PRIVACY AND DATA PROTECTION POLICY

This Privacy Policy (“Policy”) is effective as of the date set forth above. Upskills OU (“Company”, “Upskills OU”, “We”, “Us”, “Our” etc.), operating under “UpskillsTutor” brand, is committed to honoring and encouraging the protection of your privacy (both users who are registered (“Users”), and visitors, who operate without registration (“Visitors”)).

This Policy applies to every individual whose personal data is collected by the Company through the website and other persons whose personal data is lawfully disclosed to and processed by Upskills OU (“Data Subjects”). This Policy describes how we collect and use the personal information you provide us with through your use of the website https://upskillstutor.com.ng (“Site”).

We cannot control employees and contractors engaged by Our partners. If you visit another site which is placed on Our Site, another person or entity may collect and use your personal information. Be sure to check their privacy policies before accepting their terms or services.

Be attentive while disclosing your sensitive personal information (e.g. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, health, your sex life or sexual orientation) (“Sensitive information”) to other Users and Visitors through the Site!

You may print a copy of this Policy for your records.

We act as a Data Controller

We act as a data controller, that is, a legal person that determines the purposes and means of the processing of personal data, with regard to personal data of Our Website Users and Visitors. Questions, comments and complaints about Our data practices can be submitted to the following address:

Upskills OU (Reg. No. 14307305).

Address: Tuukri tn 19, Tallinn, Harjumaa. 10152, Estonia;

Phone number: +48223906217;

Email address: info@upskillstutor.com.ng; 

Website: https://upskillstutor.com.ng;

Director: Kyrylo Lazarev.

Data We Collect

We collect different categories of personal data for Visitors and Users of Our Site. If you visited the Site or clicked a link to the Site with or without any purpose and did not fill in the registration form, you instantly become a Visitor. 

Should you want to receive tutor selection services, you need to fill in the registration form and acquire a User status: either as a tutor (any natural or legal person who has accepted a contract offer and uses this Site in intention to receive new students for private tuition and/or orders for one-off intellectual tasks (“Tutor”)) or a student (a natural or legal person, who uses this Site to search, select and communicate the details with a selected Tutor for paid individual classes and (or) consultations (“Student”)).

Information created when you visit Our Site is:

  • IP address;
  • Browser you use;
  • Network connection;
  • Language you use;
  • Device identifiers.

We use this information to make the functionality of Our Site available to you, enable you to use the third-party services, to enhance Our Site, and answer any question or queries you may have. 

Information We may ask you as a User to provide us with if you are:

  •  a Tutor are as follows:
  • Contact details (name, surname, telephone number, Skype nickname, other identificators issued by message apps, e-mail address, sex, age, address of residence, the address where the tutoring is done);
  • Demographic data (information about education, documents confirming obtaining a diploma of higher education and / or qualifications of the services advertised, type and nature of services provided, number of students (orders), costs of services provided, company data and / or individual entrepreneur’s data (if any);
  • Profile data (username and password, information about classes and published materials, other profile data that was provided during registration including photo, date of birth);
  • Billing information (number, expiration date and card type, address for invoicing, VAT number, company or registry number); 
  • Technical data (IP address);
  • Records of conversations between a Tutor and Our representative (as described below).
  • a Student are as follows:
  • Name (first name, family name);
  • Telephone number;
  • Date of birth;
  • Place of residence;
  • Email address; 
  • Level of education;
  • Number of lessons per week;
  • Duration of one lesson;
  • Other data you may reveal to Us via means of communication, e.g. phone, email, request submission form etc. 

You do not have to fill in the data mentioned above. However, profile gets you an opportunity of richer experience from Our Site, including the opportunity of choosing a Tutor for a Student or assigning a Student for a Tutor. 

We treat the information as true data about you. We use these data in order to identify you and confirm your persona, facilitate the communication on the matter of tutor selection services.

We do not run any automated decision-making devices or software including those based on all the data aggregated. 

We do not use personal information We collect for profiling.

Profile and publicity

Remember that any data about yourself placed on the profile will be publicly available. It means that information embedded in the Site might be scanned by search engines (see more in Terms of Use for Tutor). Be sure not to post any Sensitive Information on your profile without assessing the risks and likely consequences. At the same time, you manifestly make public the data listed in your profile. Please be advised that you could not use the Services in a due manner otherwise.

Cookies and Third-Party Technologies

Cookies 

Cookie is a small piece of data sent by the web-server to be stored by your device. Cookie may contain your unique identifier and typically serve to improve your experience of Internet surfing: for instance, due to cookies, you are able to browse pages you have once visited quickly, to set your unique options in “settings” menus, as well as monitor your way through the webpages in order to aggregate precise information about your navigation and preferences, so the site owners may analyze the information and offer you a better service and relevant ads in the future.

You may learn more about cookies We use here: [https://upskillstutor.com.ng/cookies/].

Why We use cookies

We implemented cookies on the Site for a few reasons: 

  • To verify your persona (your account on the Site and device) and help prevent identity theft or other fraudulent use of credentials;
  • To ensure your good experience while using Our Site, for instance:
    • To avoid re-entering of your login and password each time you use the Site;
    • To recognize your device and remember the options as to the settings you have made earlier;
    • To provide you with the webpage formats tailored to the device and software (web browsers) you use and so on.
  • To analyze the way the Site is used and accessed (your clicks, time you spend reading a page or an ad, etc.) etc. 

Analytics cookies 

This website uses Google Analytics, a web analysis service by Google Inc. ("Google"). Google Analytics uses cookies. The information generated by the cookie about the use of this website is usually sent to a Google server in the USA and stored there.

Google will use this information to evaluate the use of the Site, to report on the Site and to provide other website operators with other services related to the operation of the Site. The IP address provided to Google Analytics under Google Analytics will not be combined with other data provided by Google.

Please, pay attention that Google Analytics might collect personal data. For more information, please, check Google’s Privacy Policy.

Opting out

Opting out is a mechanism of withdrawing your consent to be tracked by cookies. You can opt out by setting browser to either completely disallow any cookies or just notifying you of the cookies present on a site. 

The exact settings or method of disabling cookies depend on the browser you use: you may find the necessary option by clicking on your Help button. 

If you reject or block all cookies in the settings, you may not be able to take full functionality of Our Site: some cookies are an essential part and are necessary for the correct operation of the services you want to receive.

Our Partners

Some of features are not developed by us but embedded on Our Site by Our partners and are not used by us to collect your data or provide services to you on Our own behalf. Strictly speaking, some services you can obtain access to via Our Site are part of Our partner’s sites or apps and are placing the cookies (and collecting your personal data through them, if you provide them with such personal data) themselves.

Cookies of Our partners are subject to such partners’ privacy policies.

Widgets of Community Portals

On Our Site, We can place features related to social networks, such as the "Like" button from the Facebook network and widgets, such as the "Share" button and interactive mini-programs that run on Our Site. These functions can obtain the IP address and track the page visited on Our website and configure cookies to work properly. The functions and widgets of social networks can be used directly on Our website or on other websites. Your interaction with these features is governed by the privacy policy of the company that provides them.

Service of One Entry

You can log into Our site via various login services, such as Facebook Connect or OpenID. These services will identify your identity and allow us to share certain personal information (e.g. your name and email address) to automatically fill out Our registration form or verify you.

How We Use Personal Data

Our Purposes

Our Site is aimed at providing you with informational and other services, according to Our Terms of Service. Thus, We need your data to provide you with the respective Services. 

As We mentioned in Data We Collect, We will use your personal data for the following purposes: 

  • THE DATA OBTAINED FROM A TUTOR:
  • Provision of information services regarding the selection of students and promotion of a personal tutor profile and its services;
  • Implementation of the platform's activities and its improvement;
  • Sending confirmed applications and new orders;
  • Registration of technical support rights (if any) or other benefits available to registered users;
  • Response to requests and complaints sent to the customer service department;
  • Account administration;
  • Sending the requested information about products or services;
  • Warning, preventing or taking action against illegal activities and/or violations of the terms of service provision.
  1. B) THE DATA OBTAINED FROM A STUDENT:
  • Provision of information services related to the selection of a tutor;
  • Implementation of the platform's functionality and its improvement;
  • Sending supplementary information about orders;
  • Sending the requested information about products and services;
  • Warning, preventing or taking action against illegal activities and/or violations of the Terms of Service.

Processing personal data for marketing purposes

Where you have opted in to receive marketing communications from us, We will process your personal data to provide you with marketing communications in line with the preferences you have provided.

The legal basis on which We process your personal data for marketing purposes is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at info@upskillstutor.com.ng, via telephone number or via online form in any marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that Our processing of your personal data before you withdraw your consent was unlawful.

Disclosure of Your Personal Data

We ensure We always include the controls and warranties embodied in this Policy to the contracts and agreements We enter into with Our partners and contractors whom We grant access to your personal data to. 

Grounds for Processing

We promise that We use the personal data we’ve obtained from you or on your behalf in a way that does not outweigh your rights and freedoms. 

Despite this, We must comply with the GDPR requirements to the legal grounds for processing. The GDPR allows us to collect and process your personal data on the legitimate grounds as follows: 

The processing is necessary to provide you with the Services and features available through Our Site 

To achieve this purpose, We may need Your account information.

The processing is necessary to fulfill Our legal obligations 

The law of Estonia, as well as other applicable laws depending on the relationship between you and Our company may affect: 

  • the scope of personal data We collect; 
  • ways We process your personal data in;
  • our ability to keep the confidentiality of your data and avoid their disclosure;
  • duration of the planned retention, etc.

Where processing is necessary to protect the vital interests of individuals or public policy, We cannot refuse to provide the copies of your personal data We have collected or may have access to within the functionality of the Site to the authorities and enforcement agencies in case of receipt of their legitimate decision or demand to do so. 

Also, We may be obliged to provide the aggregated information to the state statistics bodies or to state historical archives.

The processing is necessary to secure Our or third parties’ legitimate interests

We may use the personal data We collect and process (including yours) in order to maintain and enhance Our user’s safety and security (for instance, We use cookies in order to prevent fraudulent use of credentials), enabling or administering Our business (quality control, consolidated reporting, customer service), transfer of ownership and so on. 

Also, We may report to the police or other competent enforcement agencies in case We discover fraud, threats to other users or any other violations of the applicable law or suspicious behavior or actions committed on behalf of your account.

Pursuant to and as limited by your consent

Among the purposes We list above, We rely on your consent when We use your personal data (for instance, your experience of interaction with Our Site as caught and stored via the cookies) for optimizing and enhancing the operation of the Site, developing new features and services (including when it is collected as a part to the aggregated data), and providing you with relevant marketing materials as long as it is allowed by your device or browser’s personalization and privacy settings.

Your Age

Before using Our Services, you have to reach the age of sixteen (16) if you are a Student and the age of eighteen (18) if you are a Tutor. We do not normally provide services to subjects under the abovementioned age. Subsequently We do not process their personal data. We reserve the right to implement any tools and techniques to reveal the human trafficking and exploitation of children, and report them immediately to the appropriate state authorities and enforcement agencies, including the personal data associated with the activities which, at Our own discretion, are suspicious and may raise concerns about their association with the violation of applicable laws.

By using or accessing Our Site, We believe that such Data Subjects are at least sixteen (16) years (if they are Students) or eighteen (18) years (if they are Tutors) old and have all rights to enter into an agreement with us as to the receipt of Services and use of Site, as well as collect and process personal data under Data Subjects’ consent for the purposes We mention in this Policy. 

If you know that We process personal data of a Student under sixteen (16) years old or a Tutor under eighteen (18) years old, please inform us by sending email at info@upskillstutor.com.ng or via telephone number +48223906217. 

Retention of Personal Data

We will store and process your personal data for as long as your account is active or for as long as needed to provide you or Our users with the Services. In case your account is not active anymore, the personal data will not be stored longer than one (1) year from the moment of its last activation. Some cookies data might be stored longer. Its retention period you might find at Cookies Policy.

After expiry of a year retention period we are to delete your personal data, unless its storage is justified by legal obligation or our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

Where We have processed your personal data to provide you with marketing communications with your consent, We may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from Our list.

We can obtain access to the recordings of conversation between a Tutor or a Student and our representative within 6 (six) months after the event. Please be advised that our processor Binotel is instructed to collect and store such data using appropriate organisational and technical safeguards. 

Deleting your account will automatically entail deletion of your data, unless its storage is justified by legal obligation or Our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

You may also solely delete your account under its settings, or request deletion of your account at any time by sending us an email at contact info@upskillstutor.com.ng or via telephone number +48223906217, or via special online form of withdrawal. Executing your request, We will delete your account within thirty (30) days. Sometimes We may be unable to delete your account or personal data (for instance, in case of unsettled or unresolved dispute or claim, or in case We suspect you in being associated with a crime or other violation of applicable law, e.g. fraud, unsafe behavior, security incident). Upon the resolution or settlement of claim, conclusion of a criminal or administrative proceeding, or learning that Our suspicion is unjustified, We will delete your account or personal information.

We would also like to inform you there might occur certain cases where your personal information may stay in the Internet search engines for some time after such data has been removed from Our Site. This is because your personal information is public (see more in Terms of Services for Tutor). In that case, Internet search engine operator is responsible for the processing that it carries out of personal information which appears on web pages published by Us. We advise you to contact directly to the search engine. 

State authorities, enforcement agencies, courts

We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency or a court in case We receive a mandatory request for such disclosure from them. 

As We warned you earlier, We may be proactive and address the competent authority in case We suspect a violation of law to be committed in association with your account or persona via Our Site.

Your consent

We will notify you of the purposes and scope of the disclosure and ask for your permission in case your personal data is to be shared with a third party not mentioned in this Policy.

Right to Withdrawal of Consent

The GDPR reserves your right to withdraw consent to processing of your personal data. 

You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not mean that the processing before the withdrawal is considered thus illegal. 

You may withdraw your consent by deleting of your account, sending us an email to info@upskillstutor.com.ng or via telephone number +48223906217 as well as through online form of withdrawal. Before withdrawing your consent, take into attention the outcome such withdrawal may entail.

We will do our best to verify your withdrawal of consent within seventy two (72) hours since the receipt of your request. 

Cross-border Transfer of Data 

Our headquarters is in Estonia. We make every effort to protect entrusted data against unauthorized access. The procedures applied, such as a comprehensive access authorization system and technical security measures, are regularly reviewed and adapted to technical progress. The secure transmission of user data via SSL encryption which ensures reliable data protection.

Some data may be accessed and processed by next companies:

NAME

PURPOSE

COUNTRY

PRIVACY POLICIES

Digital Ocean LLC.

Placing (hosting) platforms, storing databases and providing related infrastructure for information processing.



USA

https://www.digitalocean.com/legal/privacy-policy/ 

Virtual PBX Binotel LTD

PBX cloud, virtual call center services and related infrastructure.

Ukraine

https://offers.binotel.ua/privacy_policy 

Zadarma Project, Inc.

PBX cloud, providing virtual phone numbers.

USA

https://zadarma.com/en/legal/privacy-policy/ 

Tormuto Technologies LLC.

SMS operator, notifications for clients and tutors.

Nigeria

https://tormuto.com/privacy_policy 

Google, Inc.

Google provides tools for working with emails and businesses, cloud platform service and analysis software, the authorization widget.

USA

https://policies.google.com/privacy?hl=en-US 

Facebook , Inc.

Facebook provides services for attracting potential customers, ads, widgets, comments, a connection widget with the support service, an authorization widget.

USA

https://www.facebook.com/legal/FB_Work_Privacy 

LinkedIn, Inc.

The service for attracting potential customers and tutors.

USA

https://www.linkedin.com/legal/privacy-policy 

Coranto Informatica

Managing the postal addresses of the company, employees and ancillary addresses for mailings

Italy

http://www.coranto.it/en/info/privacy/ 

Mailgun, Inc.

Management and sending of email notifications

USA

https://www.mailgun.com/privacy-policy/ 

Sendpulse, Inc.

Mass email campaign management

USA

https://sendpulse.com/legal/pp 

Fondy LTD

Credit card processing and payment services

United Kingdom

https://drive.google.com/file/d/1drnQjBI_4kmGj-tsVYAQsVuC2UuSH573/view 

Paypal, Inc.

Credit card processing and payment services

USA

https://www.paypal.com/va/webapps/mpp/ua/privacy-full 

Paysera LT, JSC

Credit card processing and payment services

Lithuania

https://www.paysera.com/v2/en/legal/privacy-policy 

We also may use support from the specialists skilled in performing tasks to enhance our Services and Website as well as other independent contractors, e.g. IT specialists, accountants, auditors, lawyers, etc, provided that all adequate safeguards are put in place. 

In order to secure the adequate level of protection, We implemented the Standard Model Clauses as well as signed Data Processing Agreements in the relationships with the engaged contractors, so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us.

We process and store personal data using Digital Ocean LLC and Google Inc. technical decisions. Its data security compliances might be checked here:

https://www.digitalocean.com/legal/privacy-policy/;

https://policies.google.com/privacy?hl=en-US

If it is required to transfer personal data from the EU to an organization in the United States it should be checked that the organization the personal data are transferred to is signed up with the Privacy Shield framework at the U.S. Department of Commerce. In order to be able to certify, companies must have a privacy policy in line with the Privacy Principles e.g. use, store and further transfer the personal data according to a strong set of data protection rules and safeguards. The protection given to the personal data applies regardless of whether the personal data is related to an EU resident or not. We transfer your personal data to the US organizations only if such organizations are signed up with the Privacy Shield.

Your Rights

Rights under the GDPR 

The GDPR reserves a scope of rights you may enjoy as to personal data protection. The list of rights protected by the GDPR is as follows:

  • right of access (i.e. you may ask us to send you a copy of the data about you that We collected); 
  • right to rectification (i.e. you may ask us to correct the outdated or false data, or complete the data which is missing or incomplete)
  • right to erasure (i.e. you may ask us to delete the personal data We retain, provided that the GDPR allows you to do so);
  • right to restriction of processing (if processing may be restricted under the GDPR)
  • right to object to processing (if the GDPR reserves your right to object as to certain kinds of processing or in certain circumstances)
  • right to data portability (i.e. you may ask us to transfer a copy of your data to another organization or to you provided that the circumstances comply with the GDPR).

Please remember that We do not charge any fees in relation to exercising your rights protected by the GDPR (unless we receive repetitive requests without a clear justification behind the need to request the information within such short periods of time; in this case, we may charge you a small fee to compensate the expenses that incur due to the repetitive and excessive character of requests). We typically do Our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case We are processing a large amount of requests the answer may took us longer than you might expect. 

You can send us the request via email info@upskillstutor.com.ng or via telephone number +48223906217. Please verify that your request comprises the details: 

  • your name;
  • contact information;
  • right you want to exercise, and, where applicable;
  • your personal data in Our processing;
  • reason/justification behind such request.

We may ask you to provide us with some information we already have to verify that it is you or holder of parental responsibility on your behalf.

Complaint Lodgement

In case you are convinced We are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority. Our lead authority is:

Estonian Data Protection Inspectorate

39 Tatari St., 10134 Tallinn

+372) 627 4135
email: info[a]aki.ee.

https://www.aki.ee/en/inspectorate

We kindly invite you to share your concerns with us first. You may use the following channels to address your inquiries: 

Email address: info@upskillstutor.com.ng;

Telephone number: +48223906217.

Updates to the Privacy Policy

We may occasionally update this Policy. 

We reserve the right to change the Privacy Policy (at its own discretion and at any time). If We make significant changes, We will notify you of the changes on Our Site or through others means, such as email, before they enter into force. We encourage You to periodically review this Policy for the latest information on Our privacy practices.

If as a result of these changes, you would like to change the mode of authorized use of personal data by us, you can do so by making necessary changes to your profile or send us a question to the address info@upskillstutor.com.ng or via telephone number +48223906217.