Privacy and Cookie Policy

Last Modified: 1st Sep, 2021

A. PRIVACY POLICY

TMN has created this Privacy Policy (“Privacy Policy”) so You are aware of how we collect, use, process or store Personal Data (as defined in ADGM Data Protection Regulations (“Regulations”)) (“Personal Data”) You provide us when using this Site and in order to demonstrate our firm commitment to the privacy practices as the data controller for the purposes of the Regulations and any other applicable data protection laws.

Unless otherwise indicated all definitions in the Customer Terms & Conditions and the Mentor Terms & Conditions shall apply to this Privacy Policy. In this Privacy Policy, references to “You” and “Your” are references to the user of www.teachmenow.com (the “Site”) regardless of whether You are a Customer, a Mentor or other user.

1. THIS POLICY

This Policy explains our processing of Your Personal Data and Your rights according to the Regulations. We reserve the right to modify this Privacy Policy at any time without notice by posting the changes on this page.

2. INFORMATION WE COLLECT

2.1. WHAT INFORMATION IS COLLECTED?

(a) Personal Data You give us that is necessary for the use of the TMN Site

TMN processes Personal Data as a necessary part of entering into and performing our contract with You, which is governed by our Terms of Use and the Mentor, Customer or Third Party Provider Terms & Conditions (as applicable). As part of the process of using the Site and the Services, we require You to give us certain Personal Data which we need to provide our Service. Without this information we may not be able to fulfil our contract with You. This information includes:

Account information: to enable us to create an account for You on the Site. Depending on whether You register as a Sponsor (i.e. parent or guardian), Student, Third Party Supplier representative, or Mentor, this information can include Your name, email, telephone number, postal address, date of birth, time zone, school name, grade or year group, any police and criminal background checks and associated information, the number of languages You speak and Your bank account details in order to facilitate payments from or to You.

Mentor application details: so we can process Your application to become a Mentor. These details include Your educational background and qualifications, Your mentoring subjects, Your profile picture and video resume, Your resume, the prices You charge, Your availability, Your gender and any information related to police and criminal background checks that we are required to undertake.

Communication history: to enable communication with other users of the Site and with the TMN team, we store details about Your communication history including user messages, requests You have made, and Your interactions with the TMN team.

Booking history: to facilitate Sessions including information on booking requests, status of bookings, booking subjects and levels, and results of Your set-up tests whilst using the Session space.

Discounts You have redeemed: we record details of promotional discount codes shared, redeemed and other promotions You interact with to be able to apply rewards to Your account.

Identity verification information: when You apply as a Mentor we ask for verification that You study or studied at the university You claim to, have a valid government issued ID card and a clean criminal background check (if applicable).

(b) Information we automatically collect from Your use of the TMN Site

We collect some information from all users of the TMN Site regardless of whether You are registered with us as a Customer, Mentor, or Third Party Provider . This is due to the fact that we have a legitimate interest in collecting such personal information as it enables us to operate the TMN Site and Services effectively.

Automatically tracked information includes: Cookie information, Your IP address, details of the device You use to access the Site, the pages You visit and the actions taken, the times and dates of actions You take on our Site, Your interactions with our email, text and in-app messages, the source of Your visit and/or previous webpage before visiting our Site, any sites you navigate to from links on our Site, and Your page response times.

Mentor capacity information: If You have a profile as a Mentor on the Site we collect information on Your on-site behaviour, capacity and interactions with other users to help show You the most relevant requests and show Customers the most relevant Mentors.

(c) Information we collect from third parties

Your reviews from other TMN users: users on TMN can rate Mentors after Sessions, this information is shared with You if You are a Mentor and may be displayed on Your public profile.

Other sources: where You use an available single sign-on option to log into Your account, we may collect certain identity credentials from the third party service that you use for single sign-on, such as your name, email address and any available profile photo. We reserve the right, where permitted by law, to collect and use information on You from third party providers.

(d) Financial Information

We may require You to provide us with financial information to authorise or process payment and bill You or pay You for your use of the Services. For Mentors, these details include Your nominated bank account, Your invoices and Your payment history, and for Customers Your payment history and payment card details.

When You receive payment for delivering Mentoring Services via the Site (if You are a Mentor), we will pass Your financial information to the necessary third parties to process Your transactions with us, such as credit card companies, payment gateway providers, and banks.

(e) Legal basis

The legal bases under which we are permitted to process the types of Personal Data described in this section 2.1 in these ways are as follows:

1. The processing is necessary for the performance of a contract to which You are a party, or to take steps prior to entering into a contract with You. If you are a Customer, this includes our requirement to provide you with the Services in exchange for payments you make to us. If you are a Mentor, this includes our requirement to remit payments to you for Sessions taught. Where we require information from You for these purposes we have set out below which information it is necessary for us to process, without which we will be unable to provide You with our Services.

2. The processing is necessary for us to comply with legal obligations that we are subject to. For example, by law, we are required to safeguard the well-being of children using our Services and notify the authorities of any material circulated on our Site that is harmful to children. In order to comply with those obligations, we need to process Your Personal Data, including information related to Your user account, such as your name, contact details, location data and account activity.

3. The processing is necessary for the purposes of our legitimate interests. We want our Site and the Services we provide to be of as high a quality as possible. In order to do this, our customer services, support and safeguarding teams need to be able to process Your Personal Data. For example, if You are experiencing technical difficulties during a Session, or are unable to top-up your credit in order to pay for new Sessions, you might report these difficulties to us. We need access to your Personal Data to help resolve these issues. Furthermore, understanding how our users use the Site and the Services allows us to improve Your user experience and introduce features on the Site that You might request or benefit from.

4. It is necessary for the purposes of our legitimate interests, such as fraud prevention, child safeguarding and protection, maintaining quality of Service, error detection and cybersecurity, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as You). To determine this, we shall consider a number of factors, such as what You were told at the time You provided Your data, what Your expectations are about the processing of the data, the nature of the data, and the impact of the processing on You.

5. In order to comply with our legal obligations to protect and safeguard children from harassment and abuse, and given that such safeguarding represents a substantial public interest, we video record and store Mentoring sessions. These video recordings will not be shared with other third parties, except where necessary to comply with our legal obligations and the substantial public interest to safeguard the wellbeing of children using our Services.

6. As part of our safeguarding efforts, we require that Mentors supply us with Special Category Personal Data related to criminal convictions and offences. The legal bases upon which we rely to process such Special Category Personal Data are:

a. performance of a contract with the Mentor and in order to take steps at the request of the Mentor prior to entering into such contract; and

b. the fact that processing is necessary for reasons of substantial public interest, as we hope to ensure that children using our Site and Services are not at risk of exposure to any unlawful, abusive or exploitative behavior by Mentors.

7. Where You have given us explicit opt-in consent to the processing of Your Personal Data for the purpose of providing you with electronic direct marketing by us, we will rely upon that consent in order to send you direct marketing.

8. Where we need to comply with a legal obligation.

9. In rare circumstances, where we need to protect Your interests (or someone else's interests); and/or where it is needed in the public interest or for official purposes.

2.2. HOW IS THE INFORMATION USED?

The Site asks You to provide various types of Personal Data to enhance the quality of the Services we can provide to You and the more accurate the information You provide, the better we are able to respond to Your requirements.

Any Personal Data that is held with TMN shall be retained in accordance with applicable data protection laws, including the Regulations. TMN is the data controller in respect of all of the Personal Data which TMN collects and receives about You when You use the TMN Services.

(a) Data processing to provide and improve the TMN Site and Services

We use Your information primarily to fulfil our contract to provide you with the Services that You request, and related Services (this includes providing this Site, Site administration and security). We run the following processes to fulfil our contract with You:

i. Enabling You to access the Site and create an account

ii. Enabling Mentors to create and promote their profile on the Site

iii. Facilitating matching between Customers and Mentors

iv. Enabling You to communicate with other users, including Mentors, and receive updates from TMN about Your account

v. Enabling bookings between Customers and Mentors

vi. Enabling payments

vii. Providing support for Customers and Mentors

viii. Providing photos and videos to create trust and enable better connections between users and promote effective delivery of Session content.

We also use Your information to support our legitimate interests in developing the Site and the Services. These processes include:

i. To aid the technical administration of the Site

ii. To better understand how the Site is functioning for users to inform our product development

iii. To draw conclusions upon demographic information

iv. Preventing fraud, spam and abusive or inappropriate behaviour

v. Fulfilling our safeguarding and legal obligations

vi. You acknowledge that Your Personal Information may be used by TMN to contact You by post, phone or by electronic mail when necessary in connection with the Services requested by You on the Site.

vii. Data processing to provide, tailor and improve our marketing activities

We also use the video recordings of sessions, to comply with our legal obligations to protect and safeguard children from harassment and abuse, and given that such safeguarding represents a substantial public interest, we video record and store Mentoring sessions. These video recordings will not be shared with other third parties, except where necessary to comply with our legal obligations and the substantial public interest to safeguard the wellbeing of children using our Services.

We also use Your information to support our legitimate interests in marketing our Site and the Services. These processes include:

i. Marketing activities to promote our Services to registered users. These communications may be personalised to You and Your interactions with the Site and can be delivered by email, social media advertising and other digital marketing channels

ii. Notifying You about upcoming promotions, discount codes, Services or Customer surveys

iii. Undertaking impact reporting to understand the efficacy of our Services

iv. Undertaking research to better understand our Customers’ interests

v. Analysing Your interactions to improve the efficiency of our marketing activities

(b) Direct marketing

Where you have expressly opted in to receive direct marketing from us, TMN may, from time to time, contact You by telephone or by electronic mail, with information or offers relating directly to the Site and the Services.

You may unsubscribe (i.e. opt-out) of direct marketing at any time. This can be done by clicking "unsubscribe" in any marketing e-mail that we send You. You may also contact TMN by sending an email to privacy@teachmenow.comwith subject line “UNSUBSCRIBE REQUEST” or a similar statement. Where you receive telephone marketing by text message, you may unsubscribe by responding to the message with the response specified in the marketing message to opt-out. Where you receive telephone marketing by telephone call, simply instruct the person you are speaking to to remove you from our direct marketing database.

3. WHO ELSE HAS ACCESS TO THE INFORMATION?

(a) Other users on the TMN site:

Your Personal Data may also be viewed by Mentors (where You are a Customer) or by a Customer or Mentor (where You are a Mentor) for the sole purposes of enabling Mentors to deliver their Mentoring Services direct to You and to provide You with information about their Mentoring Services and access to the Mentoring Services themselves.

If You as a Customer make a request for Mentoring Services with a Mentor via the Site, Your Personal Data will be shared with the Mentor to enable the Mentor to deliver the Mentoring Services or to follow up on any enquiry. Such details may include: first name and initial of surname, your school, the languages you speak, your age, the contents of Your message, and the subject and level You requested.

If You as a Mentor submit Personal Data on the Site for example by creating a profile, Personal Data in Your profile may be accessible by any user who visits the Site. The Personal Data shared may include: first name and initial of surname, university details, the resume You write for TMN, Your profile picture picture and video, Your grades, Your Mentoring subjects and price band, Your Mentoring record and reviews. Releasing this Personal Data is necessary for You to make use of the Site and the Services.

If You as a user send a message to another user on the Site, You acknowledge that TMN may monitor the content of Your message to fulfil our safeguarding obligations and to protect our legitimate interests

(b) Third party companies and service providers:

We use a variety of third party companies to provide the Services and we may need to pass some Personal Data to these third parties. If we pass Personal Data to third parties, we minimise as far as possible what Personal Data is shared. The categories of third party providers we share Personal Data with include:

i. Analytics providers

ii. Sponsors of tutorials

iii. Payment providers

iv. Communications platforms for email, text and in-app communications and video conferencing/calling functionality

v. Marketing platforms

vi. Business operations tools

vii. Identity verification tools

viii. Surveys and research providers

ix. Accounting and finance platforms

x. Customer support platforms

(c) Disclosure of Your Personal Data and financial information in compliance with laws:

You should be aware that we may release Your Personal Data or financial information when we believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transacted with TMN, or to protect the rights, property or safety of TMN personnel, Site users or other persons.

(d) Transfer of Your Personal Data and financial information outside of the ADGM

We may transfer Personal Data to entities outside of the ADGM, including onshore in the UAE. Where we transfer Your information outside the ADGM we will undertake an assessment of the level of protection in light of the circumstances surrounding the transfer and:

i. Only transfer it to a non-ADGM jurisdiction with privacy laws that give the same protection as the ADGM; or

ii. Ensure we have an agreement in place with the recipient under which they are under a duty to protect Your Personal Data to the same standards as those in place in the ADGM; or

iii. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek Your consent unless there is an overriding legal need to transfer the information; and

In all cases where Your information is transferred outside the ADGM, You have a right to contact us for information on the measures we have put in place.

(e) Other websites/third party vendors and their privacy policies and cookie policies

This Site may contain links to other websites. TMN is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, and so You should be careful to read and understand those Site policies independently.

4. HOW DO WE PROTECT YOUR INFORMATION?

The privacy and protection of Your Personal Data is important to us. You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, we cannot ensure or warrant the security of any information You transmit to us, or to or from our online Services. You accept that TMN cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. You transmit all such information at Your own risk. However, once we receive Your transmission, we use our best efforts to ensure its security on our systems.

The Site has security measures in place to protect the loss, misuse and alteration of the information under our control. We encrypts all Your Personal Data, including credit card number, name, and address, so that it cannot be read as the information travels over the Internet.

5. COOKIES

For information about cookies and how they are used on this Site, read our Cookie Policy below.

6. COMPLAINTS OR QUERIES

TMN tries to meet the highest standards when collecting and using Personal Data. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This Privacy Policy does not provide exhaustive detail of all aspects of TMN’s collection and use of Personal Data. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below. If You are not satisfied with our response or believe we are processing Your Personal Data not in accordance with the law You can complain to the ADGM data protection regulator, the Commissioner’s Office.

7. HOW LONG WE KEEP YOUR INFORMATION FOR

We will retain Your Personal Data for different periods depending on the Service You have chosen to use us for, which may be a longer period than that for which we need to hold Your data to provide those Services, i.e. where we are under regulatory or statutory duties to hold Your data for a longer period. Data will be held by us for the period necessary to meet the purposes for which we initially collected the information.

By default, we retain Personal Data for as long as You are an active user of the Site. Where You have been inactive for a period of 6 months or more, we will terminate Your account. Thereafter, subject to the paragraph above, we will delete Your Personal Information once a period of [1 year] has elapsed.

After that period has passed, or after You request us to delete Your data (whichever is earlier) we will delete Your Personal Data except where we have specific reason which means we need to keep it for longer.

Records that You have shared publicly or have shared with another user, for example reviews You leave, messages You send and bookings You make, may remain on the Site after Your Personal Data has been deleted but will no longer have identifying information which links them to You associated with them.

We may retain records where necessary to fulfil our regulatory or statutory duties.

8. DATA SUBJECT RIGHTS

(a) Access to and rectification of Personal Data

TMN tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if we hold any Personal Data by making a 'data subject access request' under the data protection legislation. If we do hold information about You, subject to You paying us a fee for our reasonable administrative costs, we will let You have a copy of that information unless a legal exception applies, in which case we will inform You of this at the time. You also have the right to request that information we hold about You which may be incorrect, incomplete, or which has been changed since You first told us, is updated or removed.

To make a request to exercise either of these rights, please either put the request in writing addressing it to the address provided below or email us Your request to privacy@teachmenow.com with the subject line “DATA SUBJECT ACCESS REQUEST”.

(b) Moving your Personal Data

In the event that we process Your data by automated means where You have either provided us with consent for us to use Your information or where we used the information to perform a contract with You, You have the right to request that we send to You or to another organisation, an electronic copy of the Personal Data we hold about You in a structured, commonly used and machine-readable format, for example when You are dealing with a different service provider. If You would like us to provide You, move, copy, or transfer Your information in this manner, please let us know by email to privacy@teachmenow.com We will respond to You within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.

(c) Deletion of your Personal Data

You can 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 You have withdrawn consent for us to process it (as explained 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 request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.

To request that we delete Your Personal Data please send an email with the subject line ‘Personal data deletion’ to privacy@teachmenow.com.

(d) How you can withdraw consent to our processing your Personal Data

You have the right at any time to withdraw any explicit consent You have given us to process Your Personal Data. Please note if You withdraw Your consent it will not affect the lawfulness of any processing of Your Personal Data we have carried out before You withdrew Your consent. Should You wish to do so You can change Your consent preferences at any time. To withdraw Your consent for us to send Your third-party promotions, please change Your preferences on Your account settings and/or by contacting us at privacy@teachmenow.com.

(e) How you can restrict or object to our processing your Personal Data

You can ask us to suspend the way in which we are using Your information in certain scenarios, or object to our processing Your data where we are relying on a legitimate interest ground (or those of a third party) and You feel it impacts on Your fundamental rights and freedoms, or where we are processing Your Personal Data for direct marketing purposes. In some cases where You object, we may demonstrate that we have compelling legitimate grounds to process Your information which override Your rights and freedoms.

Please note that if You want us to restrict or stop processing Your data this may impact on our ability to provide our Services. Depending on the extent of Your request we may be unable to continue providing You with our Service.

Any queries or concerns about the way in which Your data is being used can be sent to privacy@teachmenow.com.

9. AUTOMATED DECISION MAKING AND PROFILING

To provide You with our Services, it is necessary for us to conduct profiling and automated decision making on Your data consisting of monitoring log in activity to determine whether Mentor's profiles remain active on the Site.

Should You wish to discuss or contest this decision or request that a person is involved in this automated decision, which You have a legal right to do, please email privacy@teachmenow.com

B. COOKIE POLICY

Our Site uses cookies. TMN have created this cookie policy (“Cookie Policy”) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using this Site and the data that We collect about You online. We ask You to consent to our use of cookies in accordance with the terms of this Cookie Policy when You first visit our Site. By using our Site and agreeing to this Cookie Policy, You consent to our use of cookies in accordance with the terms of this policy. In this Cookie Policy, references to ‘You’ and ‘Your’ are references to the user i.e. the person (or company) visiting Site. When You use the Site, You agree that this Cookie Policy applies to that use in addition to any other terms and conditions which may apply including, but not limited to, those contained in our Privacy Policy, the Terms of Use and the Mentor Terms & Conditions, Third Party Provider Terms & Conditions and/or the Customer Terms & Conditions (as applicable), and which are duly incorporated by this reference. TMN reserves the right to change this Cookie Policy at any time without notice, effective immediately upon posting on the Site. Please check this page of the Site periodically. Read it carefully and ensure that You understand its effect before proceeding to use the Site. Your continued use of the Site is taken as meaning that You agree to such changes or updates.

10. INFORMATION ON COOKIES?

We use cookies to personalize content and to provide you with an improved user experience. By using this Site you consent to the deployment of cookies onto your devices. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

We only set a few cookies ourselves, but when we include content from other websites (like Facebook or Twitter) they also get the opportunity to set cookies, to help them serve their content better. We cannot guarantee that we will have listed every cookie you might get from a third party, as they can change them at any time as their needs change. The main types and categories of cookies used by our Site are set out below.

11. TYPES OF COOKIES:

Session cookies: these cookies remain in your browser during your browser session only, i.e. until you leave the Site.

Persistent cookies: these cookies remain in your browser for a set period of time after the browser session (unless deleted by you).

12. CATEGORIES OF COOKIES:

Strictly Necessary Cookies: These cookies are fundamental to website functionality and cannot be switched off without blocking features on the Site. They are usually set in response to your actions on the Site, such as filling in forms, setting preferences, or recognize the user as valid and authenticated while accessing protected areas of the Site.

Analytics cookies: TMN collects information about how you use our Site including details such as the website that referred you (e.g. search engines, marketing campaigns, referring domains), the content you viewed, the Site path you navigated and the links that you clicked on. This is in order to understand your interests on our Site and the number of times you visit our Site. We use this information to improve our Site and enhance visitor experience. We share this information with analytics and search engine providers that assist us in improving and optimising our Site.

Preference cookies: TMN uses preference cookies also known as “functionality cookies,” to allow our Site to remember the choices you have made in the past (such as your username, language or the region you are in) and provide you with an enhanced more personalised experience.

Advertising cookies: TMN may present ads to you on websites that are not owned or operated by TMN to promote TMN services. The cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously re-appearing. These advertisements are solely intended to make you aware of relevant TMN promotions. TMN does not sell your data to any third parties. Please see our Privacy Policy for more details.

13. COOKIES ON THIS SITE:

Cookie Type Purpose Cookie Name Cookie Source Expiry
Strictly Necessary / Authentication Cookies Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. NCT TeachMeNow 60 Minutes
G_ENABLED_IDPS Google Never Expires
Preference / Functional Cookies Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. teachmenowrememberme TeachMeNow 3 Minutes
teachmenowemail TeachMeNow 3 Minutes
teachmenowpassword TeachMeNow 3 Minutes

14. YOU DON’T WANT COOKIES?

Whether the Site is able to set cookies depends on a setting in your web browser and device. By visiting the Site with cookies enabled, you consent to our use of cookies. If you wish to disable cookies, you can find instructions on how to do so for various popular web browsers by following the links below:

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Internet Explorer:https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

Safari: https://support.apple.com/en-ae/guide/safari/sfri11471/mac

Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy

 

If you use a different web browser, please contact the browser maker for instructions on disabling cookies. Please note that, if you disable cookies in your browser, some aspects of the Site, and of other websites, may stop working.

15. CHANGES TO THIS PRIVACY AND COOKIE POLICY

We're here to help. If You have any queries, requests, comments or complaints regarding the Site or the Privacy and Cookie Policy, just get in touch. You can contact us through the Contact Us page of the Site, or write to us at:

The Webmaster:
Teach Me Now Limited
DD-16-121-027, Level 16, WeWork Hub71, Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island
privacy@teachmenow.com

We keep our Privacy and Cookie Policy under regular review. This Privacy and Cookie Policy was last updated on [01] [09] [2021].