The Privacy Notice below describes how your data is collected and used.

Over time the Privacy Notice has been updated. I only update the Privacy Notice when I feel that wording could be improved to make things more transparent or where a new service is introduced on the website (or where the law changes).

I will never change the Privacy Policy retrospectively to retain more data. Please check this page regularly, as changes may be made over time.

Who I am (The Data Controller as well as the service provider)

Adam Wardle, 43 Miller Drive, Fareham, Hampshire PO16 7LY trading as a sole trader (Email: This email address is being protected from spambots. You need JavaScript enabled to view it.)

Who I hold information on

I hold personal data on:

  • People who contact me

  • Customers

  • People who visit my website

  • People who use contact me via my social media pages (Facebook. Twitter, etc.)

  • People who communicate with me through Skype (or other chat service)

  • People/Companies I use for business services (e.g. advertising)

How I receive your information

Information I have about you comes from us getting in contact with each other. Normally this is by you emailing me with an enquiry or booking with me, but it could be by you phoning me or booking through a third party website.

You could alternatively provide me information through one of my social media pages (Facebook, Twitter, etc.), your use of Skype (or other chat service) or your use of this website.

What kind of information I may hold about you

For the majority of customers the only personal information I hold is name, address, email address and possibly telephone number.

Please note that depending on how you pay me your details can appear on my bank statements against your payments (e.g. if you pay by bank transfer your name/account details may appear on my statements).

I may hold additional information from your use of the website (or where you contact me or leave information on one of my external Social Media pages). Please see:

  • ‘Cookies/Website/Google Analytics/reCAPTCHA’

  • ‘Information relating to social media sites’; and

  • ‘Information relating to Skype (and other chat services)’

all of which are below.

Why I collect this information

The personal data is necessary for me to:

  • deal with customer enquiries (e.g. someone emails about tuition, so I email back with a quote);

  • provide my services to you under the terms of our contract (e.g. book appointments etc.);

  • comply with my legal obligations, for example tax (e.g. I write down your name and address on my accounts against a payment you make me, as the tax authorities require me to record who I receive any payments from); and

  • deal with enquiries in relation to payments

Where you wish for a written quotation, I cannot do so without your basic contact details (e.g. an email).

Without your name and address I cannot provide you with tuition.

The legal basis for processing your information

I need to process information for the following reasons:

  • The performance of the contract with you or for me to take steps for me to enter into a contract

    • This covers situations such as where someone makes an enquiry with a view to booking tuition, I may use their email address to email back with a tuition offer.

    • This also covers situations such as where someone with an existing contract emails me about tuition and I email back.

    • This also covers things such as me booking appointments.

  • The perfomance is in compliance with a legal obligation, such as providing information to a tax or other authority

    • This covers situations, such as where I record personal details on my accounting records to show where payments have come from. Like any other business I am required by law to keep full detailed accounts. This includes providing details on who I receive payments from as well as details of any refunds I make.

    • HMRC requires me to retain details relating to payments received and refunds made to prove the authenticity of my accounts (for example correspondence in relation to refunds I make).

    • I also may need to provide copies of my bank statements to HMRC, which show payments in from you (and payments made to you, for example, in the event of a refund).

    • Although it is unlikely, I may possibly need to provide evidence to HMRC of cancellations, contract terms or other correspondence between us if required by them. In this event this may involve showing emails from customers to HMRC.

    • Regarding Coronavirus impact: Please note that HMRC has previously announced that businesses making any claims relating to Coronavirus impact are required to retain evidence of Coronavirus impact. This does not make any difference to data being retained, but it means that HMRC may (possibly) ask for and require sight of customer correspondence, such as customer emails cancelling tuition because of the Coronavirus situation.

  • The performance is in relation to a legitimate interest:

    • I keep customer reviews (typically emails) so that their authenticity can be verified.

    • I store correspondence relating to contracts (e.g. cancellation emails) in case of a later query or complaint.

    • I may need to show an accountant doing services on my behalf accounts records, correspondence supporting any financial claim, etc.

    • If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). As a result, I may need to present some bank statements to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements show the names of the people who paid me, which is personal data).

I do not do mailing lists, etc.

I do not do mass marketing emails, etc.

Test and Trace

To support the NHS Test and Trace programme, I will be keeping a record of all visitors in person (if ever there are visitors in person and the Test and Trace system is still in place at that time). The aim of the NHS Test and Trace programme event is stop the spread of Covid-19. The visitor record would include details of:

• your name
• your contact phone number
• the date of your visit
• your arrival time
• your departure time

I will only share your details with NHS Test and Trace, if asked by the service.

Each visitor record will be destroyed after 21 days have passed (i.e. on the 22nd day).

You can opt out of the Test and Trace system if you wish, but are strongly recommended not to do so.

Visitor Record

In addition to the Track and Trace record detailed above, a record of all visitors to art is kept, as this is required by the hall for their insurance purposes. This is being kept for up to six years and ten months.

Please note I also need to keep a record of who is physically present at sessions, leaves early, etc. in case of a fire, etc. (required by insurance as well as the hall for safety reasons).

Information relating to social media sites

With the exception of private messages you send me through a social media account, my social media accounts are by their very nature public. Consequently when you submit any information, ‘like’ a page/article/comment or leave a comment, etc. on any of my social media accounts, by its very nature you are making that information/action you take public. Usually such information stays on my public social media pages indefinitely (e.g. liking a page, leaving a review, commenting on a post I make, etc.).

As the social media services are public anyone can look at them, so any information or action you make public will be available for anyone to see. I cannot control how other people use that information. In short, if you are not happy for anything you do on the social media accounts to be made public, please do not do it in the first place.

Retention periods in relation to social media accounts

  • The individual social media services will have their own Privacy Policies which you should be aware of. I have no control over their Privacy Notices and their retention of data.

  • As regards notification emails, these fall into two groups:

    • Email notifications I receive giving details of customer reviews I may keep indefinitely. This is under the legal ground of legitimate interest, as I may need to prove the authenticity of reviews in the future.

    • Other social media notification emails will be deleted by me within a maximum of one year (with the exception of where I am required to retain them by law (e.g. court order), in which case they will only be kept for so long as the law requires me to do so).

  • As regards private messages received through a social media account:

    • These will be deleted within a maximum of one year with two exceptions:

      • 1. Where you book tuition within a year (or already have a contract with me), the message (and/or a copy of the message) may be kept by me for a maximum of six years and ten months. This is done under the ground of legitimate interest, as I may need to deal with queries or questions relating to what was said/agreed or to deal with a possible complaint.

      • 2. Where I am required to retain the private message for longer by law (e.g. court order).

Information relating to Skype (and other chat services)

Skype and any alternative chat services (if ever used) have their own Privacy Policy which you should consult. Their retention of data is subject to their individual Privacy Policies over which I have no control.

The only data I technically have control over on Skype is your username, which may or may not be personal data depending on the circumstances. Using your username is necessary for us to be able to chat to one another. This is likely to be the same for other chat services (if ever used).

Any information exchanged during Skype sessions is likely to be general in nature and related to, say, the language being learned, rather than personal data.

I will delete you from my Skype contacts (and consequently any conversations my end if not done automatically) within a year of you completely finishing sessions. I keep these conversations for that one year on the grounds of legitimate interest. This is to enable me to deal with the unlikely event of a complaint.

Tax Deductible Expenses

This is unlikely to be of relevance to customers, but is included here for completeness. I am required by law to keep evidence of tax deductible expenses. I retain such documents for up to six years and ten months (unless required by law to retain them for longer e.g. court order, in which case I would not keep them longer than required by law).

Foreign Visa Applications

If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). This may mean I may need to present some bank statements to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements show the names of the people who paid me against payments made, which is personal data). This does not affect the data that I retain, but is mentioned for completeness. Using data in this way (if ever it is) would be done under the ground of legitimate interest.

Bank Statements

For clarity, bank statements which may have details of your payments are kept for up to 6 years and 10 months from the statement date. (Due to the nature of statements, each statement shows the previous months´ transactions therefore I may have details of transactions from up to 6 years and 11 months in the past). As detailed previously statements are kept, as they may be required by HMRC.

How long I will retain your information

For details on the retention of i) my social media accounts and ii) Skype (and other chat services) and iii) evidence of tax deductible expenses (unlikely to affect customers) please see the relevant sections above, but this section sets out the retention limits of all other data.

Where you do not book tuition at all, data (e.g. emails, etc.) in relation to your enquiry may be kept for up to one year from the date when you last contact me.

Where you do book tuition, albeit at a later date, (or where you have paid for my details through a third party website), data (e.g. email enquiries, email correspondence, accounts records, etc.) may be kept for a maximum of six years and ten months with the exception of:

  • Correspondence with people continuing tuition on an ongoing basis.

    • Where someone is receiving tuition on an ongoing basis, documentation (e.g. emails) relating to the terms of the ongoing contract may be kept. (It would be very unusual for someone to be receiving tuition under the same contract for such a length of time). All other documentation will be retained (or deleted) in accordance with the other provisions of this Privacy Notice.

  • Customer reviews

    • As regards customer reviews, I keep these indefinitely to prove the authenticity of these in the future.

  • Where required by law

    • This would cover the situation where I am required to keep documentation because of, for example, a court order.

Cookies/Website/Google Analytics/reCAPTCHA

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

"Session" cookies and "Persistent" may be used on this website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

The session cookies are used to: keep track of you whilst you navigate the website; prevent fraud and increase website security.

Persistent cookies are used to: enable the website to recognise you when you visit; keep track of your preferences in relation to your use of our website.

Blocking/Deleting Cookies

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer (version 9) you can refuse all cookies by clicking "Tools", "Internet options", "Privacy", and selecting "Block All Cookies" using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

Google Analytics

Google Analytics is used by this site to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: policies.google.com/privacy.

reCAPTCHA

The contact forms on the site use reCAPTCHA, which is a service provided by Google. The idea behind it is to reduce spam being sent. The reCAPTCHA terms are at https://www.google.com/intl/en/policies/privacy/ and https://www.google.com/intl/en/policies/terms/.  Links to the terms are on the relevant pages.

Links to external Sites

If you click on links to certain services or external sites, you will be using their services and be subject to their Privacy Policies. These are the links to Facebook, Twitter, etc.

Security measures in place.

– Encryption

– This site uses https instead of http

– Offline storage

Links to other sites/Booking tuition through other sites

Essentially:

  • Where my website has links to other websites, those sites are not covered by this Privacy Notice.

  • Where you book tuition through a third party site (e.g. Firsttutors) this Privacy Notice does not govern their retention of data provided by you on their site. (I cannot control what data an independent third party holds and how long they hold it for). In this scenario this Privacy Notice only governs data held by me (i.e. in my control).

Future changes to this privacy notice

It is possible that I will need to update this privacy notice in the future. In that event, I will update the Privacy Notice on this website. (Please be reassured that I will not increase time limits for retention of data retrospectively). Please look regularly for updates here, so that you are up to date on what information is collected and how it is used.

Your rights

You have the right to:

  • request your personal data;

  • object to processing of personal data that is likely to cause, or is causing, damage or distress;

  • have inaccurate personal data rectified;

  • request your information to be deleted or destroyed (Please note normally if I can I will, but I must keep certain records for legal reasons); and

  • claim compensation for damages caused by a breach of the Data Protection Regulations

If you are not happy with how your personal information is used, I would ask that you contact me, but you have the right to complain to the Information Commissioner’s Office at www.ico.org.co.uk.

Contacting me

Feel free to get in contact with any quesions.