Hoolr Education Limited ("we", "our" or "Hoolr") is committed to protecting the privacy of all visitors to our Website hoolr.co.uk and all visitors who access our Website or services through any mobile application (together, "Website").
Please read the following privacy policy which explains how we use and protect your (“you” or “your” refer to any User, no matter whether you are a Tutor or Student) information, as the data controller for the purposes of the GDPR (General Data Protection Regulations EU 2016/679) and related UK legislation.
We reserve the right to modify this notice without notice by posting any changes on our Website.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Category of Personal Data |
Purpose/Activity |
Lawful basis for processing including basis of legitimate interest |
Personal details including name and contact information |
To enable us to register you as a new customer and to enable us to manage and process transactions and our relationship with you. We also use contact information to deliver notifications and relevant marketing materials. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us). (c) Necessary for our legitimate interest (to develop and grow our business). |
Identity verification information |
To enable us to verify the identity of Tutors using the Website and comply with money laundering regulations. |
(a) Performance of a contract with you. (b) To meet our legal obligations. |
Profile details |
Profile details provided by Tutors are used to process Tutor applications to join the site. Some data collected by third parties and automatically generated data (Tutor reviews) are used to assess Tutor’s continuing suitability to use Hoolr, as communicated on Tutor dashboards, in our FAQs and in our t&cs. |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
Credit card information and payment details |
To facilitate transactions including billing Students for Lessons as agent for the Tutor and passing on payments to Tutors for lessons taught. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to be able to take payments for services). |
Location details |
To enable us to fulfil our contract in helping to facilitate matches between Tutors and Students through the Website and to allow us to invoice for Lessons. Anonymised location data is also used to aid us in understanding our user base through analytics. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to be able to provide and take payments for services). |
Special categories of personal information including criminal conviction information |
To enable us to display “Background Checked Status” on Tutor profiles, as described in our t&cs. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interest to be able to assure quality and safe teaching. |
Electronic identification data including IP address and information collected through cookies |
To enable us to analyse the use of the Website and help improve the Website’s usability. |
(a) Necessary for our legitimate interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
User activity details and user preferences |
To enable Users to communicate with other Users of the Website, to facilitate matches between Tutors and Students and to aid our understanding of our User base. User preferences are stored to enable us to comply with user preferences. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
Contractual details including the goods and services provided |
To enable us to facilitate transactions correctly and to fulfil our legal obligations to keep financial records. |
(a) Performance of a contract with you. (b) To meet our legal obligations. |
Device and browser details |
To help us improve the Website’s usability. |
(a) Necessary for our legitimate interest (to enable us to keep our Website updated and relevant, and improve its usability). |
Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a Website. Your browser sends these cookies back to the Website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen. We use cookies for two main purposes:
You may block cookies by activating a setting on your browser that allows you to refuse the setting of all or some cookies. By doing so, you may not be able to access all or parts of our site. For more information please read the advice at AboutCookies.org.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the below.
If you wish to exercise any of the rights set out above, please contact us.
To ensure that we can deal with your request as promptly as possible, please ensure you make your request as clearly as possible.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to request that we send to you or to another organisation, an electronic copy of the personal data we hold about you in a structured, commonly used and machine-readable format, for example when you are dealing with a different service provider.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.
Any changes to our Privacy Policy will be posted to the Website and, where appropriate, via e-mail.
Please do not hesitate to contact us regarding any matter relating to this Privacy and Cookies Policy via email at support@hoolr.co.uk.
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