Privacy and cookies policy

Introduction

1.1 TutorShell is owned by Spaising Technologies LLP. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.

1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.5 In this policy, “we”, “us” and “our” refer to Spaising Technologies LLP . For more information about us, see Section 17.

The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

2.3 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

2.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the profile data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the profile data from the relevant social media account provider.

2.5 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (“service data”). The service data may include [specify data]. The source of the service data is you and/or your employer and/or our services.

2.6 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.7 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.8 We may process [identify general category of data]. This data may include [list specific items of data]. The source of this data is [identify source].

2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations – We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3 Publications – We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.

3.4 Relationships and communications – We may process contact data, account data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of relationships, and the proper administration of our website, services and business.

3.5 Personalisation – We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.

3.6 Direct marketing – We may process contact data, account data and profile data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.

3.7 Research and analysis – We may process usage data and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.9 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.10 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

Automated decision-making

4.1 We will use your personal data for the purposes of automated decision-making in relation to appropriate suggestions, recommendations, bug fixing, issue resolution and other in application automations

Providing your personal data to others

5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for technical purpose including but not limited to issue resolution, hosting, data backup and other similar technical purposes.

5.4 We may disclose contact data along with any other personal data contained in enquiries made through our website or services to one or more of those selected third party suppliers of goods and/or services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the personal data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum period of eighteen months following the date of the most recent communication between you and us, and for a maximum period of ten years following that date;

(b) account data will be retained for a minimum period of eighteen months following the date of closure of the relevant account, and for a maximum period of ten years following that date;

(c) profile data will be retained for a minimum period of eighteen months following the date of deletion of the profile by you, and for a maximum period of ten years following that date;

(d) service data will be retained for a minimum period of eighteen months following the date of termination of the relevant contract, and for a maximum period of ten years following that date;

(e) communication data will be retained for a minimum period of eighteen momnths following the date of the communication in question, and for a maximum period of ten years following that date; and

(f) usage data will be retained for ten years following the date of collection.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Third party websites

7.1 Our website includes hyperlinks to, and details of, third party websites.

7.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

Personal data of children

8.1 Our website and services are targeted at persons over the age of 18.

8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we may delete that personal data.

Updating information

9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

Acting as a data processor

10.1 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

11. About cookies

11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

12.1 We use cookies for the following purposes:

(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b) personalisation – we use cookies to store information about your preferences and to personalise the website for you;

(c) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d) advertising – we use cookies to help us to display advertisements that will be relevant to you;

(e) analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(f) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

13.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

13.3 We publish Google AdSense advertisements on our website. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies. The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google’s personalised advertising by visiting https://www.google.com/settings/ads and you can opt out of third party cookies use for personalised advertising by visiting http://www.aboutads.info. You can review Google’s privacy policy at https://policies.google.com/privacy.

13.4 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

Managing cookies

14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

14.2 Blocking all cookies will have a negative impact upon the usability of many websites.

14.3 If you block cookies, you will not be able to use all the features on our website.

Cookie preferences

15.1 You can manage your preferences relating to the use of cookies on our website.

Amendments

16.1 We may update this policy from time to time by publishing a new version on our website.

16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

16.3 We will notify you of significant changes to this policy by email.

Our details

17.1 This website is owned and operated by Spaising Technologies LLP.

17.2 We are registered in India, and our registered office is at SPAISING TECHNOLOGIES LLP Megapolis, Splendour, A – 15, F – 1304, Pune, Pune, Maharashtra, 411057, India.

17.3 Our principal place of business is at SPAISING TECHNOLOGIES LLP Megapolis, Splendour, A – 15, F – 1304, Pune, Pune, Maharashtra, 411057, India..

17.3 You can contact us using our website contact form