Privacy Policy

Wonders of Maths Limited (“WoM”, “we”, “us”, “our”) is a tutoring provider for children specialising in tailored tutoring adapted for each child’s optimum learning strategy. We are also a provider of software products and services that allow others to provide tailored tutoring adapted for each child’s optimum learning strategy.

This Privacy Notice is intended to ensure that our students, their parents/carers, our tutors and our software users (“you”, or “your”) are aware of the categories of your personal data we may collect, how we collect it, what we use it for and who we share it with.

By “personal data” we mean information about you which could identify you such as your name and contact details.

We will be the “data controller” of personal data processed in connection with this Privacy Notice. This means that we are responsible for deciding how we hold and use personal data about you. Our address is Kings House, 174 Hammersmith Road, Hammersmith, London, W6 7JP. We are registered with the Information Commissioner’s Office under registration number ZC204913. Should you have any questions about this Privacy Notice you can contact us at this address or by emailing info@wondersofmaths.com.

We have appointed Pierre Reibel as Data Protection Officer (DPO) to oversee our data privacy matters. If you have any questions about this Privacy Notice or how we handle your personal data, please contact the DPO at pierre@wondersofmaths.com.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Notice.

If you provide us with personal data of anyone else (for example, someone who has referred you), please provide those persons with a copy of this Privacy Notice and make sure they gave their prior consent to you sharing their personal data with us.

Children’s data

Because our services are provided to and used by children, we take particular care with children’s personal data and have regard to the ICO’s Age Appropriate Design Code (the “Children’s Code”). We collect only the data we need to deliver tutoring safely and effectively, and we present information about how we use children’s data in clear, age-appropriate language where it is directed to a child. Where we rely on consent to process the personal data of a child under the age of 18 (including for any marketing, optional cookies, or use of photos/videos), that consent is given and managed by the child’s parent or carer. We do not use profiling to deliver marketing to children, and a parent or carer may exercise the data protection rights set out below on the child’s behalf.

What personal data do we collect about you and what do we use it for?

The categories of personal data about you we may collect, store and use are set out below and in each case we have specified what we use it for and our ‘lawful basis’ for processing it.

The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will use your personal data under the following lawful bases: (1) where we need to perform the contract we have entered into with you; (2) where we need to comply with a legal obligation; (3) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or (4) where you have consented to us doing so.

Information you provide to us

We collect personal data that you provide to us by undertaking our online assessment, filling in forms, signing up for any of our services, or corresponding with us by post, phone, email, or otherwise.

‍Students — photos/video: we may collect photos that you send to us or we may take photos or videos ourselves, which we would like to use for marketing and promoting our services. We only do this if you, and your parent/carer (if you are under 18), consent.

‍Students — contact details (name and email address, school name, year group and date of birth): to send you marketing emails about our products and services. Our lawful basis is either your consent (where you signed up on our website) or our legitimate interests in promoting our products and services (where you are an existing student and did not opt out). You can opt out at any time via the unsubscribe link.

‍Students — online Learning Profile Assessment: we collect your name, academic year, school, how you heard about us, your favourite subject, how much you read, whether you like the sciences, your maths set/group, your hobbies, your answers to a learning-behaviours questionnaire, and your answers and working to a maths assessment. This helps us work out your level, create your learning profile, match you with the right tutor, and inform our algorithm for recommending tutoring materials and methods. Our lawful basis is performance of our contract with you and our legitimate interests in building a rounded picture to provide the best service.

‍Students — offline tutoring: we collect your name, address, email address and telephone number, and may ask your age, year group and school, so that we can identify and communicate with you and create and tailor classes. Our lawful basis is performance of our contract with you.

‍Parents/carers — contact details (name, email and any feedback, collected at the end of the Learning Profile Assessment): so that we can contact you about our services or information you have requested, send marketing emails, and enable tutors to send you progress reports. Our lawful basis is performance of our contract with you or the student under your care and/or our legitimate interests; and, for marketing, your consent or our legitimate interests (with an opt-out).

‍Parents/carers — payment details: depending on your payment method, we process your bank account details or debit/credit card numbers to manage payments, fees, charges and refunds. Our lawful basis is performance of our contract with you and our legitimate interests in managing payments.

Information we collect automatically and information we create

‍Students — behavioural information: when you take classes or receive tutoring, we create information about your learning behaviours and progress to monitor and track your progress, tailor our services, and develop the way we provide our services. Our lawful basis is performance of our contract with you and our legitimate interests in developing and providing our services.

‍Online users — website and technical data: we automatically collect certain data when you use our website or open our emails, using cookies, pixels and similar technologies. This may include your IP address, device ID, location, browser type and internet service provider (see “Cookies and Similar Technologies” below). We use this to provide, personalise, measure and improve our website and to assess our email campaigns. Our lawful basis is your consent (for optional cookies) or our legitimate interests in operating our website and informing our marketing strategy.

‍Online users — payment details: as above, processed to manage payments; our lawful basis is performance of our contract and our legitimate interests in managing payments.

‍Tutors: we collect photos/video (for your tutor profile and marketing, on the basis of consent or our legitimate interests); your name and email (for your profile and to communicate with you — contract and legitimate interests); your address, postcode, phone number and emergency contact details (to communicate with you and comply with our legal, employer/contractor and health-and-safety obligations, stored on your profile but not visible to students/parents — contract); your DBS number and certificate (to comply with safeguarding obligations — contract and legitimate interests in engaging suitable tutors); your qualifications and education history, interests and hobbies, and availability (for your profile, matching and scheduling — contract and legitimate interests); and your replies to tutor/student matching questionnaires (for matching — legitimate interests). If you are engaged in our offline tutoring we collect the equivalent contact, DBS, qualification, availability and emergency-contact details for the same purposes.

Legal requirements

In addition to the uses above, we may also process your information where we are required by law to do so or if we reasonably believe it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Special categories of personal data

There are more limited bases for processing special category personal data (which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation) and criminal convictions and offences data.

We ask all our tutors to undertake a Disclosure and Barring Service (DBS) check and so we may process information about criminal convictions and offences as part of those checks. This is to assist us in assessing the tutor’s fitness and propriety to perform their role. Because this is criminal-offence data, our processing is carried out under Article 10 UK GDPR and a condition in Schedule 1 to the Data Protection Act 2018 — namely safeguarding of children and of individuals at risk (paragraph 18) and, where relevant, our legitimate interests in ensuring the fitness and propriety of our tutors and compliance with regulatory requirements. We maintain an Appropriate Policy Document governing this processing, as required by the Data Protection Act 2018, which is available on request.

Otherwise, we do not intend to actively collect special categories of personal data about anyone. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally — for example, where you volunteer special category data to us, such as if you send us an email containing it. Where we do hold special category data (for example, information about a student’s health or additional learning needs shared with us to help us support them), our condition for processing is your explicit consent or, where applicable, the substantial-public-interest or safeguarding conditions in Schedule 1 to the Data Protection Act 2018. Where possible, we request that you redact or otherwise withhold such data unless it is necessary to provide it and it has been manifestly made public by you.

Health, allergy and special educational needs (SEN) information about students

We do not routinely require health or SEN information, but a parent/carer or student may choose to share it with us — for example a medical condition, an allergy, or a special educational need or additional learning requirement — so that we can support and teach the student safely and appropriately. Where this happens, we may record that information within our Educai platform or our customer relationship management (CRM) system. We treat this information as sensitive and confidential.

Health information is special category data under Article 9 UK GDPR. Where we hold it, our condition for processing is your explicit consent or, where applicable, the safeguarding-of-children or substantial-public-interest conditions in Schedule 1 to the Data Protection Act 2018, and we maintain an Appropriate Policy Document for this processing. Information about SEN or additional learning needs is treated with the same care. Access is limited to the authorised members of staff and tutors who need it in order to support the student; it is stored securely, retained only for as long as necessary, and you may ask us to update or remove it at any time.

What if you do not provide the personal data requested?

Where we need to collect personal information by law, or under a contract we have with you, or in order to provide you with information you have requested, and you do not provide it when requested, we may be prevented from complying with our legal obligations or unable to perform all or part of our contract or provide the information requested. For example, we require certain information about a student in order to select an appropriate tutor and create a tailored learning path, your contact details in order to send you information, and your payment details in order to process payment.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use it for an unrelated purpose, we will notify you and explain the lawful basis which allows us to do so.

Who will we share your personal data with?

We may share your personal data where required by law, where necessary to perform our contract with you, where we have another legitimate interest in doing so, or with your consent. The parties with whom we may share your personal data include: (1) payment service providers who process card payments on our behalf; and (2) other service providers such as data management and storage providers who host our services, and marketers and advertisers who assist us. We put in place a written data processing agreement with each processor requiring them to protect your personal data and act only on our instructions.

We may share your personal data with third parties, for example in the context of a possible sale or restructuring of the business, or with a regulator or to otherwise comply with applicable law or judicial process.

As part of our own learning process and to improve our services, we have engaged certain third parties worldwide (our affiliates) with whom we exchange information on our students, tutors and assessments in order to connect students and tutors and monitor the learning experience. Where we share children’s data internationally with affiliates, we do so only where a lawful basis applies and appropriate safeguards are in place. Where possible we anonymise or pseudonymise the data so that affiliates cannot identify you, rendering it general information rather than personal data. If we are required to share identifiable personal data, we take precautionary measures to ensure it is protected by the same safeguards as required by UK data protection law.

WoM is based in the UK but we use some service providers who host and provide services from other countries, including the USA. These countries may not have the same standard of data protection laws as the UK but, where required, we have put in place appropriate safeguards. These safeguards are the UK ‘adequacy’ regulations where the country or provider is covered by them, or the UK International Data Transfer Agreement (or the International Data Transfer Addendum to the EU Standard Contractual Clauses) where it is not. You can request further information about these transfers and safeguards from info@wondersofmaths.com.

Cookies and similar technologies

We, as well as third parties that provide content or functionality for our website and services, may use cookies, web beacons, pixel tags and similar technologies to understand usage of our website and interactions with our emails, and to improve our content and offerings. Strictly necessary cookies are always active. We set analytics and other non-essential cookies only with your consent, which we obtain through our cookie banner. The banner lets you reject non-essential cookies as easily as you can accept them, and you can change your choice at any time. For more information on cookies, please read our Cookie Policy at https://staging.educai.io/cookie-policy.

How long will we retain your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such records. In doing so we have regard to the amount, nature and sensitivity of the data, the potential risk of harm, the purposes of processing, whether we can achieve those purposes by other means, and applicable legal requirements. Generally, we will keep information relevant to our dealings with you for a maximum of 7 years after our relationship with you ends. In some circumstances we may anonymise your personal data so that it can no longer be associated with you. Once we no longer require your personal data, we will securely destroy it in accordance with applicable laws.

How we keep your personal data secure

We have put in place appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or disclosure. We limit access to your personal data to those who have a business need to access it, and they are subject to a duty of confidentiality. We also have procedures to deal with any suspected personal data breach and will notify you and the ICO of a breach where we are legally required to do so.

Accuracy of personal data

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Your rights in relation to your personal data

You have rights as an individual which you can exercise in relation to the personal data we hold about you in certain circumstances. These are to: request access to your personal data (a “data subject access request”); request rectification; request erasure; request restriction of processing; object to processing; not be subject to a decision based solely on automated processing which significantly affects you; and request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact us at info@wondersofmaths.com. We will respond within one month of receiving your request (we may extend this by up to two further months for complex or numerous requests, and will tell you if so). When responding to an access request we are entitled to carry out a reasonable and proportionate search for your personal data. We will do our best to accommodate your request or objection but please note that not all rights are absolute.

You also have the right to make a complaint at any time to the supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office. We would, however, appreciate the chance to deal with your concerns first, so please contact us before doing so. The ICO can be contacted at www.ico.org.uk, by telephone on 0303 123 1113, or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Fees

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact info@wondersofmaths.com, or, where applicable, by clicking the ‘unsubscribe’ link in the emails you receive from us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we now have an alternative legal basis for doing so.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy available on our website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Further information

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact info@wondersofmaths.com.