This privacy policy was last updated 05/02/2021. This privacy policy explains how we use the information we collect about you and procedures that we have in place to safeguard your privacy.

Personal data relates to an individual. It could be used to identify you. It includes your name and contact details, but can also include data about your calls, other transactions and your use of our services.

Friendly Tutor Limited is committed to protecting your privacy and will only use the information as permitted by law. Our Data Protection Reference is ZA847964.

 

1. Information we collect and how we use it

When you purchase any of our products or services we need to know your name, postal address, email address and telephone number. The information submitted may be used for credit checking, as set out below and also for anti-fraud investigations with the appropriate regulatory authorities, as set out in our Standard Terms and Conditions of Service.

If we’re required by law to share your data with other organisations, such as the government, we always do so securely and we won’t share more than we need to. When we ask other companies to process data on our behalf we’ll always make sure they follow similarly high standards to those followed by Friendly Tutor. Sometimes we use data to support government initiatives. But any reports that we publish will always be anonymous, so your personal data remains exactly that – personal to you.

We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our products and services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

 

2. Lawful Basis for Processing

We process your information:

1. Where it is in our legitimate interests for the purposes of security, to detect and prevent fraud and to protect our business, consumers and also the business of third parties.

2. Where it is in our legitimate interests to ensure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, to protect our business interests and the interests of our customers.

3. Where it is in our legitimate interests to develop and improve our products and services to ensure we can continue to provide products and services that our customers want to use and to ensure our business model remains competitive.

4. For the performance of our Agreement or to take steps to enter into an Agreement with you.

If we change our Privacy Policy, we will post the changes and dates effective on this page and may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. Continued use of Friendly Tutor products and services will continue to signify that you agree to all such changes.

Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

 

3. Email and Text Notifications

Notification by Email is an essential core communication channel for all call processing and other service notices including billing and charging information. It is used to keep you updated with the progress of your order or additional order(s).  Our products and services require  a valid email address to operate correctly. You are in full control of the various levels of email and text notification from within your Account settings.

We also need to provide you with essential information about our service upgrades and related products.

You may ‘unsubscribe’ from all email notifications at any time by closing your Account and terminating your Agreement with us.

 

4. Cookies and Website Security

A cookie is a piece of information that is stored on your computer’s hard drive by your web browser.

We use cookies in an ethical manner in order to make your experience better and help Friendly Tutor to improve its service. Except for site performance measurement purposes, using Google Analytics, we do not pass your usage data to third parties. Friendly Tutor does not use cookies to target advertising or otherwise track your activities.

Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may still use most of the features of our web site, including purchasing items. However, you may find that certain handy features such as automatic login and saving Account preferences do not work.

Your personal data is sent to our website using best practice encryption methods to protect all personal data and transaction information. All passwords are encrypted in such a way as to make them undecipherable, even by Friendly Tutor.

We do not store your credit and debit card details.

 

5. Credit reference agencies and fraud prevention agencies

The personal information that you provide when you apply for the Friendly Tutor service may be used to carry out a credit check with licensed credit reference agencies, and to verify your identity. This is to protect you from identity theft and Friendly Tutor from fraudulent credit applications.

Information held about you by the credit reference agencies may already be linked to or associated with records relating to one or more of your partners where you have associated or joint financial arrangements.

During the lifetime of your service agreement with us, we may disclose Account and billing information to the credit reference agencies such as change of address, the payments you made, Account balances, any payment default, dispute, queries and debts. This information will be retained by the credit reference agencies, and may be used by us and other organisations to help make decisions about other credit applications made by you or other members of your household with whom you are linked financially.

We will also share your details with fraud and theft prevention agencies to protect you and us from fraud and theft. Information supplied to these fraud prevention agencies may result in a warning marker being placed against the address or addresses used in any applications and this will be accessible to other members of those fraud prevention agencies. A warning marker means that Friendly Tutor and other members of these fraud prevention agencies should take extra precautions to ensure that personal and address information is genuine – this helps to protect an address from any further misuse.

Any information we hold about your Account will also be used for debt tracing and claims assessments. In the event that you do not repay in full and on time, we may tell credit reference agencies who will record the outstanding debt.

If you do not become a customer of Friendly Tutor Limited we will continue to hold information about you for customer enquiries, for complying with any legal obligation and for the prevention and detection of fraud.

The Credit Reference Agency Information Notice (CRAIN) describes how the three main credit reference agencies in the UK each use and share personal data. The CRAIN is available on the credit reference agencies’ websites:

• • • www.equifax.co.uk/crain

    • www.experian.co.uk/crain

 

6. Retention of your data

We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end (e.g. following closure of your Account or following a transaction) or, your application for a product or service is declined or, you decide not to go ahead with it, we will only retain your personal data for a period of time that is calculated depending on the type of personal data, and the purposes for which we hold that information.

We will only retain information that enables us to:

• • Maintain business records for analysis and/or audit purposes;

  • Comply with record retention requirements under the law (for example, as required under legislation concerning the prevention, detection and investigation of fraud);

  • Assist with fraud monitoring; or

  • Defend or bring any existing or potential legal claims;

  • Deal with any future complaints regarding the services we have delivered;

  • Maintain records of anyone who does not want to receive marketing from us;

  • Assess the effectiveness of marketing that we may have sent you.

The retention period is often linked to the amount of time available to bring a legal claim, which in many cases is six or seven years following closure of your account or following a transaction. We will retain your personal data after this time if we are required to do so to comply with the law, if there are outstanding claims or complaints that will reasonably require your personal data to be retained, or for regulatory or technical reasons. If we do, we will continue to make sure your privacy is protected.

 

7. Protecting Your Data and Your Rights

The GDPR aims to give you more control of your data. It provides new and strengthened rights. You have certain rights regarding your personal data, subject to local law. These include the following rights to:

• • request a copy of the personal data we hold about you;

  • request that we supply you (or a nominated third party) with an electronic copy of the personal data that you have provided us with;

  • inform us of a correction to your personal data;

  • exercise your right to restrict our use of your personal data;

  • exercise your right to erase your personal data; or

  • object to particular ways in which we are using your personal data.

Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular data we hold on you.

You can also logon your Account to update or correct your information, if it changes or if the personal data we hold about you is inaccurate. You can write to Friendly Tutor at any time to request us to action any of the above rights or to lodge a complaint about privacy.

If you would like more information on these rights, or wish to exercise them, you can do this by writing to us via our secure Contact Form. Please use the subject: GDPR Privacy Inquiry.

You must use the above Contact Form with correct subject line. Direct emails or invalid subject lines, will not be processed for data protection security reasons.

For changes to or copies of your personal data you must enclose:

• • a photocopy of your passport or driving licence, so that we can verify your identity.

  • Your signature and the date of the request.

  • If you are applying on behalf of another person then signed authority from the individual is required.

Friendly Tutor Ltd is the ‘data controller’ for your personal data. This means it is responsible for deciding how we can use your personal data.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the United Kingdom using their website – https://ico.org.uk.

To find out more about the GDPR, please visit the Information Commissioner’s Office website – it’s an independent authority that upholds information rights in the public interest.

 

8. Automated processing

The way we analyse personal data in relation to our services may involve profiling, this means that we may process your personal data using software that is able to evaluate your personal aspects and predict risks or outcomes. We may also use profiling, or otherwise employ solely automated means, to make decisions about you that relate to:

• • transaction monitoring for fraud, either to prevent you committing fraud, or to prevent you becoming a victim of fraud;

  • identity and verification checks;

  • credit limit decisions;

  • credit and affordability assessment checks to determine whether your application will be accepted;

  • anti-money laundering and sanctions checks;

  • assessments we are required to carry out by our regulators and applicable authorities;

  • determining if an account is dormant due to lack of telecoms activity and dealing with its closure and or asset recovery;

This is known as “automated decision-making” and is only permitted when we have a legal basis for this type of decision-making. We may make automated decisions about you:

• • where such decisions are necessary for entering into a contract. For example, we may decide not to offer our services to you, or we may decide on the types of services that are suitable for you, or how much to charge you for our products based on your credit history and other financial information we have collected about you;

  • where such decisions are required or authorised by law, for example for fraud prevention purposes; or

  • where it is a reasonable way of complying with government regulation or guidance, such as our obligation to treat customers fairly.

You can contact us to request an automated decision to be reviewed by a human being.

E&OE