Full policy

1 Who we are

GemTuition is operated by Joseph O Odegbami, a sole trader trading as GemTuition.

Joseph O Odegbami is the data controller for the personal information described in this notice.

For privacy questions or to exercise your information rights, email info@gemtuition.com.

2 Who this notice covers

This notice applies to pupils, parents and guardians, prospective and approved tutors, website visitors, and people who contact GemTuition. It covers the GemTuition website, Moodle learning platform, tuition booking and payment workflows, online lessons, attendance, grading, communications, tutor applications and safeguarding processes.

3 Information we collect

Account and contact information: names, usernames, email addresses, telephone numbers, country, time zone and account authentication records.

Pupil and parent information: date of birth or age, linked parent or guardian relationships, tuition preferences, subjects, courses, bookings and relevant support information.

Learning and tuition information: lesson participation, attendance, assignments, submissions, grades, tutor feedback, progress records, lesson-delivery outcomes and communications connected with tuition.

Booking and financial information: bookings, prices, payments, refunds, cancellation requests, transaction references and billing records. GemTuition does not receive or store full payment-card numbers; Stripe processes card details.

Tutor application and vetting information: qualifications, experience, subjects, availability, references, identity and right-to-work evidence where relevant, DBS and safeguarding information, declarations, review decisions and audit records.

Technical and security information: IP address, browser and device information, login history, system logs, cookies and records used to secure and operate the service.

Safeguarding and complaint information: concerns, incidents, allegations, communications and actions taken. These records may include sensitive information or information about alleged offences where necessary.

4 How we obtain information

We obtain information directly from account holders, parents, pupils and tutors; from a parent or guardian who creates or links a pupil account; from referees and vetting sources; automatically when the website and learning platform are used; and from service providers involved in payments, communications or lesson delivery.

5 Why we use information and our lawful bases

Contract: to create and administer accounts, provide and book tuition, deliver lessons, record progress, take payment, process cancellations and refunds, and communicate about the service.

Legal obligation: to keep tax and accounting records, respond to lawful requests, meet applicable safeguarding duties and maintain records required by law.

Legitimate interests: to operate and improve GemTuition, match pupils with suitable tutors, manage quality, prevent misuse and fraud, secure systems, investigate complaints and establish or defend legal claims. We balance these interests against the rights of pupils and other users.

Consent: where required for optional marketing, non-essential cookies or another genuinely optional use. Consent may be withdrawn at any time without affecting earlier lawful processing.

Vital interests and substantial public interest: where necessary to protect a person from serious harm or handle safeguarding matters. Criminal-offence and DBS information is processed only where authorised by law and subject to additional safeguards.

6 Children and parental involvement

GemTuition provides services to children. We use children’s information only as needed to provide and safeguard tuition. Parents or guardians normally arrange services and link younger pupils to their accounts. Pupils also have their own information rights. We provide a shorter child-friendly notice alongside this full notice and use brief explanations when sensitive information is requested.

7 Who we share information with

We share only what is necessary with tutors assigned to a pupil or class; parents or guardians linked to a pupil; authorised GemTuition administrators; hosting and infrastructure providers; Stripe for payments; online lesson, email and communications providers; professional advisers, insurers and auditors; and public authorities, regulators, law-enforcement or safeguarding bodies where disclosure is required or necessary.

We do not sell personal information. Tutors and parents must not use information obtained through GemTuition for unrelated purposes.

8 International transfers

The GemTuition website server is located in London, United Kingdom. Some suppliers or their support teams may process information outside the United Kingdom. Where a restricted transfer occurs, GemTuition will use an applicable adequacy regulation or an approved UK transfer mechanism, such as the UK International Data Transfer Agreement or UK Addendum, and any additional safeguards required following a transfer-risk assessment.

9 How long we keep information

We keep information only for as long as needed for the purpose stated, legal obligations, safeguarding, complaints and legal claims. We review records and delete or anonymise them when they are no longer required. The proposed standard periods are listed below; a record may be held longer where a safeguarding concern, dispute, legal hold or statutory requirement applies.

Record category	Standard retention period
General enquiries not followed by registration	12 months after the last contact
Active account and core service records	While the account is active, then 6 years after closure or the last transaction
Bookings, invoices, payments, refunds and accounting records	6 years after the end of the relevant financial year
Learning, attendance, grading and lesson-delivery records	6 years after the tuition relationship ends; earlier anonymisation where practical
Routine platform messages and support correspondence	3 years after the matter closes, unless linked to a contract, complaint or safeguarding matter
Security and access logs	Normally 12 months; longer where required to investigate an incident
Unsuccessful tutor applications and ordinary recruitment notes	6 months after the final decision
DBS certificate copies or images	Not normally retained; if exceptionally necessary, no longer than 6 months after the decision. A limited record of the check, date, level, reference and decision may be retained
Approved tutor qualification, reference and vetting records	For the engagement and 6 years afterwards, subject to periodic review and minimisation
Right-to-work evidence where a statutory retention duty applies	For the engagement and 2 years afterwards
Safeguarding concerns and allegations	According to the nature of the case and applicable safeguarding guidance; ordinarily until the pupil reaches age 25, or 6 years after the matter closes if later, with longer retention where required for an allegation, inquiry or legal claim
Consent and suppression records	For as long as needed to demonstrate the choice or ensure the person is not contacted
Backups	Removed through the normal backup rotation, ordinarily within 90 days after deletion from live systems

10 Security

We use role-based access, account authentication, restricted tutor and administrator workflows, encrypted web connections, server-level monitoring and security controls, software updates, backups and audit records appropriate to the information and risk. No online system is completely secure. Users should keep login details confidential and tell us promptly about suspected misuse.

11 Your rights

Depending on the circumstances, you may ask for access to your information, correction, deletion, restriction, portability, or objection to processing. You may withdraw consent where consent is the lawful basis. You may also ask for information about safeguards used for an international transfer.

Email info@gemtuition.com. We may need to verify identity and authority, particularly where a parent requests information about a pupil. You may complain to the UK Information Commissioner’s Office at ico.org.uk, but we would welcome the opportunity to address the concern first.

12 Cookies

GemTuition uses necessary cookies to provide login, security and platform functions. Any analytics, advertising or other non-essential cookies will be used only after the required choice or consent has been obtained. A separate cookie notice should identify the cookies actually enabled on the live website.

13 Changes to this notice

We may update this notice when services, suppliers or legal requirements change. The current version and update date will be published on the GemTuition website. We will provide a prominent notice where a change materially affects how information is used.

GemTuition Privacy Notice for Pupils

This is a shorter guide. The full notice above has more detail. Ask an adult for help if anything is unclear.

Who looks after your information

GemTuition is run by Joseph O Odegbami. You or your parent can email info@gemtuition.com with a privacy question.

What information we use

We use your name, account details, lessons, attendance, schoolwork, grades, tutor feedback and messages about your tuition. We also keep information needed to keep your account and lessons safe.

Why we use it

We use this information to arrange and deliver your tuition, show your progress, help your tutor teach you, keep the service secure and help protect you from harm.

Who can see it

Your parent or guardian, your assigned tutor and authorised GemTuition administrators may see the information they need. Companies that securely run our website, lessons, email and payments may also process limited information for us.

What we do not do

We do not sell your information. We do not let tutors use it for unrelated reasons. Stripe handles card details, so GemTuition does not store full card numbers.

Your choices and rights

You can ask what information we have about you. You can ask us to correct something that is wrong, and sometimes to delete it or stop using it. Ask a parent or trusted adult to help if you wish, or email info@gemtuition.com.

If something worries you

Tell your parent, tutor or another trusted adult. You can also contact GemTuition. If we believe someone may be at risk of harm, we may need to share information with people whose job is to keep them safe.

How long we keep it

We keep your information only while it is needed for tuition, safety, legal records or a complaint. The full notice explains the time limits.

Need help

Email info@gemtuition.com.