Privacy Policy

SOTC LTD, a company registered in England and Wales (No. 09328574), herein referred to as ‘Spires’ or ‘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. Unless otherwise indicated all definitions in the Client Policy and the Tutor Policy shall apply to this Statement. 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 the Terms of Service and the Tutor Policy and/ or the Client Policy (where applicable) by this reference.

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 Britain's Data Protection Act 1998 (“DPA”).

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, 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 who 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. We do not knowingly collect any personal information from children under the age of 13 and the services offered by Spires are not intended for use by children.

HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION

We only collect personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information.

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.

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 our 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;
• 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; and
• 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, including for the purposes of completing or arranging for the completion of background checks and other searches. Such a request, and your consent to such request, may be given in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.

DPA permits Spires to disclose personal information to third parties without the affected party’s 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;
• 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;
• 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.

Personal information supplied to us is confidential and we do not disclose the information to any third party 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 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.

PROTECTING YOUR PERSONAL INFORMATION

We strive to maintain personal information in as 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.

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 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 time of the tutoring session.

Our website uses cookies, which are identifying technologies that your computer receives when you visit certain websites. We do not match or correlate this information with any personal information that you submit to Spires. 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. 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 web site. Your IP address is used to help identify you for the purposes of gathering broad demographic information.

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 web sites nor does Spires warrant the quality, accuracy or completeness of information contained in these sites.

ACCESSING YOUR PERSONAL INFORMATION

You may write to our Privacy Officer to request access to personal information about you. Spires will generally inform you if we are holding personal information about 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

If you wish to request access to personal information about you, request a correction to information about you or have questions about our privacy policy, you may contact our Privacy Officer at support@spires.co

RECOURSE

If you have a concern about the personal information handling practices of Spires, a complaint, in writing, may be directed to our Privacy Officer. Upon verification of your identity, we will 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 Privacy Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.