Fleet Privacy Policy

Last updated on 30 August 2024

INTRODUCTION

Fleet Education Services Limited (“Fleet”, “we” and/or “us”) are an online and face-to-face tuition provider (the “Services”) to parents, educators and partner organisations (“you”) to assist the learning of students of school age or older. Fleet respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or apps (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE 
  • PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Fleet Tutors (a division of Fleet Education Services) collects and processes your personal data through your use of this website (which includes the domain https://www.fleet-tutors.co.uk/ and all related subdomains) and through your engagement with our team of consultants, including any data you may provide through this website, when you sign up to our Services, including our tuition services, or to receive our tips, news and offers.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

  • CONTROLLER

FLEET TUTORS (is the controller and responsible for your personal data).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us for the attention of the Data Privacy Manager, using the details set out below. 

Our full details are:

Full name of legal entity: Fleet Education Services Limited

For the attention of: The Data Privacy Manager 

Email address: clientsupport@fleet-tutors.co.uk 

Postal address: Wallace House, 4 Falcon Way, Welwyn Garden City, AL7 1TW

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  • THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, last name, email address, username or similar identifier, gender, date of birth, student year group, language and country of birth. We may also collect family lifestyle information about the students such as family member names, relationship, phone numbers and email addresses, details of the student’s school and recordings of the student in their tutoring sessions.
    • Contact Data includes emergency contact details for the student (which includes name, email/postal address and phone number of the contact), billing address, email address and telephone numbers.
    • Transaction Data includes details of services you have purchased from us and sessions attended (such as number of sessions attended, number of absences and reasons for absences).
  • Financial Data includes last 4 digits, expiry date, type and full address of credit/debit card used to purchase the service and transaction history, including successful and unsuccessful payments (including the amount of each payment) made to Fleet Tutors. 
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our online video conferencing platform.
  • Profile Data includes purchases or requests made by you, your interests, preferences, feedback and survey responses.
  • Student Learning Data includes subject progress, test or assessment scores and attitude towards learning. 
  • Usage Data includes information about how you use our website and services.
  • Marketing Data includes your preferences in receiving marketing from us and your engagement with our marketing activities.
  • Communications Data includes your communication preferences and email, voicemail and telephone records to customer support.
  • Special Category Data includes, race, ethnicity and any relevant medical information about the student including any special educational needs, including details of any applicable Education and Healthcare Plan (EHCP) or SEND statements about the student. We will always obtain your express consent before collecting this type of data, so we will send you a further communication asking for you to confirm your consent to this processing. We do not collect any other type of special category data about you as a parent or educator. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and/or Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
    • apply for or use our services;
    • attend any of our tuition sessions;
    • subscribe to our service;
    • request marketing communications or content to be sent to you;
    • correspond with our Customer Service or Sales teams;
    • partake in a promotion;
    • complete a survey; or
    • provide us with feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our Cookie Policy for further details. We may also collect Student Learning Data to facilitate the EdPlace Learning Recommender algorithm we use. See further below in section 4 for more information as to how this works.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    • Student Learning Data when you attend any of our group tuition sessions;
    • Technical Data from analytics providers such as Google and Mixpanel based outside the EEA;
    • Financial Data (for example the success or otherwise of a transaction) from payment providers based either inside or outside the EEA.

 

  1. HOW WE USE YOUR PERSONAL DATA

We use your personal data to provide our education services to students and to monitor their progress and educational needs. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances and in the context of our partnerships with third-party organisations:

  • Where we need to provide our tutoring and educational services and to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as providing references about students where required.
  • Where we need to comply with a legal or regulatory obligation, such as safeguarding student welfare and providing appropriate pastoral care.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data, although we will get your consent when collecting special category data (such as information about special educational needs) and before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at clientsupport@fleet-tutors.co.uk.

  • PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we 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 us at clientsupport@fleet-tutors.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact(c) Special Category Data		 Performance of a contract with you
To process and deliver your subscription and tuition services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications(f) Special Category Data(g) Student Learning 		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a promotion (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation
To deliver relevant website and app content, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical(g) Student Learning 		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage(c) Student Learning 		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about features that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile(f) Student Learning		 Necessary for our legitimate interests (to develop our products/services and grow our business)
To deliver learning content to you and measure the effectiveness of that content  (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Student Learning
(f) Technical		 (a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to keep our product/services up to date and relevant, to provide personalised feedback to individual users)

 

  • MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and in all cases have opted in to do so. 

THIRD-PARTY MARKETING  

We do not share your personal data with any company outside of our Group for marketing purposes. 

OPTING OUT  

You can ask us to stop sending you marketing messages at any time by editing your preferences in your Parent or Educator dashboard or by contacting us at clientsupport@fleet-tutors.co.uk. We endeavour to make the opt out process as simple as possible.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or a service experience.

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookie Policy.

  • CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at clientsupport@fleet-tutors.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • Partners and Group Company Responsibilities

Fleet Tutors is part of the Supporting Education Group family of companies. We may share your personal information with our group companies as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us).

Please be assured that we have put in place data privacy compliance measures to ensure that those companies comply with data protection obligations and your data is kept safe and secure. In particular, we ask our group companies and partners to do the following:

  • Obtain explicit consent from their students or their students’ guardians before sharing personal data with Fleet Tutors;
  • Ensure data accuracy and integrity;
  • Implement appropriate security measures to protect personal data;
  • Inform Fleet Tutors of any data breaches or security incidents involving their students’ data.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above:

  • Local Authorities and the student’s school.
  • The NHS, UK welfare services (such as social services) and law enforcement officials such as the police, if, for example, there is a safeguarding issue.
  • Companies that we work with or partner with to deliver our Services to you, including any external tutors or providers of learning software we use for our tuition services;
  • Professional services and technology providers such as, our Human Resources agency, marketing agencies, website development companies and other technology companies, such as Customer Relationship Management or Marketing Automation tools, who help us run our business;
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
  • Partner organisations selling or providing you with access to our services;
  • Where we are required to do so for legal or regulatory compliance.

We may provide third parties with aggregated but anonymised information and analytics about our customers and students and, before we do so, we will make sure that it does not identify you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

We share your personal data within Fleet Tutors and its group companies. Some of our external third parties are based outside the UK and European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and EEA.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us at clientsupport@fleet-tutors.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION
  • HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. See section 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your erasure request for specific legal reasons or if doing so would impact upon other users. You will be notified that we are unable to comply for these reasons, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us at clientsupport@fleet-tutors.co.uk. 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND  
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. GLOSSARY

 

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us clientsupport@fleet-tutors.co.uk.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.