Tutorio Ltd ("Tutorio", "we", "us") is committed to protecting the privacy of everyone who uses Tutorio - learners, parents, tutors and organisations. This Privacy Policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it and the rights you have. It applies to tutorio.app, the Tutorio apps, the tutor workspace, live lessons, Rio and every other part of the Service, and to our communications with you.
We are the data controller for the data described here, except where you use Tutorio through a school, college or other organisation, in which case that organisation is normally the controller and we process data on its behalf (see When we act as a processor).
Who we are
Tutorio Ltd is registered in England and Wales (company number 14962372) at Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE. Our data protection contact can be reached at [email protected]. We are registered with the Information Commissioner's Office (ICO).
The data we collect
Information you give us
- Account details - name or display name, email address, password (stored only as a salted hash), date of birth or age band where we ask for it, country and timezone, and the role you hold (learner, tutor, admin).
- Profile and preferences - avatar, qualification, exam board and subjects you choose, notification preferences, theme and language.
- Learning content you create - answers, drawings on the annotation layer, notes, saved items, bookmarks, feedback and reports you submit.
- Tutor content - courses, topics, questions, mark schemes, lesson plans, assignments, reviews and messages you create as a tutor.
- Contact and support - anything you send us by email, phone, chat or in-app feedback.
- Payment details - handled by our payment providers; we receive the card type, last four digits, billing name and transaction outcome, never the full card number.
- Parent or guardian details - where provided, so we can contact you about a child's account.
Information generated when you use Tutorio
- Learning activity - questions attempted, answers, scores, time taken, hints used, streaks, XP and quests, progress through courses, screening test results and live lesson participation (including answers and response times shown to your tutor).
- Class and organisation membership - which classes, tutors and organisations you are connected to, and when you joined or left.
- AI interactions - prompts you send to Rio and the answers submitted for AI marking, together with the output (see AI Transparency Statement).
- Device and technical data - a random device identifier we assign, device type and OS, app version, browser, IP address, approximate location derived from IP (country/region), language, screen size, referrer and crash or performance diagnostics.
- Notification tokens - push notification, live activity and widget tokens issued by Apple or Google for your device.
- Security records - sign-ins, failed attempts and lockouts, sign-outs, password changes, sessions and the IP address and user agent involved, held in our audit trail.
- Usage analytics - pages and features used and how long for, collected to understand and improve the Service.
Information from other sources
- Sign in with Apple or Google - your name, email (or an Apple relay address) and a stable identifier from the provider.
- Tutors and organisations - when a tutor or organisation adds you to a class or issues you a licence, they give us your name and contact details.
- App stores and payment providers - purchase and subscription status.
Using much of Tutorio does not require an account. For guests we collect only the device identifier, learning activity on that device and technical data.
Why we use your data and our lawful bases
| Purpose | Examples | Lawful basis |
|---|---|---|
| Providing the Service | Creating your account, saving progress, marking answers, running live lessons, showing results to your tutor, syncing across devices | Performance of a contract (or legitimate interests for guests) |
| Classes and organisations | Connecting you with tutors, sharing your class progress with them, notifying tutors when learners join | Performance of a contract; for organisation deployments, the organisation's instructions |
| AI features | Drafting content, marking, feedback, Rio | Performance of a contract; legitimate interests in improving learning support |
| Communications | Receipts, invitations, reminders, live lesson alerts, security notices | Performance of a contract; legitimate interests; consent for marketing |
| Payments and licences | Processing purchases, issuing licences and credits, preventing fraud | Performance of a contract; legal obligation (tax and accounting) |
| Security and integrity | Audit trail, lockout, detecting cheating and abuse, rate limiting | Legitimate interests in keeping the Service and its users safe; legal obligation |
| Safeguarding | Responding to concerns, cooperating with authorities | Legal obligation; vital interests; substantial public interest |
| Improving Tutorio | Analytics, testing features, fixing bugs, understanding which content works | Legitimate interests; consent for non-essential cookies |
| Legal compliance | Responding to lawful requests, enforcing our terms, defending claims | Legal obligation; legitimate interests |
Where we rely on legitimate interests we have balanced them against your rights and interests and concluded they are not overridden, giving particular weight to the interests of children. You can ask us about any balancing assessment.
Who can see your data
Tutors, classes and organisations
If you join a class, the tutors of that class - and colleagues in their organisation where the organisation enables sharing - can see your display name, progress, answers, scores, screening results and activity for that class, and can contact you through the Service. During a live lesson your answers are visible to the tutor as you submit them, and the tutor may show a leaderboard or summary to the class. Other learners cannot see your answers unless the tutor chooses to reveal them. You can leave a class at any time, after which the tutor keeps only the historical class records.
Parents and guardians
A parent or guardian linked to a learner's account can see that learner's progress and activity, as described in Children's Privacy & Parents.
Service providers (processors)
We use carefully selected companies to host, run and support Tutorio - cloud hosting, databases, email and SMS delivery, push notifications, payment processing, AI model providers, error monitoring and customer support tools. They may only use personal data on our instructions and under contracts that protect it. The current list, with locations and purposes, is published in Sub-processors & Data Locations.
Others
- Apple and Google - for sign-in, app distribution, in-app purchases and notifications, under their own privacy policies.
- Authorities - where required by law, court order or to protect someone's safety, including safeguarding referrals.
- Business transfers - if Tutorio is acquired or merges, data may transfer to the new owner under the same protections; we will tell you first.
- Professional advisers - lawyers, accountants and insurers under confidentiality.
We do not sell personal data and we do not share it with advertisers for targeting. Where the public parts of our website show advertising, the ad provider only receives the standard technical data described in our Cookie Policy, subject to your cookie choices, and no advertising is shown to signed-in learners inside the learning experience.
AI and your data
When you use an AI feature, the content needed for that request (for example, your written answer and the mark scheme, or your question to Rio and the topic you are studying) is sent to our AI provider to generate a response. We minimise what is sent, do not include your name or contact details unless you type them, and our contracts with providers prohibit them from using the data to train their models. We keep AI interactions with your learning record so you and your tutor can review them. Tutors review AI output before it reaches learners as content, and no decision with a legal or similarly significant effect is made by AI alone. Read more in the AI Transparency Statement.
Notifications, widgets and live activities
With your permission we send push notifications about classes, assignments, reviews, live lessons, streaks and account security. On iPhone we can also show a live activity on the lock screen and in the Dynamic Island during a live lesson or study session, and render a home-screen widget with your progress. These use the device tokens issued by Apple or Google and data from your account. You can turn any category off in Tutorio's notification settings or in your device settings. We do not send marketing by push notification.
Cookies and similar technologies
We use cookies and local storage to keep you signed in, remember your device and preferences, protect against cross-site request forgery, and (with consent) measure how the public website is used. Our Cookie Policy lists each one and how to control them.
International transfers
Your data, including every backup, is stored in the United Kingdom. Some service providers process limited data in other countries, principally the United States, to carry out a specific task such as delivering a push notification, signing you in or answering an AI request. Where they do, we rely on UK adequacy regulations or the UK International Data Transfer Agreement or Addendum together with supplementary measures such as encryption. The transfer mechanism for each provider is shown in Sub-processors & Data Locations.
How long we keep data
| Data | Retention |
|---|---|
| Account and profile | While your account is open, then deleted within 30 days of account deletion |
| Learning activity and progress | While your account is open; anonymised or deleted on account deletion. Class records kept by a tutor or organisation are retained under their instructions |
| Guest device data | Deleted after 24 months of inactivity |
| AI interactions | Kept with your learning record; provider-side logs deleted by the provider within 30 days or less |
| Security audit trail | 12 months, or longer where needed for an investigation or legal claim |
| Payment and licence records | 7 years, as required by UK tax law |
| Support correspondence | 3 years after the case is closed |
| Backups | Rolling backups are overwritten within 35 days; deleted data leaves backups on that cycle |
| Safeguarding records | In line with statutory guidance, which may require longer retention |
How we protect your data
We use encryption in transit (TLS 1.2 or higher) and at rest, ISO 27001 certified hosting, role-based access control, hashed passwords with a configurable strength, history and lockout policy, multi-factor sign-in through Apple and Google, logging and monitoring, regular tested backups, and secure development practices with dependency scanning and code review. Staff access to personal data is limited to what their role requires and is logged. Full details are published on our Security & Compliance page. No system is perfectly secure; if we discover a breach that puts you at risk we will tell you and the ICO as the law requires.
Your rights
Under the UK GDPR you have the right to:
- Access the personal data we hold about you and receive a copy.
- Rectify data that is inaccurate or incomplete.
- Erase your data ("right to be forgotten") in many circumstances, including by deleting your account.
- Restrict or object to processing based on legitimate interests, and object to direct marketing at any time.
- Portability - receive data you provided in a machine-readable format.
- Withdraw consent where processing is based on consent, without affecting earlier processing.
- Not be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you.
Most of these can be exercised directly from your account settings. Otherwise email [email protected]. We respond within one month and never charge for a reasonable request. Your Data Rights & Account Deletion explains each step.
You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first.
Children
Tutorio is used by children, and we design it with them in mind. We apply the ICO's Age Appropriate Design Code: high-privacy defaults, no behavioural advertising, no nudges to share more data, clear language, and parental tools. Accounts can be created from age 13; younger learners use Tutorio through a parent, tutor or organisation. Everything specific to under-18s is in Children's Privacy & Parents.
When we act as a processor
When you use Tutorio through a school, college, council, agency or other organisation, that organisation decides what data is entered and how it is used, and is the controller. We process the data on its instructions under our Schools & Organisations Agreement. Requests about that data should go to the organisation in the first instance; we will help them respond. Independent tutors who set up their own classes are controllers of the learner data they collect.
Changes to this policy
We will update this policy when our practices or the law change. Material changes will be announced by email or in-app notice before they take effect, and every version is retained in the version history at the bottom of this page.
Contact
Data protection: [email protected]
Tutorio Ltd, Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE
Phone: 01908 904106