GDPR Policy

Policies » GDPR Policy

Last Updated: 18 September 2025

Shani’s Tutoring Ltd is committed to protecting the privacy and personal data of everyone who uses our services. Privacy means respecting your information, keeping it secure, and using it only in ways that are lawful, fair, and transparent.

This policy explains the standards, responsibilities, and procedures that apply to all matters of data protection within Shani’s Tutoring. It covers all aspects of our work, including live online tutoring, face-to-face sessions, lectures, online courses, community spaces, and the Learning Hub. Personal data may be collected directly through your use of our platforms or disclosed to staff during the course of our work. In all cases, information will be handled responsibly and in line with this policy.

Everyone connected with Shani’s Tutoring has a role to play in protecting data. This includes, but is not limited to, staff, students, parents, guardians, affiliates, and school representatives. By using our services or working on our behalf, you agree to uphold the principles and practices set out in this policy.

You may be asked to actively agree to this policy before gaining access to the full range of our platforms and services. This policy may be updated when required. Any new version will be published on our website and Learning Hub, with notifications sent to staff, students, and community members where appropriate. The most recent version always applies.

Data Controller

Shani’s Tutoring Ltd

323 Bury Street West, London, N9 9JW

ICO Registration Number: ZB992152

Email: shani@shanistutoring.com

Table of Contents

1. Data we collect

Shani’s Tutoring collects personal data so that we can provide high-quality educational services, keep our platforms safe, and meet our legal responsibilities. We only collect information that is necessary for these purposes, and we handle it with care.

We may collect the following categories of personal data:

Identity data

Student names
Parent/guardian names (for under-18s)
Date of birth (to confirm the age and safeguarding requirements)

Contact data

Email addresses
Telephone numbers
Billing addresses (for payment purposes)

Account data

Usernames and login details for the Learning hub and related platforms (passwords are stored securely and not visible to us)

Profile data

Display names, avatars, profile pictures, short biographies, interests, settings, and preferences

Academic data

Assessment results
Coursework, homework, essays and feedback
Attendance and participation records (including Zoom session logs)

Community and content data

Forum posts, comments, reactions, private messages, shared files, polls, and uploads
Logs of user activity within community spaces (e.g. post creation, replies, edits, deletions)
Records of reported content, moderation actions, and enforcement of community standards

Financial data

Payment records processed via Stripe (we do not store card details)
Affiliate payment information (names, contact details, bank/PayPal details)

Technical data

IP addresses
Device and browser type
Cookies and usage data from our website and learning platforms

Communication data

Emails and newsletters
Support queries (via FluentSupport or other tools)
Chat logs from the Learning Hub forums, discussions or Zoom sessions

Safeguarding data

Any safeguarding concerns, reports, or incident notes recorded in line with our safeguarding obligations

Media data

Audio, video, and image recordings of online sessions (including user voices, faces, and shared screens)
Screenshots of recordings of lessons where necessary for safeguarding, training, or service delivery

2. How we use your data

Shani’s Tutoring uses personal data to deliver services, keep our platforms safe, and meet our legal duties. Each type of data is collected for specific purposes, as set out below:

Identity and contact data

To register students and parents for tutoring services
To confirm ages and apply safeguarding measures
To communicate about lessons, updates, and policies
To enable compliance with our Safeguarding Policy and statutory safeguarding duties

Account and profile data

To create and manage user accounts on the Learning Hub, WordPress, and community spaces
To personalise learning experiences and community participation
To maintain secure login and access systems
To enable compliance with our Safeguarding Policy and statutory safeguarding duties

Community and content data

To enable participation in forums, discussions, and community spaces
To support collaboration and peer learning
To enforce community rules, investigate misuse, and moderate discussions
To investigate and respond to safeguarding concerns, in line with our Safeguarding Policy

Financial data

To process course payments and subscriptions via Stripe
To manage affiliate referrals, commissions, and financial records
To comply with HMRC and other financial regulations

Technical data

To operate and secure our websites and learning platforms
To monitor site performance and fix errors
To analyse usage trends and improve user experience

Communication data

To respond to support requests and enquiries
To send newsletters and marketing emails (only with your consent)
To record logs of important correspondence for safeguarding or service delivery

Safeguarding data

To protect students and other users from harm, abuse, neglect, exploitation, or bullying
To record and respond appropriately to safeguarding concerns, in line with our Safeguarding Policy and statutory duties
To comply with legal and statutory safeguarding requirements

Media data

To provide access to recorded lessons and training materials
To ensure quality and accountability in teaching
To support safeguarding monitoring and compliance with our Safeguarding Policy

2.1 Lawful bases for processing

We rely on the following lawful bases under UK GDPR:

Contract – where data is necessary to deliver tutoring services, manage accounts, or process payments.
Legal obligation – for safeguarding, child protection, and financial record-keeping.
Consent – for newsletters, marketing emails, and the use of recordings for training or promotional purposes.
Legitimate interests – to improve our services, secure our systems, and manage online communities.
Vital interests – in rare cases where data must be used to protect someone from serious harm.

Shani’s Tutoring shares personal data only with trusted third-party providers who help us deliver our services. We do not sell or rent your personal information to advertisers.

We may share data with:

Payment processing

Stripe (secure payment collection)
PayPal (where chosen for affiliate payments)
Klarna (alternative payment methods)

Learning and account management

Moodle (online learning platform for the Learning Hub)
WordPress and Fluent tools (FluentCRM, FluentCart, FluentSupport) for accounts, newsletters, and support

Video and communication

Zoom (online lessons and session logs)
Google Workspace (Drive, Docs, Gmail, Calendar) for documents, communication, and scheduling

Hosting and infrastructure

YouTube (lesson and explainer videos, embedded content)
Hostinger (website hosting)
Bunny.net (content delivery and performance)

Analytics and monitoring

Google Analytics (website usage statistics)
Internal monitoring tools to ensure service reliability and security

Safeguarding and legal compliance

Relevant safeguarding agencies, regulators, or law enforcement if required by law, or where there is a serious safeguarding concern

Where these providers process data outside the UK, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the ICO.

4. Data retention

Shani’s Tutoring keeps personal data only for as long as necessary to provide our services, meet legal obligations, and uphold safeguarding responsibilities. When data is no longer required, it will be securely deleted or anonymised.

We apply the following retention periods:

Student and academic records

Lesson records, coursework, assessments, and feedback are retained for up to 6 years after tutoring ends, in line with safeguarding and educational record-keeping requirements.

Payment and financial data

Payment records, invoices, and affiliate payment details are retained for 7 years, as required by HMRC.

Affiliate records

Referral and commission records are retained for 7 years, in line with financial regulations.

Safeguarding records

Any safeguarding concerns, reports, or incident notes are retained for as long as required by statutory guidance, which may extend beyond the standard retention periods.

Session recordings

Lesson recordings are retained for up to 2 years unless required longer for safeguarding, training, or quality assurance. Where recordings are used for training or promotional purposes, separate consent will be obtained.

Community and forum data

Forum posts, messages, and contributions remain available even if a user account becomes inactive. Users may request that their contributions are anonymised or deleted. In some cases, we may need to retain content for safeguarding, moderation, or legal reasons.

Marketing and communication data

Email subscription data is retained until you choose to unsubscribe.

5. Your rights

Under the UK General Data Protection Regulation (UK GDPR), you have important rights in relation to your personal data. Shani’s Tutoring is committed to respecting these rights and enabling you to exercise them.

You have the right to:

Access – request a copy of the personal data we hold about you.
Rectification – have inaccurate or incomplete data corrected.
Erasure – request that your personal data is deleted, where this is not required for legal, safeguarding, or contractual reasons.
Restriction – ask us to stop using your data in certain ways while still allowing us to store it.
Portability – request a copy of your data in a structured, commonly used, machine-readable format so it can be transferred to another provider.
Objection – object to the processing of your data where we rely on legitimate interests.
Withdraw consent – withdraw consent where we rely on it, such as for newsletters, marketing communications, or optional use of recordings.
Raise concerns – complain to the Information Commissioner’s Office (ICO) if you believe your rights are not being respected.

5.1 Safeguarding and legal exceptions

In some cases, we may not be able to fully comply with a rights request. For example:

Safeguarding records cannot usually be deleted, as we have a statutory duty to retain them.
Payment and financial records must be kept for a minimum of 7 years to comply with HMRC requirements.
Lesson recordings may be retained for safeguarding or quality assurance purposes, even if a deletion request is made.

Where this applies, we will explain the reason clearly when responding to your request.

5.2 How to make a request

The easiest way to exercise these rights is through the privacy and data request tools, available via your account settings on our Learning Hub. Requests made through the Learning Hub are tracked and handled securely within the platform.

If you cannot access the Learning Hub or prefer not to use this tool, you can also contact us at shani@shanistutoring.com. We will respond within one month, as required by law.

6. Data security

Shani’s Tutoring takes the security of personal data seriously. We use technical and organisational measures to keep your information safe from loss, misuse, unauthorised access, alteration, or disclosure.

Our measures include:

Secure hosting and encryption – data is stored on secure servers provided by trusted hosting partners (Hostinger, Bunny.net, Moodle), with encryption applied where appropriate.
Access controls – only authorised staff and contractors can access personal data, and only for the purposes required to carry out their role.
Password protection – all accounts use secure login systems, and we encourage users to choose strong passwords. Passwords are stored using secure hashing methods.
Regular updates and monitoring – our platforms and plugins are regularly updated to reduce vulnerabilities. We use monitoring tools to detect unusual activity or security risks.
Recorded sessions – lesson recordings are stored securely, with access restricted to authorised staff and, where applicable, the students concerned.
Data minimisation – we collect and store only the data necessary for service delivery, safeguarding, or legal compliance.

While no system can guarantee absolute security, we continually review our procedures to maintain a high level of protection for the data we process.

7. International transfers

Some of the third-party providers we use may process or store data outside the United Kingdom. This includes widely used services such as Google, Zoom, and Stripe, which may operate servers in the European Union, the United States, or other countries.

Whenever personal data is transferred outside the UK, we ensure that appropriate safeguards are in place to protect it. These safeguards may include:

Adequacy decisions – where the UK government has determined that a country offers an equivalent level of data protection.
Standard Contractual Clauses (SCCs) – legally binding agreements approved by the Information Commissioner’s Office (ICO) that ensure your rights and protections travel with your data.
Additional safeguards – such as encryption and strict access controls, to reduce risks when data is stored or processed abroad.

By using our services, you acknowledge that your data may be transferred internationally, but always under conditions that uphold your rights and comply with UK GDPR.

8. Updates to this policy

This Privacy Policy may be updated from time to time to reflect changes in our services, legal requirements, or data protection practices. The most recent version will always be published on our website and Learning Hub. Where significant changes are made, we will notify users by email or through our platforms.

9. Contact information

If you have any questions about this Privacy Policy or how your data is handled, you can contact us at:

Data Controller
Shani’s Tutoring Ltd
323 Bury Street West, London, N9 9JW
ICO Registration Number: ZB992152
Email: shani@shanistutoring.com

If you are not satisfied with how we handle your data, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO): https://ico.org.uk