Privacy Policy

SOTC LTD, a company registered in England and Wales (No. 09328574), herein referred to as Spires. We have created this privacy statement ("Statement"™) in order to demonstrate our firm commitment to the privacy of the details that you provide to us when using this website.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

Unless otherwise indicated all definitions in the Terms and Conditions shall apply to this policy. In this Statement, references to "You" and "Your"™ are references to the User of i.e. www.spires.co (the Site) regardless of whether You are a Client or a Tutor or other user. When You use the Site, You are consenting to the practices set forth in this Statement. It applies to information we collect about Users of our Site and amongst other things, this Statement describes what personally identifiable information "Personal Information"™ we collect from You, how and when it is used, how We protect it and who has access to it. This Statement incorporates our Cookie Policy.

Spires, recognizes the importance of confidentiality and the protection of personal information. This privacy policy explains how we use and protect the personal information we hold, whether it relates to our students, parents, tutors, potential tutors, its staff, consultants and third party service providers in connection with our business and has been developed to comply with the U.K's Data Protection Act 1998 ("DPA"™) and the EU's General Data Protection Regulation (GDPR).

We may change this Privacy Policy from time to time. We may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

WHAT IS PERSONAL INFORMATION

Personal information means information about an identifiable individual or information that permits an individual to be identified. It does not include business contact information, such as name, title, business address and business telephone number when used for business communications.

OUR COMMITMENT

Spires takes responsibility for maintaining and protecting the personal information under our control. We have appointed a Data Controller who can be contacted directly by the public at [email protected]. Our Data Protection Officer is responsible for our day to day compliance. We review this policy and our personal data protection practices regularly to ensure that we are in compliance with applicable legislation and current best practices.

HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION

We only collect and process personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information and will delete all provided information within 6 years of the termination of the usage of our services, save for information required for tax and regulatory purposes for a longer period of limitation.

Spires typically collects personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Where the purpose for the collection of personal information is unclear, you can ask the Spires representative with whom you are dealing to provide an explanation of the purpose for the data collection. More generally, we are happy to provide you with all personal information we hold upon request in writing to [email protected]

Our reason for collecting personal information about tutors, students, parents, staff and consultants is to establish and maintain our contractual or other business relationship with that individual.

The purpose for collecting personal information about tutors and students is primarily to facilitate the provision of educational tutoring services online, including to allow students to quickly and easily assess the professional and educational background of tutors, as well as allowing us to communicate effectively with tutors, students and parents and to maintain mailing lists. We may also use your personal information to:

• Respond to your comments, questions and requests and provide customer service.
• Communicate with you about services, offers and promotions and provide news and information we think will be of interest to you. We will seek seperate consent for marketing and promotional emails as required by GDPR regulation.
• Manage your account and send you technical notices, updates, security alerts and support and administrative messages.
• Monitor and analyse trends, usage and activities.
• Link or combine with information we get from others to help understand your needs and provide you with better service.
• Carry out any other purpose for which the information was collected.

As appropriate, Spires will ask for specific consent to collect, use and disclose personal information. Such a request, and your consent to such request, may be given in writing, orally or through the Spires platform. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.

DPA and GDPR permit Spires to disclose personal information to certain third parties without the affected parties knowledge or consent to certain parties. Accordingly, we may share personal information about you as follows:

• With consultants and other service providers who need access to such information to carry out work on our behalf, including our legal advisors and affiliate education providers.
• In response to a request for information from a court, law enforcement agency or other government agency or department if we believe disclosure is in accordance with any applicable law, or as otherwise required by any applicable law;
• Including for the purposes of completing or arranging for the completion of background checks and other safeguarding requirements.
• With educational insitutions or award granting bodies, in cases where academic misconduct is suspected or has occurred. if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party; in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another entity; and otherwise with your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Generally, personal information supplied to us is confidential and we do not disclose the information to unconnected third parties except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.

Spires may use third party service providers from time to time to carry out certain functions for us such as printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by Spires.

Spires recognizes that the European Union ("EU") and Switzerland have implemented omnibus data protection regimes established pursuant to the GDPR, European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively. Among other things, these laws require an "adequate level of protection" for the transfer of certain individually identifiable data about individuals in EU member countries and Switzerland to Spires' operations.

We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our website or services. The source of the usage data is Google Analytics, Mix Panel, Smartlook and Facebook. This usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is the legitimate interest of our platform and website, namely the monitoring and improvement of our website and services.

We may process information needed to set up and maintain an account with Spires, in order to provide you with our services ("account data"). This account data may include your name, phone number and email address. The source of the account data is the information you provide. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is to allow the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information to be included in your personal client profile on our website ("profile data"). This profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, educational details and employment details. Profile data may be processed for the purposes of enabling your use of our services. The legal basis for this processing is to allow the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process your personal data that are provided in the course of the use of our services ("service data"). This service data may include information about your classes, academic performance and any factors relevant to this, your current, past or future academic institutions, your availability for tuition sessions, your preferred tuition location, and your experience or qualifications. We gather this information directly from you. Service data may be processed for the purpose of effectively providing our services. The legal basis for this processing to facilitate the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). Enquiry data may be processed for the purposes of offering or providing relevant services to you. The legal basis for this processing is the legitimate interest of our platform, namely to respond to enquiries concerning our services and to make our services available to potential clients.

We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to customers. The legal basis for this processing is the legitimate interest of our platform, namely the proper management of our customer relationships.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). Transaction data may include your contact details, details of the payment method used, including details of specific payment cards, your billing address, and the details of the transaction itself. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

We may process information that you provide to us for the purpose of subscribing to our email notifications ("notification data"). The notification data may be processed for the purposes of sending you the relevant notification. The legal basis for this processing is the legitimate interests of our platform, namely the need to inform clients of relevant developments in relation to their use of our services, for example any charges to be levied in respect of those services.

We may process information that you provide to us for the purpose of subscribing to our email newsletters and job, class, account, message and payment emails (“notification data”). This data may be processed for the purposes of sending you the relevant newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us and/or other users ("correspondence data"). The correspondence data includes the communication content, video recordings, phone recordings and message transcipts and metadata associated with these communications. Our website will generate the metadata associated with communications made using the website. The correspondence data may be processed for the purposes of communicating with you, dispute resolution and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users and protecting the integrity of our platform and brand.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, reporting misconduct or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risk.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person's personal data to us, unless we prompt you to do so.

PROTECTING YOUR PERSONAL INFORMATION

We strive to maintain personal information in an accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected. We protect personal information by security safeguards appropriate to the sensitivity of the personal information, regardless of format. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies.

We may disclose your personal data to our insurers and/or professional advisers in so far as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose enquiry data, profile data, service data or correspondence data to another or multiple clients of our paltform in so far as reasonably necessary to affect an introduction between tutor and student for the purposes of arranging tuition, and to facilitate and administer that relationship, and to assist in the performance of the contract between tutor and student. The legal basis for this is the legitimate interest of our platform, namely the provision of our services.

Financial transactions relating to our website and services may be handled by our payment services providers, Stripe and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices on their websites.

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, connected companies, our ultimate holding company and all its subsidiaries) in so far as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

In addition to the specific disclosures of personal data set out in this, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect certain information about you when you access or use our website or transact business with us, including:

• Log Information: We collect information about your use of our websites, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed accessed our websites.
• Transaction Information: When you engage in a tutoring session, we collect information about the transaction, such as details regarding the type or nature of tutoring being provided and the date and date and time of the tutoring session.
• Class recordings: All tutoring session held on Spires are automatically recorded by our A/V provider Zoom. These are stored on our servers for a limited period of time to ensure safety of our tutors and our tutors and students and also to help improve the provision of our services for monitoring and quality purposes and for dispute resolution.
• Phone calls: All phone calls held through the Spires system are automatically recorded by our call service provider Twilio. These are stored on our servers to ensure safety of our tutors and students students and also to help improve the provision of our services for monitoring and quality purposes and for dispute resolution.
• Message transcripts: All messages sent through the Spires system are automatically recorded by our call service provider. These are stored on our servers to ensure safety of our tutors and students and and also to help improve the provision of our services for monitoring and quality purposes and for dispute resolution.

Our website uses cookies, which are identifying technologies that your computer receives when you visit certain websites. Most browsers can be set to reject all cookies but features of our website may not work as intended if that option is chosen. We use permanent cookies to analyse website usage and improve our services. We use temporary (session based) cookies to improve performance and to determine web trends. Temporary cookies disappear when you close your browser window. We use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is used to help identify you for the purposes of gathering broad demographic information.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

The cookies that we use relate to authentication, status, personalisation, security, advertising (Google, Facebook, Bing) and analysis. A full list of the cookies that we use and their purpose can we can we requested by email to [email protected].

Our advertising service providers use cookies and those cookies may be stored on your computer when you visit our website. We primarily make use of Google to analyse the use of our website and Google Adwords to monitor our marketing performance. Google gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

Analytical cookies generated by Google, help us track the number of visits to our website, tell us how often you visit our website and how you use it. That may include which pages you’ve viewed, what journeys are taken from one page to the next, content you may have downloaded, your IP address and what devices are used to access our website. This helps us to ensure users find what they are looking for, and understand how web users engage with our content, so we can improve it over time to ensure users have a better experience. We also collect other marketing cookies generated by third parties, namely social media platforms and Google Ads. We use this information to identify content you’re most interested in and share more relevant information with you through advertising campaigns on other websites and social media, or email campaigns if you have submitted a contact form. For example, you may see some relevant Spires adverts on various websites after your visit to our website. Additionally, if you have submitted a contact form or requested a demo, and subscribed to our mailing list, by using these cookies we’ll be able to send you emails tailored to your interests.

DATA RETENTION

We will retain your personal data as follows:
Account data, profile data, service and customer relationship data will be retained for a minimum period of one year from the time of the receipt of this data, and for a maximum period of six years from the end of the period in which the client is in receipt of Spires’ services.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

• The period of retention of correspondence, usage, transaction and notification data will be determined based on their likely relevance to future reviews of company processes, or legal proceedings.
• The period of retention of publication data will be determined based on the period of time for which this data is intended to remain in publication.
• The period of retention of enquiry data will be determined based on the likelihood of an enquiry resulting in the provision of services to the data subject.

YOUR RIGHTS

Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

• The right to access;
• The right to rectification;
• The right to erasure;
• The right to restrict processing;
• The right to object to processing;
• The right to data portability;
• The right to complain to a supervisory authority;
• The right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting https://spires.co/ and logging into your personal client account.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You may make such amendments yourself by visiting https://spires.co/ and logging into your personal client account.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is: consent; or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.

However, this right does not apply where it would adversely affect the rights and freedoms of others. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your personal data by written notice to us, specifically via email to [email protected], in addition to the other methods specified in this Section

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to SOTC Ltd’ partner companies, (details of which are provided below). Direct sharing of data will occur only in respect of clients who have entered into, or sought to enter into, a contractual relationship with both or all of the companies participating in the sharing of data, and only insofar as is necessary to fulfil the purposes set out in Section 3. In particular:

• to further the legitimate interests of our company namely provision of our services and maintenance of our reputation
• to allow us to meet our legal obligations

SOTC Ltd’ partner companies are:

• Tavistock Tutors Ltd. (https://tavistocktutors.com)
• The Profs. (https://www.theprofs.co.uk/)

EXTERNAL LINKS

To the extent that our website contains links to third party web sites. Spires is not responsible for the privacy practices or the content of such websites nor does Spires warrant the quality, accuracy or completeness of information contained in these sites.

ACCESSING YOUR PERSONAL INFORMATION

You may write to our Data Protection Officer at [email protected] to request access to personal information about you. Spires will generally inform you if we are holding personal information you, as well as details about the personal information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to personal information may be denied if required or authorized by law. If a request for access is denied, Spires will provide an explanation of the reasons for the refusal.

If you choose to withdraw your consent to continued collection, use or retention of your personal information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of personal information about you in our custody and Spires will amend personal information where appropriate.

HOW TO CONTACT US

The website www.spires.co is owned and operated by SOTC Ltd.

We are registered in England and Wales under registration number 09328574, and our registered office is at 185 Ashburton Triangle Drayton Park, London, United Kingdom, N5 1GD

Our principal place of business is at Sierra Quebec Bravo, Canary Wharf, 77 Marsh Wall, London, United Kingdom, E14 9SH. You can contact us:

by post, to the postal address given above; using our website contact blue button;

by email, using [email protected]

RECOURSE

If you have a concern about the personal information handling practices of Spires, a complaint, in writing, may be directed to our Data Protection Officer. Upon verification of your identity, we act promptly to investigate the complaint and respond within 60 days.

Where our Privacy Officer makes a determination that a complaint is well founded, we will take the necessary steps to correct the offending information handling practice and/or revise the privacy policies and procedures of Spires. Where our Data Protection Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.