1.1 Hello Tutor LLC ("Hello Tutor", "we", "us", "our") is committed to protecting the privacy of all users of our platform. The protection of your personal data is our paramount concern.

1.2 Our platform, services, and all coordinating policies have been designed to ensure that students, parents, and tutors can interact in a safe and trusted environment.

1.3 This Privacy Policy applies to all individuals who access or use the Hello Tutor website, mobile applications, or services, whether as a student, parent, legal guardian, or tutor ("Users").

1.4 By registering for or using our platform, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy.

2.1 Our platform and coordinating policies have been developed to ensure we comply with all relevant data protection legislation applicable in the United Arab Emirates.

2.2 This Policy is governed primarily by the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and its implementing regulations.

2.3 Where applicable, this Policy also takes into account the DIFC Data Protection Law 2020, the UAE Cybercrime Law (Federal Decree-Law No. 34 of 2021), and the regulations of the Telecommunications and Digital Government Regulatory Authority (TDRA).

2.4 This Privacy Policy should be read in conjunction with our Terms and Conditions and our Safeguarding Policy.

2.5 We reserve the right to amend this Policy at any time. Users will be notified of material changes via the platform or by email.

3.1 Hello Tutor seeks to provide the best service possible and to handle all personal data with the highest standards of care, transparency, and security.

3.2 This Policy aims to ensure that all Users, including students, parents, legal guardians, and tutors, understand what data we hold about them and how it is used.

3.3 This Policy outlines the responsibilities of Hello Tutor, tutors, students, and parents in relation to the collection and use of personal data, and it is important that all Users familiarise themselves with its contents.

3.4 If any User has a concern regarding how their personal data is being handled, they must contact Hello Tutor immediately at privacy@hellotutor.me.

3.5 Contravention of any of the terms contained within this Policy may result in immediate suspension of access to and permanent removal from our services.

4.1 Account information: when you register on the platform, we collect your full name, email address, phone number, and date of birth.

4.2 Tutor profile information: tutors provide details including their educational background, qualifications, subjects taught, profile photograph, written bio, availability, and tutoring experience.

4.3 Identity verification documents: tutors are required to provide a valid Emirates ID or passport, proof of UAE residence, and university enrolment certificates or degree certificates where applicable, to verify their identity before their profile is made live on the platform.

4.4 Work permit and licensing information: tutors are required to provide evidence of a valid work permit or freelance permit issued by the Ministry of Human Resources and Emiratisation (MOHRE), or an equivalent permit issued by the relevant free zone authority, confirming their legal entitlement to provide tutoring services in the UAE on a self-employed or freelance basis.

4.5 Background check information: where required, tutors are asked to provide the outcome of a background check conducted within the previous three years, in line with applicable UAE requirements.

4.6 Communications and message history: we store details of all communications between users on the platform, including messages, session requests, and interactions with the Hello Tutor support team, including recorded calls where consent has been obtained.

4.7 Booking and session history: we collect records of all bookings made through the platform, including the subject, level, date, and status of each session, as well as the results of any initial assessments conducted within the lesson space.

4.8 Session recordings: all online sessions conducted on our platform are recorded (except where an unforeseen technical malfunction occurs) and stored for safeguarding and quality purposes. These recordings remain the property of Hello Tutor.

4.9 Payment and financial information: students provide payment card details to make bookings, and tutors provide bank account details to receive payments. These details are processed via our secure, PCI-DSS compliant payment provider. We do not store full card numbers on our servers.

4.10 Reviews and ratings: students and parents may leave reviews and ratings for tutors after sessions.

4.11 Referral and promotional data: we record details of referral codes shared and redeemed, and other promotions you interact with, in order to apply any applicable rewards to your account.

4.12 Technical and usage data: we automatically collect data about how you use the platform, including your IP address, device type, browser type and version, operating system, pages visited, time spent on the platform, click-stream data, and error logs.

4.13 Cookie data: we collect data via cookies and similar tracking technologies as described in Section 13 of this Policy.

4.14 Tutor availability and engagement data: we collect information on tutors' on-platform behaviour, response times, availability, and interactions with other users, to ensure students are matched with the most suitable tutor for their needs.

5.1 To create and manage your account on the platform and to verify your identity.

5.2 To enable tutors to create and maintain a profile on the platform so that they can be found and matched with suitable students.

5.3 To match students with suitable tutors based on their learning needs, subject requirements, availability, and other relevant criteria, and to personalise the platform experience accordingly.

5.4 To enable communication between users on the platform and to provide booking, scheduling, and lesson management services.

5.5 To process payments from students and disbursements to tutors for lessons booked through the platform.

5.6 To record, store, and review online sessions for safeguarding and quality assurance purposes.

5.7 To provide customer support to both students and tutors.

5.8 To monitor in-platform messages and activity to prevent misuse of the platform, safeguard minors, and detect fraudulent or inappropriate behaviour.

5.9 To assess tutor applications, including verifying that qualifications, identity documents, and work permits meet our requirements before a profile is approved.

5.10 To send you service-related notifications, booking confirmations, payment receipts, and important updates about your account.

5.11 To send you promotional communications, special offers, and information about our services, where you have given your consent or where we have a legitimate interest in doing so. You may opt out at any time.

5.12 To improve the technical performance of the platform, identify and resolve errors, and develop new features and services.

5.13 To conduct research and analysis to better understand our users and improve our matching outcomes.

5.14 To apply and track referral rewards, promotional codes, and discounts.

5.15 To comply with our legal obligations, including obligations under UAE data protection, commercial, and cybercrime legislation.

5.16 To protect the rights, property, and safety of Hello Tutor, our users, and the public.

6.1 Contractual necessity: much of our processing is necessary to fulfil our contract with you and provide the services you have requested. Without this data, we cannot operate our platform or deliver our matching and booking services.

6.2 Legitimate interests: we process certain data where it is in our legitimate interests as a business to do so, such as fraud prevention, improving the platform, safeguarding users, and communicating about our services, provided these interests are not overridden by your rights.

6.3 Consent: where required, we will ask for your explicit consent before processing your data, for example for marketing communications or the processing of sensitive personal data. You may withdraw consent at any time.

6.4 Legal obligation: we process data where necessary to comply with applicable UAE law, including requests from law enforcement or regulatory authorities.

6.5 Vital interests: in rare circumstances, we may process data where it is necessary to protect the life or safety of a user or a third party.

7.1 Matched tutors and students: where a student is matched with a tutor through the platform, limited personal information will be shared with the relevant tutor to facilitate the introduction, including the student's first name, the subject and level requested, and the contents of their initial message. Tutor profile information, including their first name, profile photo, qualifications, bio, subjects, and reviews, is visible to all visitors of the platform.

7.2 Payment providers: we share financial data with our secure payment processing partner to facilitate payments in connection with lessons arranged through the platform. Card details are not stored on Hello Tutor's servers.

7.3 Identity, permit, and background check providers: tutor identity documents, MOHRE permit information, and background check data may be shared with our verification partners for the purposes of screening and compliance.

7.4 Analytics providers: we share anonymised usage data with analytics platforms to understand how users interact with the platform and improve our matching service.

7.5 Communications platforms: we use third-party platforms to send emails, SMS notifications, and in-app messages. Limited personal data is shared with these providers for this purpose.

7.6 Cloud hosting and storage providers: personal data is stored on secure cloud servers operated by our hosting partners. All providers are contractually required to maintain appropriate security standards.

7.7 Customer support platforms: we use third-party tools to manage customer support requests. Support staff may access relevant account information to resolve queries.

7.8 Marketing platforms: with your consent, we may share limited data with digital marketing platforms to deliver relevant promotional content.

7.9 Legal and regulatory authorities: we may disclose personal data to UAE law enforcement, regulatory bodies, or other competent authorities where required by law, including under the UAE Cybercrime Law and PDPL. This includes providing access to session recordings where a criminal offence may have occurred.

7.10 All third-party providers who process personal data on our behalf are bound by data processing agreements and are required to process data only on Hello Tutor's instructions and to the same standard of protection we apply.

7.11 We do not sell your personal data to any third party.

7.12 International transfers: some of our service providers are located outside the UAE. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place, including contractual protections that require recipients to protect data to the same standard required by UAE law.

8.1 We retain personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable UAE law.

8.2 Account data is retained for six years from the date of your last activity on the platform. This period reflects the typical lifecycle of a Hello Tutor user and allows you to resume using the platform within that time.

8.3 Session recordings are kept for a minimum of 28 days and a maximum of one year from the date of the session, unless a longer period is required due to an ongoing complaint, safeguarding investigation, or legal proceeding.

8.4 Financial records, including payment history, invoices, and transaction data, are retained for a minimum of five years in line with UAE commercial record-keeping requirements.

8.5 Identity verification documents and work permit records are retained for the duration of a tutor's active registration plus three years, or as otherwise required by law.

8.6 Marketing data is retained until you withdraw your consent or opt out of marketing communications.

8.7 Reviews and ratings submitted by students may remain visible on the platform after a tutor's account has been closed, but will be anonymised so that they can no longer be linked to an identifiable individual.

8.8 After the applicable retention period has expired, or following a valid deletion request (whichever is earlier), personal data will be securely deleted or irreversibly anonymised, subject to any overriding legal obligation to retain it.

9.1 Hello Tutor takes the security of your personal data seriously and has implemented appropriate technical and organisational measures to protect it against accidental loss, unauthorised access, disclosure, alteration, or destruction.

9.2 All data transmitted between users and the platform is encrypted using industry-standard TLS/SSL encryption.

9.3 Sensitive data, including financial information and identity documents, is stored in encrypted form on our servers.

9.4 Access to personal data within Hello Tutor is restricted on a role-by-role basis, and only staff who require access to personal data to perform their specific role are permitted to do so.

9.5 We conduct regular security assessments and monitor our systems for vulnerabilities and potential breaches.

9.6 Despite our efforts, no method of data transmission or storage is entirely secure. You acknowledge that email and internet communications are inherently not fully secure and you transmit information at your own risk. We recommend that you never share sensitive personal information by email.

9.7 In the event of a personal data breach that poses a risk to users' rights and freedoms, Hello Tutor will notify affected users and report to the relevant regulatory authority in accordance with UAE PDPL requirements.

9.8 Users are responsible for keeping their account login credentials secure and must not share their password with any third party. If you believe your account has been compromised, you must contact us immediately at privacy@hellotutor.me.

10.1 Under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, you have the following rights in relation to the personal data we hold about you.

10.2 Right of access: you may request a copy of the personal data we hold about you by submitting a Subject Access Request to privacy@hellotutor.me with the subject line "Subject Access Request". We will respond within 30 days.

10.3 Right to rectification: you have the right to request correction of any inaccurate or incomplete personal data we hold about you. Most of your information can be updated directly through your account settings.

10.4 Right to erasure: you may request that we delete your personal data where we no longer have a lawful basis to retain it. To request deletion, email privacy@hellotutor.me with the subject line "Data Deletion Request". We may be unable to comply where we are required to retain data by law.

10.5 Right to data portability: where processing is based on your consent or a contract, you may request a copy of your personal data in a structured, commonly used, machine-readable format.

10.6 Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

10.7 Right to restrict processing: you may ask us to suspend or limit how we process your personal data in certain circumstances, such as where you contest the accuracy of the data.

10.8 Right to object: you may object to processing of your personal data where we rely on legitimate interests as the legal basis, or where data is processed for direct marketing purposes.

10.9 Rights relating to automated decision-making: where we make automated decisions that significantly affect you, you have the right to request human review of that decision. Please contact privacy@hellotutor.me to exercise this right.

10.10 To exercise any of the above rights, please contact us at privacy@hellotutor.me. We may ask you to verify your identity before processing your request.

10.11 If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, you have the right to lodge a complaint with the UAE Data Office at uaedataoffice.ae.

11.1 Hello Tutor uses automated systems to rank tutor profiles and match tutors with students based on factors including profile completeness, student ratings, response times, availability, and lesson history. These systems are designed to improve the quality and relevance of our matching outcomes.

11.2 We may use automated systems to detect suspicious activity, potential fraud, or behaviour that may breach our Terms and Conditions, which could result in account restrictions or suspension pending human review.

11.3 Where an automated decision has a significant effect on you, you have the right to request that the decision be reviewed by a member of the Hello Tutor team. To exercise this right, please contact privacy@hellotutor.me.

12.1 The Hello Tutor platform is intended for use by individuals who are at least 18 years old. We do not knowingly collect personal data directly from children under the age of 18.

12.2 Where a learner is under 18, their personal data is provided to us by the parent or legal guardian who holds the student account. That parent or guardian is responsible for the accuracy of any data submitted on the learner's behalf and for ensuring the learner's use of the platform is appropriate.

12.3 We take additional care when processing data relating to learners under 18, including restricting the visibility of that data and ensuring it is not used for marketing purposes.

12.4 If you believe we have inadvertently collected personal data from a child without appropriate parental consent, please contact us immediately at privacy@hellotutor.me and we will take prompt steps to delete that data.

13.1 A cookie is a small text file placed on your device when you visit our platform. Cookies allow us to recognise your device on return visits and enable certain platform features to function correctly.

13.2 Strictly necessary cookies are essential for the platform to function and cannot be disabled. They do not collect personal information for marketing purposes.

13.3 Performance cookies collect anonymised information about how users interact with the platform, such as which pages are visited most frequently and whether any error messages are received. This data is used solely to improve platform performance.

13.4 Functionality cookies allow the platform to remember your preferences, such as your login details and language settings, to provide you with a more personalised experience.

13.5 Targeting and advertising cookies track your browsing behaviour in order to deliver more relevant advertising on and off the platform. You may opt out of these cookies at any time.

13.6 We use Google Analytics to collect anonymised data about how users interact with the platform. You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout.

13.7 By continuing to use the platform after being presented with our cookie notice, you consent to our use of non-essential cookies.

13.8 You can manage, restrict, or block cookies through your browser settings at any time. Please be aware that disabling certain cookies may affect the functionality of parts of the platform.

14.1 Any user reported for a breach of this Privacy Policy or our Terms and Conditions will be immediately suspended from the platform pending investigation by Hello Tutor and, where appropriate, the relevant UAE authorities. The user will be informed of their suspension.

14.2 Hello Tutor reserves the right to make a final decision on the action taken in respect of minor breaches of this Policy.

14.3 Any user reported for illegal activity in connection with their use of the Hello Tutor platform may be permanently barred from the service, reported to UAE law enforcement, and reported to any other relevant authorities or organisations.

14.4 Any personal data breach discovered by Hello Tutor will be assessed promptly. Where the breach is likely to result in a risk to users' rights and freedoms, Hello Tutor will notify affected users and report to the UAE Data Office without undue delay and in accordance with UAE PDPL requirements.

15.1 This Privacy Policy will be reviewed by Hello Tutor on a regular basis to ensure it remains accurate, adequate, and aligned with current UAE data protection law and best practices.

15.2 Where material changes are made to this Policy, Hello Tutor will notify users via the platform or by email prior to the changes taking effect.

15.3 The date of the most recent update is always shown at the top of this page. Your continued use of the platform following notification of any changes constitutes your acceptance of the updated Policy.

16.1 For any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact our Data Protection team at privacy@hellotutor.me.

16.2 For safeguarding concerns, contact us at safeguarding@hellotutor.me.

16.3 You may also write to us at: Hello Tutor LLC, Dubai, United Arab Emirates.

16.4 We aim to acknowledge all privacy-related enquiries within 5 working days and to provide a full response within 30 days.