Privacy and Data Protection Policy

1.1 Who we are and what this policy covers

Tugo is a trading name of Trailblaze Education Ltd, a company registered in England and Wales with company number 15855007, whose registered office is 41 Streathbourne Road, London, SW17 8QZ. We provide online group tuition to children in Years 5 to 13.

This policy explains what information we hold, why we hold it, who else sees it, how long we keep it and what you can ask us to do about it. It covers everyone whose information we handle: the parents and guardians who buy our classes, the children we teach, people who enquire but never buy, and the tutors who work with us.

We are committed to handling your information properly and in line with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations.

1.2 This document is also our data protection policy

We deliberately keep one document rather than two. This policy is both our public privacy notice and our internal data protection policy.

Where our tutor agreements, staff agreements or contracts require someone to comply with "the Company's data protection policy", or to process personal data "in accordance with the Company's written instructions", this document is that policy and section 13 contains those instructions. If you work with us in any capacity, section 13 is the part that applies to you and you are expected to have read it.

We do this so that there is one place to look, one version to keep current, and no gap between what we tell families we do and what we require of the people who do it.

1.3 Who is responsible, and how to reach us

Trailblaze Education Ltd is the data controller for the information described in this policy. That means we decide what is collected and why, and we are the organisation answerable for it.

You can reach us about anything in this policy at privacy@tugotutors.com, or by post at 41 Streathbourne Road, London, SW17 8QZ, United Kingdom. A person reads that inbox.

We are not currently required to appoint a Data Protection Officer and have not appointed one. We keep that under review as we grow, and in the meantime our directors are accountable for data protection and privacy@tugotutors.com reaches them.

1.4 Complaining to the regulator

You have the right to complain at any time to the Information Commissioner's Office, the UK's data protection regulator, at ico.org.uk or on 0303 123 1113. We are registered with the ICO.

You do not need our permission and you do not have to come to us first. We would genuinely rather hear about it and fix it ourselves, so please do tell us if you can — but that is a preference, not a condition.

2.1 About you, the account holder

If you buy a class from us, we hold:

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  Who you are: your name, email address and phone number.
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  What you bought: which plan, which subject, which class, when it started and when your access runs to.
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  Payments: the amount, the date, whether it succeeded, any refund, and a reference to the receipt. Your card details are handled by Stripe and never reach us — we cannot see your card number.
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  Which version of our policies you accepted, and when: so that both of us can tell what you actually agreed to.
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  Messages between us: emails, WhatsApp messages and notes from calls.
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  How you use our website: pages visited, device and browser type, and general location from your IP address. See section 11.

2.2 About your child

We hold deliberately little about the child we teach, and no child has an account with us. We hold:

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  Their first name, and their last name where you gave it. Tutors see only a first name and a last initial.
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  Their year group and the subject they are studying.
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  Which class they are in, and when they joined and left it.
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  Their work in lessons, and what our tutors and AI assistant made of it: marks, feedback and progress reports. Section 4 explains this in full.
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  Anything we have been told that affects their learning: a special educational need, or an access arrangement, where you have chosen to tell us.

We do not ask for your child's date of birth, home address, school or exam results. We do not ask them to create a profile, and we do not use their information to advertise anything to them or to you.

2.3 About people who enquire but never buy

Most families reach us through the enquiry form on our website, or through an advert on Facebook or Instagram. If you do that, we hold your name, email address, phone number where you gave it, your child's year group, the subjects you asked about, and what you told us you were hoping to achieve.

We record this before you continue to WhatsApp so that a lead is not lost if something fails on the way, and we copy it into HubSpot, our customer relationship system, so that whoever calls you can see what you asked for. If you book a free trial lesson, we also hold which lesson you booked and your child's first name.

We keep this for 24 months from the last time we heard from you, and then delete it. See section 8.

2.4 About our tutors

If you tutor with us, we hold rather more, because we are engaging you to work with children:

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  Contact and identity: your name, title, email, phone and mobile numbers, address, town, postcode, country and timezone.
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  Your professional record: your qualifications, the institutions you attended, the subjects and levels you are approved to teach, your biography, tagline and photograph.
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  Your DBS status: whether you hold a current Enhanced DBS certificate or Update Service registration, and the date it was issued. We do not keep a copy of the certificate or record what it says.
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  Your engagement with us: the classes you have taught, your rate, your invoices, and notes we have made about your work.
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  Historic records: where you previously worked with us through TutorCruncher, the record we exported when we moved off it.

Whether you appear on our public website is a separate choice that is yours to make, and it is off unless you have turned it on. Your name, photograph and biography are not published because you have a tutor record with us; they are published because you have agreed to it, and you can withdraw that at any time.

2.5 Sensitive information, and what we do not collect

Some kinds of information get extra protection in law — information about health, race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, sex life or sexual orientation, genetic and biometric data, and information about criminal offences.

We do not ask anyone for any of it, and none of it is needed to buy or attend a class. There are two exceptions, and we would rather set them out plainly than make a sweeping claim that is not quite true:

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  Tutor DBS status. We record whether a tutor holds a current Enhanced DBS certificate and the date it was issued, because we will not put anyone in front of children without one. We do not hold the certificate or its contents.
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  Safeguarding concerns. If a concern is raised about a child's welfare, the record of it may unavoidably contain information about health, family circumstances or alleged criminal conduct. We do not choose to collect this; it arrives with the concern.

For both, we rely on the safeguarding condition in Schedule 1, Part 2 of the Data Protection Act 2018 — protecting children and individuals at risk from harm. We hold a policy document covering this processing, as that Schedule requires.

If you volunteer sensitive information to us — telling us about your child's diagnosis so their tutor can teach them better, for example — we will use it only for that purpose, and only tell the people who need to know.

3.1 The reasons we rely on

We are only allowed to use your information where the law gives us a reason to. These are the reasons we rely on:

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  To perform our contract with you. We cannot teach your child, take payment or tell you when a lesson has moved without using your information.
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  Our legitimate interests. Running and improving a tuition business — following up an enquiry, keeping our teaching under review, preventing fraud. We only rely on this where it does not override your rights, and you can object.
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  Legal obligations. Keeping accounting records, responding to lawful requests, and meeting our safeguarding responsibilities.
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  Your consent. For a small number of things that are genuinely optional: publishing a tutor's profile, non-essential cookies, and using a child's work in our marketing. Where we rely on consent you can withdraw it at any time, and nothing you have to have works differently if you do.
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  Protecting someone's vital interests, and the safeguarding condition in the Data Protection Act 2018. Where a child may be at risk of harm.

3.2 What we use it for

Examples in this table are illustrative rather than exhaustive, but we never use your information without one of the reasons above.

3.3 If we want to use it for something new

We will only use your information for the purposes we collected it for, unless the new purpose is compatible with the original one. If it is not, we will tell you and explain what allows us to do it — or ask your permission.

4.1 What it processes

While a lesson is running, the assistant processes:

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  Images of your child's work. It takes a picture of the slide your child is working on, including anything they have typed, written or drawn, and analyses it to see whether the answer is right and where they have gone wrong.
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  Your child's name as it appears in the online classroom. So that one child's work is not confused with another's, and so feedback reaches the right person.
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  What it decides and what it writes. The marks it gives, the feedback it writes onto your child's work, and the reports it drafts after a lesson and at the end of each month.

4.2 Who else sees it

The images and the name are sent to Google, which provides the AI model that analyses them. Google processes them on our instructions in order to return an answer to us, and under our agreement with Google this material is not used to train its models.

Your child's work itself is held in Classkick, the online classroom we teach in. Their tutor sees their work and the feedback, as any teacher would. Nobody else outside Tugo sees any of it.

4.3 Why we are allowed to do it

We rely on the performance of our contract with you. AI-assisted marking and feedback is part of the tuition you bought, and it is how a Tugo class works — we are not able to offer a class without it. If that is not something you want for your child, please do not buy a class, and if you have already bought one, tell us and we will refund you.

Where we use the same material to review and improve our own teaching, we rely on our legitimate interests, and you can object to that use specifically without giving up the class.

4.4 How long we keep it

Images of your child's work are working data — they exist so that the assistant can look at a piece of work once, during the lesson. We delete them within 7 days.

Marks, feedback and reports are kept until the end of the academic year after the one they were made in, so that you and your child's tutor can look back over their progress. After that we delete them.

4.5 Decisions about your child

The assistant does not make any decision about your child on its own, and nothing it produces has a legal or similarly significant effect on them. A tutor is present throughout every lesson and is responsible for it.

Some feedback is shown to the tutor to approve before your child sees it. Some is delivered to your child during the lesson without a tutor reading it first, so that they get help at the moment they are stuck rather than several minutes later.

Progress reports are different: the assistant drafts them, and a member of our team reads each one before it reaches you. If we ever change that, we will tell you before we do and update this policy.

You can ask us for a human review of anything the assistant produced about your child, and we will give you one.

4.6 When it gets something wrong

AI-generated marks, feedback and reports can be wrong, and handwriting is exactly the kind of thing software misreads. If you or your child think something is mistaken, tell us at privacy@tugotutors.com or hello@tugotutors.com.

We will look into it, correct the record, and tell you what happened. This is your right to rectification, and using it is not a complaint — it is how we find out that something is not working.

5.1 Whose information it is

Most of the people we teach are between 9 and 18. Their information belongs to them, even though the account and the contract belong to their parent or guardian.

We hold as little about a child as we can. We do not build profiles of children, we do not use their information to advertise to them, we do not use nudges or design tricks to get them to share more than they need to, and we do not sell or share their information with anyone for their own purposes.

5.2 What your child can ask for

Your child has the same rights over their own information as an adult does, set out in section 9. In practice, and because they have no account with us, the quickest route is to ask through you.

A child can also ask us directly. If a child asks us for their information, or asks us to correct something, we will help them — taking account of their age and making sure we are talking to the right person. Where a request comes from a parent, we will normally deal with it, but if a young person is old enough to make the decision themselves and would not want it shared, their wishes matter and we will take them into account.

5.3 Talking to us about your child

Ask us at any time what we hold about your child and we will tell you. The only thing we would ever withhold is information whose disclosure would put a child at risk — and if that ever applied, we would say that we were withholding something rather than pretend there was nothing to see.

6.1 Keeping a record of a concern

If someone raises a concern about a child's welfare, we write down what was said, what we did about it and who we told. We keep very little: what happened, when, and the steps taken.

6.2 Why we keep these longer

We hold safeguarding records until the young person's 25th birthday. That is not because the information is useful to us — it is because a child who was harmed may not be ready to talk about it for years, and when they are, the record needs to still exist.

Every organisation that works with children keeps these records on that basis, and it is the one place in this policy where we deliberately keep something for longer than we otherwise would. It is also a very small number of records about a very small number of children.

6.3 Asking us to delete one

A safeguarding record is the one thing we may not be able to delete if you ask us to. If you do ask, we will look at the request properly and explain our decision rather than simply refusing.

It works the other way too: you are entitled to ask what we hold about your child and to see it, and we will only withhold something if showing it would put a child at risk.

Everything else we hold about your child — their work, their feedback, their reports, their attendance — is not treated this way. Ask us and we will delete it.

7.1 The companies that help us run Tugo

We do not sell your information and we never will. We do use other companies to run parts of our service, and they only ever handle your information on our instructions and for the purposes we set. These are the ones that matter:

7.2 Where in the world your information goes

Our database, our servers and our analytics are all inside the UK or the European Economic Area — Supabase and DigitalOcean in London, PostHog in Frankfurt. Some of the companies above are based in the United States, and using them means information reaching a country whose data protection laws are not the same as ours.

Where that happens we make sure the information is protected to a standard the UK recognises: either the UK's adequacy regulations, which cover transfers to the European Economic Area, or the International Data Transfer Addendum to the standard contractual clauses, or the UK Extension to the EU–US Data Privacy Framework where the company is certified under it.

You can ask us at privacy@tugotutors.com which of these applies to a particular company, and we will tell you.

7.3 The other times we share information

Beyond the companies above, we share information in these situations and no others:

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  Safeguarding. Where a child may be at risk, we will share what is necessary with children's social care, the police, the Local Authority Designated Officer, or a school. We will not ask permission first if asking would put a child at greater risk.
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  When the law requires it. A court order, a lawful request from an authority, or our own tax and accounting obligations.
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  To take or defend legal action. Including recovering money genuinely owed to us.
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  If our business changes hands. If Tugo is sold or merged, information may transfer to the buyer. We will tell you if that happens, and your information stays protected by a policy at least as protective as this one until you are told otherwise.

7.4 Links to other websites

Our website links to other places — WhatsApp, our booking tool, our tutors' universities. We do not control those sites and we are not responsible for what they do with your information. Have a look at their own privacy policies when you get there.

8.1 Our retention schedule

Where a period runs from an event, that event is in the third column.

We may keep something longer than this if there is a complaint, a safeguarding matter or a legal claim that is still live. If we do, we keep only what that specific matter needs.

9.1 What you can ask us to do

You have the following rights over the information we hold about you, and so does your child over theirs:

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  To be told what we do with it. That is what this policy is for.
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  To see it. Ask us for a copy of what we hold about you. This is sometimes called a subject access request.
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  To have it corrected. If something is wrong or incomplete, tell us and we will fix it. This includes anything the AI assistant got wrong.
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  To have it deleted. Where we have no good reason to keep it. Section 9.3 explains where we cannot, and why.
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  To object to what we are doing with it. Particularly where we rely on our legitimate interests, or where we are using it for marketing — in which case we will always stop.
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  To ask us to pause. To restrict what we do with your information while we look into an accuracy problem or an objection.
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  To take it with you. To receive information you gave us in a machine-readable format, or have us send it to someone else.
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  To withdraw consent. Where we asked for it. Nothing you need in order to use our service depends on consent.

9.2 How to use them

Email privacy@tugotutors.com. There is no form and no fee. We will reply within one month, and if your request is complicated enough to need longer we will tell you inside that month and explain why.

We may ask you to confirm who you are before we hand over information — not to make it difficult, but because sending your child's records to someone who is not you would be the worse mistake.

9.3 Deleting your account and your information

Email privacy@tugotutors.com and ask, and we will delete what we hold about you and your child. We will do it within one month and confirm when it is done.

There are two things we will not be able to delete, and we would rather tell you now than when you ask. We have to keep payment and accounting records for six years, because HMRC requires it. And a safeguarding record is kept as described in section 6. If either applies to you, we will tell you exactly what we have kept and why, delete everything else, and stop using what remains for anything but the reason we are required to keep it.

Everything else goes: your contact details, your child's details, their work, their reports, and your marketing preferences.

10.1 Messages about your child's class

While your child has a class with us we will email you about it — reminders, a changed time, a cover tutor, a joining link, a report, a receipt, a failed payment. These are part of the service and not marketing, so there is nothing to unsubscribe from while your child is enrolled.

10.2 Following up your enquiry

If you enquire about tuition, we will get in touch about tuition — by email, phone or WhatsApp. That includes a follow-up if we do not hear back, because in our experience one reminder is welcome and silence is usually a missed email rather than a no.

We do this because you approached us about buying something and we are replying about that thing. Every email we send you carries a way to stop them, and if you tell us to stop we will stop immediately and without asking why.

10.3 Wider marketing

If we ever want to email you about something you did not ask about, we will ask your permission first and record that you gave it. You can withdraw it at any time using the unsubscribe link in any message, or by emailing privacy@tugotutors.com.

We never market to children, and we never sell anyone's details to another company. We do not use your child's work, image, voice or name in our own marketing either, unless you have given us permission for that particular use in writing — and you can withdraw that permission at any time.

11.1 Your choices

When you first arrive on our website you are asked which cookies you are happy with. We manage that through CookieYes, and nothing beyond what the site needs to work is loaded until you have made your choice.

You can change your mind at any time using the cookie link on our website. Declining analytics costs you nothing — the site works exactly the same.

11.2 What we actually use

Two things beyond the essentials:

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  Google Tag Manager. How we load and manage the tags below. It runs after you have given consent, not before.
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  PostHog. Product analytics, so we can see which pages people find useful and where our website confuses them. Hosted in Frankfurt. If you are signed in, this is linked to your account so that we can support you when something goes wrong on your particular device.

We also measure the performance of our adverts on Facebook and Instagram, which is how we know whether an advert is worth paying for.

We do not use your child's activity in a lesson for analytics of any kind.

12.1 What we do

We take security seriously and we would rather describe what we actually do than make a general claim.

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  Your information is separated by account at the database level, so one family's records are not reachable from another's, and this is enforced by the database rather than by our website code remembering to ask correctly.
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  Sensitive fields are withheld from the public parts of our systems entirely, including your child's joining link and the link between a tutor and their login.
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  What a tutor can see is deliberately narrow: a first name and last initial, a year group and some dates. Not your email, not your phone number, not your child's surname, not what you paid.
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  Only a small number of people can reach your information, all of whom are bound to keep it confidential.
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  We never see or store your card details. Stripe handles those.

No system is perfectly secure, and information sent over the internet is never completely safe from interception. If we ever have a breach that is likely to put you at risk, we will tell you and the Information Commissioner's Office, and we will tell you what happened rather than the smallest amount we can get away with saying.

12.2 Your part

Please keep your sign-in details to yourself, and do not share your child's joining link. If you think someone has got into your account, email us and we will secure it.

13.1 Who this applies to

Everyone who handles personal data on our behalf: our directors and staff, every self-employed tutor engaged by us, and anyone a tutor arranges to take a class in their place.

Clauses 3.7 and 10.2 of the Tutor Services Agreement require you to comply with our data protection policy and to process personal data only in accordance with our written instructions. This section is both. Clause 12.1 means we can update it without renegotiating your agreement, so please read it again when we tell you it has changed.

If you arrange a substitute to take your class, you are responsible for making sure they are bound to these same instructions before they teach.

13.2 Your instructions

When you handle information about a child, a family or another tutor:

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  Use it only to deliver the teaching. Not for your own tutoring business, not for research, not to contact a family about anything else.
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  Keep it on the platform. Do not save a child's personal information or their work to your own device, your own cloud storage, your own email or your own notes. If you need something you cannot get to, ask the office.
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  Do not record lessons, and do not photograph or screenshot a child's work or a class, unless the office has asked you to for a specific reason.
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  Contact families through us, not directly. You are not given a parent's email or phone number, and that is deliberate. If you need to reach a family, the office will do it.
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  Do not share a joining link with anyone. Not another tutor, not a family, not a colleague.
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  Keep it to yourself. Do not discuss a child by name outside Tugo, including with other tutors who do not teach them.
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  Use a device only you can get into, with a password or passcode, kept up to date, and not shared with anyone at home.
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  Collect only what you need. If a family volunteers something about a child's health or home life that helps you teach them, pass it to the office and use it for that. Do not go looking for more.

13.3 If something goes wrong

Tell us within 24 hours. Email privacy@tugotutors.com and copy your usual contact, or phone if it is serious.

"Something going wrong" means a lost or stolen device, an email to the wrong person, a joining link that got out, a shared password, or simply a suspicion that information has been seen by someone who should not have seen it. Clause 10.3 of your agreement requires this within 24 hours, and the law gives us only 72 hours in total to tell the regulator — most of which we need for working out what happened.

Tell us even if you are not sure, even if you think it is small, and even if it was your mistake. We would far rather know early. Nobody has ever been in trouble with us for reporting something promptly.

13.4 Safeguarding comes before this policy

If a child tells you something, or you see something, that makes you worried about their safety, none of the confidentiality rules above stop you acting on it. Report it to the Designated Safeguarding Lead straight away.

If a child is at immediate risk of harm, contact the emergency services or children's social care directly and do not wait for anyone at Tugo. Our Safeguarding Policy sets out how to do this and who to call.