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1. INTRODUCTION
RK Tutors ("we", "us", our") is committed to protecting and respecting your privacy to ensure customer satisfaction and in compliance with UK Law.
The information contained within this privacy policy (together with RK Tutors "Terms and Conditions" and other documents linked to it) sets out what data ("information") RK Tutors collects from you ("client", "customer", "student"), how RK Tutors uses and stores this information, how RK Tutors processes information and how the information is shared.
This Privacy Policy applies to RK Tutors tutoring business and connections to RK Tutors applying to RK Tutors website - www.rebecca.kesler.co.uk ("Site", "Website"), booking system, on-line classroom, storage and means of communication.  The Privacy Policy runs in compliance with other party services that enable RK Tutors to provide the best service possible to you.
From time to time the Privacy Policy may change to maintain compliance with UK Law.  RK Tutors reserves the right to change the Privacy Policy and any policies including the Terms and Conditions linked to RK Tutors at any time.  Any policies including the Privacy Policy will be available on RK Tutors Site.
Please read the following carefully to understand RK Tutors views and practices regarding your personal data and how RK Tutors will treat it.  If you have any questions or concerns about our privacy practices outlined here please contact us using the contact form on this Site or by e-mail at contact@rebecca.kesler.co.uk.
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2. ABOUT RK TUTORS
For the purpose of the Data Protection Act 1998 (the Act) and the EU General Data Protection Regulation (GDPR), the data controller is RK Tutors, Flat 3 Singleton Court, Bury Old Road, Prestwich, Manchester, M25 0FW.  RK Tutors ICO number is currently being processed.
RK Tutors nominated representative for the purpose of the Act is Rebecca Kesler.
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3. WHAT INFORMATION RK TUTORS COLLECTS
RK Tutors collects personal information to help deliver the best service possible with concern to student being tutored on-line or at home.  
When using the Website information can be collected through the Contact page via a form including the student/parent/guardian name, e-mail address and a message about the enquiry.  This can also be conducted via e-mail.  Information can also be collected through the online booking system available via the Website or Simply Book Me: http://rktutors.simplybook.it/v2/ .  Data collected via the booking system is in accordance with Simply Book Me's Privacy Policy.
When booking a lesson (either on-line, over the phone or in person) information collected includes the student/parent/guardian name, e-mail, telephone number and type of tutoring required (e.g. home or online).  If the student is being home tutored the student's home address may also be required in order to conduct lessons.  If the student is being tutored on-line further telephone numbers may be required including mobile, landline and Skype.  In addition. as each student is treated individually, personal information may be required to meet the students tutoring needs.  Students over the age of 18 may be asked for such details or the parent/guardian.  Personal information will include the level a student is working at (e.g. primary, secondary, adult learner) and subject the student requires tutoring in.  Further information may also be required (SEND needs, year, schools, topics struggling in etc.).  Information collected is regularly updated.  However if their is a change of contact details it is important the client informs RK Tutors to enable lessons to continue running smoothly.
After a lesson the tutor is required to write a report about the student's progress.  The information is also collected to enable lessons to be adapted accordingly and to keep tutor/student/parent/guardian/school up-to-date about where the student is up to.  From time to time students will send through personal information to support them in a lesson (e.g. exam papers with grades).
RK Tutors blog is accessible via the Website or through Blogger: https://rebeccakeslertutors.blogspot.co.uk/ .  Data collected via the blog is in accordance with Blogger's Privacy Policy.
When paying for a lesson personal information may also need to be collected including the name of payee, address, e-mail address, phone number and financial information linked to payee.  Currently lessons are paid for either using PayPal's system or DIrect Debit through invoicing.
Customers will be asked if they wish to opt in for receiving newsletters and be added mailing lists which will include business advertisement.  For these purposes a name, address and e-mail may be collected.
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4. HOW RK TUTORS USES YOUR PERSONAL INFORMATION
This section describes how RK Tutors processes data collected from you.  Your information will enable RK Tutors to provide you with access to the relevant parts of the Website and to supply the services you have requested.
- Personal information collected via the contact form, e-mail, telephone, Skype and Site including the Booking System may be used to contact you to discuss further support.  It may also be used book lessons, organise payment and for student reviews.
- Personal information collected will also be used to run lessons.  Physical  addresses may be used to organise home tutoring so that the tutor and student can meet.  On-line students may be contacted via e-mail, landline, mobile and Skype.
- Personal information will be collected to improve the client's experience.  A report is written at the end of each lesson about the lesson, the student and future steps.  This enables the personalisation of content and aids the students progress.  Reports may be shared with the student/parent/guardian at student reviews and during lessons.  Additionally additional personal information such as SEND needs, year, predicted grades, schools etc. may be taken to improve the student's experience so that tutoring sessions can be adapted to meet each student's individual needs.
- Personal information may be adapted when events change (e.g. the change of an address).  It is up to the student to keep RK Tutors informed of such changes so they can be correctly processed and to ensure timely payments.
- Personal information will be used in the creation of student records and administration to enable the tutor to track students progress and contact students as necessary.
- Personal information will be used to process payments and invoice students for future lessons.
- Where you have indicated accordingly, you agree that we may use your information to let you know about our other products and services that may be of interest to you including services that may be the subject of direct marketing and we may contact you to do so by post, telephone, SMS, e-mail, social media or direct mail.  You can choose to opt-in to personal information being used to deliver marketing and communication such as newsletters and mailing list.
- From time-to-time personal information may be used to contact you to discuss how RK Tutors can be improved.  Students/parents/guardians from time to time may be asked to write a review about the service they have received.  This may then be published (at RK Tutors discretion) on RK Tutors Site.  Additionally, from time to time personal information may be used to ask student/parent/guardians to trial improvement software or resources to improve the level of service and customer experience.  The student/parent/guardian can opt-out of these circumstances at any time.
- Personal information may be collected and used via Blogger in accordance with Blogger's privacy policy.  RK Tutors may use personal information supplied to Blogger to monitor traffic and further improve the service offered.
- Your messaging history (e.g. via e-mail, telephone or in person) will allow RK Tutors to provide you access to your communications history, and help RK Tutors to settle any disputes that may arise.
- Lessons are not currently recorded but personal information through reports will be kept to help with child safeguarding.
- Personal information may be used by RK Tutor's booking system to send you SMS or e-mail reminders, tell you about cancellations and booked lessons.  You can opt-out of receiving these and in any format at any time.
If you do not want RK Tutors to use your data in this way or change your mind about being contacted in the future, please let RK Tutors know by contacting via e-mail at contact@rebecca.kesler.co.uk or the contact form on this SIte.
RK Tutors may retain personal data from old customers in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, and assist with any investigations and take other actions as permitted by law.  Old customers may be contacted for marketing purposes.  Old customers have the right to opt-out of this at any time.
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5. LEGAL BASIS FOR PROCESSING INFORMATION
Below, is a description of all the ways RK Tutors plans to use your personal data, and which of the legal bases RK Tutors relies on to do so, identifying also what RK Tutors legitimate interests are where appropriate.
Please note that RK Tutors may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact RK Tutors if you need details about the specific legal ground that are relied upon to process your personal data where more than one ground has been set out below.
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5A. Consent
-RK Tutors will seek your consent to use, process and store contact details to contact you regarding student lessons and delivering the best service available to you including using the booking system.
- RK Tutors will seek your consent to opt-in to marketing services (e.g. mailing list, newsletter).
- RK Tutors students may be below the age of 18.  If this is the case parental/guardian consent must be obtained to ensure child safety and protection before a child can use any of RK Tutors services.  
At any time consent can be withdrawn.  Please contact RK Tutors using the contact form or via e-mail to do so.
RK Tutors also has the right to withdraw services if they feel consent has not been met.
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5B. Personal Information including name and contact information
Purpose or activity:
- To enable RK Tutors to register you as a new customer.  
- To enable RK Tutors to manage and process transactions.  
- To enable RK Tutors to provide an on-line or home service to you.
- To enable RK Tutors to deal with enquiries.
- To enable you and RK Tutors to successfully use the booking system.
- To enable RK Tutors to use contact information to deliver notifications and relevant marketing materials.
- To enable RK Tutors to review and improve services
Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you. 
(b) Necessary for RK Tutors legitimate interests (to recover debts due to us). 
(c) Necessary for RK Tutors legitimate interest (to develop and grow our business).
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5C. Identity Verification Information
Purpose or activity:
- To enable the booking system to verify the identity of customers 
Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you. 
(b) To meet RK Tutors legal obligations.
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5D. Payment details
Purpose or activity:
- To bill payee for lessons through invoice.  Further payment details are taken through PayPal.
Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you. 
(b) Necessary for RK Tutors legitimate interests (to be able to take payments for services).
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5E. Location Details
Purpose or activity:
- To enable RK Tutors to bill payee for lessons through invoice.
- To enable home students to be tutored in a designated location.
- To enable RK Tutors to use contact information to deliver notifications and relevant marketing materials.
Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you. 
(b) Necessary for RK Tutors legitimate interests (to be able to provide and take payments for services).
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5F. Electronic identification data including IP address and information collected through cookies
Purpose or activity:
- To enable RK Tutors to analyse the use of the blog via Blogger.  This is in compliance with Blogger's Privacy Policy.
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for RK Tutors legitimate interest (to define types of customers for RK Tutors products and services, to keep RK Tutors Site updated and relevant, to develop RK Tutors business and to inform RK Tutors marketing strategy).
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5G. Contractual details including services provided
Purpose or activity:
- To enable RK Tutors to facilitate transactions correctly
- To enable RK Tutors to fulfil legal obligations 
- To enable RK Tutors to keep financial records
Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you. 
(b) To meet our legal obligations.
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6. HOW RK TUTORS SHARES PERSONAL DATA
RK Tutors treats personal data as confidential.  Below is how RK Tutors might disclose or share personal data.
As part of providing an on-line classroom service (through Scribblar) e-mail addresses may be shared to with Scribblar so the student can access the classroom.  Contact details may also be shared with Simply Book Me so that the customer can make full use of the booking system including receiving SMS and e-mails.  Some students prefer to use Skype when running on-line lessons and it is up to the student to set up an on-line account with Skype meeting Skype's Privacy Policy.
RK Tutors does not usually share individual student information with outside parties other than the parent/guardian if below the age of 18.  There are some extenuating circumstances please read below.  Sometimes parents/guardians will ask the tutor to speak to their child's school/outside parties on their behalf.  In order to do this written consent must be obtained from the parent/guardian and only after this has been obtained can the tutor share personal details with the school/outside parties.  Additionally data may need to be shared during parent review.
From time to time RK Tutors works with educational bodies such as schools.  Sharing personal data may be necessary in these cases with fellow teachers and staff if this has been agreed in writing with the school.
For child safety and protection purposes sometimes it may be necessary to disclose personal information if a tutor is worried about a student's well being including if a student discloses confidential information that is of concern to child protection and outside services.
For marketing purposes some students/parents/guardians may be asked by RK Tutors to post comments or write a review about the service and tutoring they have received with RK Tutors.  With consent of student/parent/guardian these comments and reviews may be posted on-line on RK Tutors Site.
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7. WHERE RK TUTORS STORES AND PROCESSES PERSONAL DATA
The privacy and protection of your personal information is important to RK Tutors.  Information is stored and processed in accordance with this privacy policy, the terms and conditions and other relevant policies linked to RK Tutors as outlined here on RK Tutors Site.  Data is stored and processed in accordance with UK law.
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8. HOW RK TUTORS SECURES PERSONAL DATA
RK Tutors takes securing and processing your data seriously and take steps to protect your information from unauthorised access, accidental loss, destruction and damage.  Security measures included in securing data, but are not limited to, the use of firewalls, virus and spyware scanning and removal, intrusion prevention and browsing data security.
Only tutors employed by RK Tutors and relevant parties (as discussed above) delivering tutoring to students designated to them or need certain information to perform a specific job (e.g. accounting, marketing) are granted access to your information.
RK Tutors uses all reasonable efforts to safeguard your personal information.  However, you should be aware that the use of email/the Internet is not entirely secure and for this reason RK Tutors cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Site/the Internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at the Site, you can email RK Tutors at contact@rebecca.kesler.co.uk.
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9. HOW LONG RK TUTORS KEEPS PERSONAL DATA FOR
RK Tutors retains personal information about student/parent/guardian whilst a student is being tutored so that the best possible service can be supplied.  Once a student decides to cease tutoring with RK Tutors data is retained for marketing purposes (e.g. to contact for feedback, mailing list, newsletter, special offers).  However the said student/parent/guardian can opt-out from being contacted at any time and request their contact information is taken off RK Tutors system.  A student record is available to the student/parent/guardian upon request.  Data may be stored for financial and accounting purposes.  Data is stored electronically and data no longer needed is disposed of through clearing personal data.
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10. YOUR RIGHTS IN RELATION TO PERSONAL DATA
RK Tutors respects your rights to access and control your personal data.  If a student over the age of 18 or a parent/guardian wishes to have access to this personal data please contact RK Tutors in writing either via e-mail or the contact form on this Site and this information will be supplied.  You are expected to maintain your personal data (including financial information) supplied to RK Tutors is up to date to ensure the best quality of service is provided and to prevent lesson delays.  At any time a student has the option to withdraw consent to certain information as discussed above.  However please note sometimes certain data needs to be retained for financial and legal reasons.  To register a complaint please contact RK Tutors nominated representative either via the general email address or contact form on this SIte.  You can also contact the Information Commisioner's Office via their website: https://ico.org.uk.
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11. HOW TO CONTACT RK TUTORS
If you have any questions or concerns about privacy practices, your personal information or if you wish to file a complaint please contact RK Tutors via the contact form on this SIte or by e-mail at contact@rebecca.kesler.co.uk.  You can also send a postal message to the address stated above.
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12. LINKING TO WEBSITES AND THIRD-PARTY CONTENT
RK Tutors links to third parties for it's booking system, on-line classroom, creation of this Site, for marketing, the blog and sometimes through communication.  RK Tutors follows good practice and links to their policies for each of these third parties.  RK Tutors takes responsibility for the content RK Tutors posts through these third parties but not for the third parties themselves.  The third parties may include cookies and other technologies within their Sites.
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