |
| General complaint or support case | Three years after closure; six years where it is evidence for a contract, payment or legal claim |
We may shorten a period where we can safely do so. A longer period must be required by a specific legal or documented safeguarding need. It is not enough to keep information "just in case".
How we protect information
We use access controls, encryption, audit records, role separation and retention controls appropriate to the information and risk. We restrict child information to authorised people and use pseudonymous identifiers in analytics, events and AI processing.
No internet service can promise perfect security. If we suspect a breach, a person investigates it, contains it and decides whether affected people, the ICO or another authority must be told.
Cookies and information stored on your device
Cookies and similar technologies include browser cookies, local storage, session storage and identifiers used by software development kits.
Some storage is necessary to:
- keep you signed in and maintain the current session;
- protect forms, accounts and payments from fraud or misuse;
- remember a choice you explicitly ask us to remember; and
- complete a checkout or another feature you request.
Necessary technology does not require optional consent, but we still explain it. Session items normally end when the session or browser closes. Security, authentication and payment items last only as long as needed for their stated purpose.
The public website loads non-essential analytics from PostHog EU Cloud only after you choose Accept. It sends only Grade Roadmap button clicks, the broad page category and the button position. It does not send pageviews, campaign parameters, page addresses, query strings, referring pages, session or device details, automatic clicks, errors, recordings or form data.
If you choose Decline, the public website sends no optional analytics to PostHog. You can use Manage analytics on every page to change your choice. Withdrawing consent takes effect immediately: we clear the PostHog cookie, local storage and browser identifier. If you accept again later, the browser gets a new random identifier. This does not remove storage that is necessary for security, sign-in, payment or another feature you request.
We do not load advertising, session replay or third-party experimentation.
The current browser-storage inventory is:
| Item | Purpose | Normal lifetime |
|---|---|---|
| Secure tutors.gg session cookie | Keeps a signed-in account authenticated and protected | Browser session, or up to 14 days when the account holder asks to stay signed in |
| Security, rate-limit and checkout tokens | Protects forms, accounts and payments and completes a requested checkout | Session or the provider's short fraud-prevention period |
| Remembered theme and family preference | Applies a choice made on that device | Until the person clears or changes it |
| Current Roadmap, account and assistant step | Lets the person continue the current task in the same tab | Current browser tab session |
| Local interface state, such as recent destinations or panel size | Restores a local interface choice; it does not become a marketing profile | Until the person clears the site data |
| Analytics consent choice | Remembers whether you accepted or declined analytics cookies | Until the person clears or changes it |
| PostHog persistence cookie, local storage and random browser identifier (only after Accept) | Connects permitted Grade Roadmap button clicks from the same browser without creating a person profile | Up to 90 days; removed immediately after Decline |
We review this inventory against the deployed service when browser storage changes.
You can clear browser storage through your browser settings. Doing so may sign you out or remove a choice you asked us to remember.
How AI helps
AI-assisted features may help us:
- organise learning information;
- draft a recap or explanation;
- suggest practice or a next step;
- assist with redaction, classification or routing; and
- help a human review service information.
We disclose AI where it is used. We send the minimum information needed and use a pseudonymous identifier instead of a child's identity. OpenAI does not use API inputs or outputs to train its models by default. Its standard abuse monitoring logs may retain API inputs and outputs for up to 30 days unless a shorter approved retention control applies.
We do not send a child's name, contact details, date of birth, school, home address, health information, SEND information or safeguarding notes to an AI model. A raw lesson transcript may pass only through the bounded recap process; it is not kept afterwards as learner-record data.
AI output can be incomplete or wrong. A person makes the final safeguarding, money, guarantee and academic-claim decision. You may ask us to explain, correct or have a person review an AI-assisted output by emailing privacy@tutors.gg or using the support route beside the feature.
We do not make a solely automated decision that has a legal or similarly significant effect on a learner.
Marketing
We do not market to children.
We send marketing to an adult only where we have a lawful basis. Where consent is required, the choice is voluntary, specific and separate from buying the service. Every marketing message explains how to unsubscribe. An unsubscribe suppresses future marketing across our channels, although we may still send necessary service messages.
We keep a minimal suppression record so we can honour the request.
Your rights
Depending on the circumstances, you may have the right to:
- receive a copy of your personal information;
- correct inaccurate or incomplete information;
- ask us to delete information;
- restrict how we use information;
- object to use based on legitimate interests or direct marketing;
- receive certain information in a portable format;
- withdraw consent; and
- ask for human intervention where automated decision rules apply.
A learner has their own rights. We respond in an age-appropriate way and consider the learner's understanding, best interests and circumstances. A guardian does not automatically override a competent learner's rights.
Email privacy@tutors.gg. Tell us which right you want to use and enough information to find the relevant record. Do not email identity documents unless we ask for them through a secure route.
We may need to check identity and, for a guardian request, authority. We respond without undue delay and, at the latest, within one month. The law may allow extra time for a complex request or several requests; if so, we will explain the extension within the first month.
We do not charge for an ordinary request. We may charge a reasonable fee or refuse a request only where the law allows, such as a manifestly unfounded or excessive request. A person checks every deletion request against legal, financial and safeguarding holds. We do not automatically delete or automatically refuse it.
Questions and complaints
Email privacy@tutors.gg if you have a question, concern or complaint. We will acknowledge a privacy complaint within two working days and aim to give a substantive response within ten working days. If an investigation needs more time, we will explain why and when you will hear from us again.
You can also complain to the Information Commissioner's Office:
- website: ico.org.uk;
- telephone: 0303 123 1113; or
- post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
We would appreciate the chance to address the concern first, but you do not have to contact us before contacting the ICO.
Changes to this notice
We update this notice when our processing or the law changes. A material change is explained clearly and, where appropriate, shown before it takes effect. We do not use a new notice to make an earlier unlawful use lawful.
We keep evidence of the notice and choices shown at relevant collection and purchase points.