1. GENERAL

This Privacy Policy (the "Policy") forms an integral part of our Terms of Service (the “Terms of Service") and describes our practices regarding the collection, use and disclosure of the information we collect from and relating to you when you use our websites at: www.tutorela.com and www.tutorela.es (the "Website") and our services.
We at Limud Naim Ltd. take our obligations regarding your privacy and personal data seriously and have prepared this Policy in a manner that is clear and easy for you to understand.  

In general, you can use our Services without giving us any personal data. If you choose to register as a tutor, open a personal page, or sign in as student in order to get all of the benefits, then you must provide us with your age, email, address etc. and other information which pertains to be Personal Data (as such term is defined by applicable data protection law).

We may use and process your Personal Data in accordance with this Privacy Policy. Capitalized terms not defined herein shall have the meaning ascribed to them in the Terms of Service.

By using the Website, you hereby explicitly consent that we may process your Personal Data in accordance with this Privacy Policy. If you do not agree to the terms and conditions set forth herein, please do not use our Website or our services.

2. INFORMATION WE COLLECT

We collect Personal Data, such as your name, address, age, contact details and the like, when you sign up to our Website or our Services, only as long as it is needed to fulfill the purpose of processing as detailed hereunder.

Further, we may record the videos and call that the tutor makes as part of our marketing and customer support, some of these calls may be recorded by a service operator or any other sub processor. You acknowledge and agree that we may record conversations between the tutor and the student, and you have no objection for such recording.

Students and parents

We may also collect Personal Data related to your documentation of and payment for tutoring sessions; tutoring questions related to homework or your studies; school information; tutors feedback of a student (once the parent provides consent for submission); and content you upload for the purposes of transmitting it to another user or for public display on the Services platforms.

If you elect to pay for tutoring lessons we may utilize a credit card payment processing service provider to collect payment information, including your credit card number, billing address and email. Such information is collected by the credit card payment processing service provider.
To learn more please see our Notice to Students.

Tutors

We may also collect Personal Data, bank account details for transferring payments and content you upload for purposes related to transmission to other users or public display on the Site or Apps. We also collect bank account information to facilitate payment.
To learn more please see our Notice to Tutors.

Cookies:

We use cookies on the Websites. We use them for the following main purposes:

  • to associate each of the pages that you visit on our Websites with each other and thereby allows us to present the correct information to you; 
  • to keep you signed in to our Websites and ensures the content you are viewing is secure;
  • to maintain your personal preferences

You can delete advertising cookies in your browser by using this form: https://optout.aboutads.info/

3. PURPOSES FOR USING THE PERSONAL DATA

We use the Personal Data we collect, store and process, in order to:

  1. Provide our customers with our services through the Website.
  2. Communicate with you with respect to the Website or our services and respond to queries.
  3. Provide updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Website, and administering our Website.
  4. Improving your user experience when you visit our Website.
  5. Monitor aggregate metrics and statistical information regarding our Website and users thereof; and personalize and improve the Service, deliver and display targeted advertisements on our Service, content or features in the Service and for administration of and troubleshooting regarding the System.
  6. Diagnose and fix technical problems reported by our users or engineers. The processing of your account information is completely segregated from the processing areas of the service in our systems, and your account information will not be used for any purpose other than to enable the management and use of your account.

4. SHARING DATA WITH THIRD PARTIES

We do not sell or disseminate Personal Data to third parties for marketing purposes without your consent.

However, we share Personal Data with service providers and third parties for our operational and analytical purposes to enable the provisions of our Website services. Third parties who provide crucial functions such as: customer support platforms, hosting service providers, payment processors, analytics partners, third party account providers, security and/or social media services.

We may also share Personal Data to comply with applicable laws and regulations or to respond to a lawful request for information we receive.

5. DATA RETENTION

We may retain communications with you in order to process your inquiries, respond to your requests and improve our Websites and/or services we provide. Unless instructed otherwise by a user, by default we do not retain identified usage data. We also periodically review and delete or de-identify inactive data and related personal data that have been inactive for five years.

6. CHILDREN’S PRIVACY

You must be 14 years old or older to use the Website or our services; If you are under 14 years old, you agree that you received your parent or legal guardian's consent to use and access the Website or our services. We do not knowingly collect information from children under the age of 14 without receiving their parent or legal guardian's consent. If we become aware that we have collected Personal Data from a child under the age of 14 years old without parent or legal guardian's consent, we will use commercially reasonable efforts to delete such information from our database.

7. YOUR PRIVACY RIGHTS

You have certain rights in connection with your Personal Data and the manner by which we handle it. Some of these rights may be subject to certain exceptions or limitations in accordance with applicable law. The following is a non-exhaustive list of certain privacy rights you may exercise:

  • Right to access your or your end-user's information. At any time, you may contact the Company as provided below, and request to access the Personal Data we hold about you.
  • Correcting your or your end-user's information. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, please provide us with the necessary information in order to correct it.
  • Withdrawing your or your end-user's consent. You are entitled to contact us if you would like to withdraw your consent to the processing of your Personal Data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
  • Deleting or restricting access to your Personal Data. You may request to delete or restrict access to your Personal Data. We may postpone or deny your request if your Personal Data is in current use for providing services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.
  • Opt-out of cookies and other similar technologies. Your browser or device can allow you to opt-out of data collection through cookies or similar technologies. Please note that your experience using our website or the Services might be degraded or certain functionalities may not work, if you opt-out to such collection.
  • Opt-out of marketing communications. If you wish to opt out of our use of your contact information for our direct marketing purposes, you can click the "Unsubscribe" button located within the most recent marketing email you received from us or contact us at.
  • Additional opt-out rights. Depending on where you are located, you may have additional rights to opt-out of certain uses of Personal Data.

If you have any concerns about the way we process your Personal Data, you are welcome to write to us at: [email protected]. We will look into your request and make good faith efforts to resolve any concern you may have. We aim to respond to a data subject request for access or deletion within 30 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

8. INFORMATION SECURITY

We use appropriate technical and organizational measures designed to protect the Personal Data of our users. Our security practices conform to the best practices of applicable Israeli law.

The measures we employ are designed to provide a level of security appropriate to the risk of processing your Personal Data and we continuously develop them. Our measures vary, but typically include controls to limit access to services or systems that contain Personal Data, pseudonymisation, databases protected by firewalls, passwords, and other technical measures.

9. CROSS-BORDER DATA TRANSFERS

We may store and process information in a member state of the European Union, in another signatory state of the Agreement on the European Economic Area, or in another country outside the European Economic Area non the basis of any adequate decision of the European Commission that have an adequate level of data protection, or through cloud services. Most of the access and processing activities may be performed from Israel. The laws of this country have an adequate level of data protection. You agree to the transfer of your information to other countries for the purpose of the processing as described in this Policy, including through cloud services.

10. LEGAL BASIS FOR PROCESSING PERSONAL DATA

11. CHANGES TO OUR PRIVACY POLICY

If you have questions or concerns regarding this Privacy Policy, please contact us. the data controller, at: [email protected].

Information Type Purpose Legal Basis
Processing Personal Data Provision of the Services The legal basis under applicable law for processing and collecting your Personal Data is our legitimate interests in operating our Services.
Processing Personal Data Online marketing and profiled advertising? The legal basis under applicable law for collecting and processing your Personal Data for profiled advertising purposes is your explicit consent.
Processing Analytical Information Operation and enhancement The legal basis under applicable law for processing and collecting analytical data is our legitimate interests in operating our services, ongoing management of our business and business development