1. INTRODUCTION
1.1. Dragonfly Tuition Limited respects your privacy and is committed to protecting your personal data. This data protection policy will inform you as to how we look after your personal data and tells you about your data protection rights and how the law protects you.
1.2. Dragonfly Tuition Limited is registered as a data processor with the ICO (Registration Number ZB604929).
1.3. Definitions:
1.3.1. Lawful Basis means one of the following:
● Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
● Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
● Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
1.3.2 Internal Third Parties means the Company’s employees and directors and self-employed tutors engaged in the provision of Tuition Services for the Company acting as processors or joint controllers.
1.3.3 External Third Parties mean one or more of the following:
● Service providers acting as processors based the UK who provide IT, payment and administration services.
● Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
● HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
2. DATA PRIVACY MANAGER
2.1. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this data protection policy. If you have any questions about this data protection policy, including any requests to exercise your legal rights, please contact Claire Callinan using the following details:
Claire Callinan: Clairecallinan@dragonflytuition.co.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. CHANGES TO THE DATA PROTECTION POLICY AND YOUR DUTY TO INFORM US OF CHANGES
3.1. We keep our data protection policy under regular review.
3.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. THE DATA WE COLLECT ABOUT YOU
4.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
4.2. We may collect, use, store and transfer different kinds of personal data about you and your student/s which we have grouped together as follows:
● Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
● Contact Data includes billing address, delivery address, email address and telephone numbers.
● Financial Data includes bank account and payment card details.
● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
● Lesson Data includes information regarding your marks, scores and progress relating to the Tuition Services we provide.
4.3 We do not collect any Special Categories of Personal Data about you or students (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. HOW IS YOUR PERSONAL DATA STORED?
5.1. We use different methods to store data from and about you including through: FreeAgent- a cloud- based accounting software. Computer and Mobile devices of Dragonfly Tuition and the self-employed tutors , including communications made via social media platforms such as WhatsApp and Messenger.
6. HOW WE USE YOUR PERSONAL DATA
6.1. We will only use your personal data (which shall include the personal data of the student or) when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
6.1.1. Where we need to perform the contract, we are about to enter into or have entered into with you.
6.1.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
6.1.3. Where we need to comply with a legal obligation.
6.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1. We will use your personal data for the purposes of the provision of Tuition Services and all reasonably related purposes.
7.2. 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.
Reviewed and Updated : 28/07/25
8. MARKETING
8.1. We want to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and any marketing emails will always include the ability to opt out.
8.2. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
8.3. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
8.4. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the provision of Tuition Services.
9. DISCLOSURES OF YOUR PERSONAL DATA
9.1. We may share your personal data with Internal and External Third Parties for the purposes of the provision of Tuition Services and related activities.
9.2. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this data protection policy.
9.3. We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9.4. We do not transfer your personal data outside the United Kingdom.
10. DATA SECURITY
10.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
10.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. DATA RETENTION
11.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
11.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 11.3. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
11.4. In some circumstances you can ask us to delete your data: see your legal rights below for further information.
11.5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. YOUR LEGAL RIGHTS
12.1. You have rights under data protection laws in relation to your personal data as set out below.
12.2. 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 could refuse to comply with your request in these circumstances.
12.3. 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.
12.4. We try to respond to all legitimate requests within one month. Occasionally i it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12.5. You have the right to:
● Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
● If you want us to establish the data’s accuracy.
● Where our use of the data is unlawful, but you do not want us to erase it.
● Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
● You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.