Privacy Policy

Elephant Connect Education (“we”, “us”, “our”, “Elephant Connect”) is committed to protecting the privacy of everyone who uses our website elephantconnect.com (the “Site”) or our tutoring and educational services (the “Services”), including parents, guardians, students, and prospective clients.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, who we share it with, and what rights you have. It applies whether you are based in the United Kingdom, the European Union, or elsewhere, and is written to meet the requirements of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR).

Who We Are (Data Controller)

Elephant Connect Education is the “data controller” responsible for your personal data for the purposes of UK and EU data protection law.

Trading name: Elephant Connect Education
Company registration number: 07604368
Registered office / principal place of business: 11 Merthen Grove, Tattenhoe, Milton Keynes, MK4 3AX
Email: administrator@elephantconnect.com
Telephone: +44 7825 698416 | +44 7570 353281 | +44 7825 739659

Data protection contact: Abhay Joshi, +44 7835 347697

Personal Data We Collect

The personal data we collect depends on how you interact with us. This may include:

Information you (or your parent/guardian) give us directly

Contact details: name, email address, telephone number, and country/region of residence
Parent/guardian details, where the Student is under 18
Student details: name, date of birth or age, year group, school, exam board, and subjects requested
Learning-related information: academic goals, current attainment, and, where voluntarily shared, information about special educational needs, disabilities, or learning difficulties relevant to tutoring support
Billing information necessary to process payments (processed by our payment providers — see Section 6)
Correspondence you send us, including enquiry forms, emails, and feedback

Information collected automatically

Technical data such as IP address, browser type, device type, and general location, collected when you use the Site
Usage data such as pages visited and time spent on the Site, typically collected via cookies or similar technologies (see Section 5, Cookies)

Information generated through the Services

Session records: dates, times, subjects covered, and Tutor notes on progress
Communications between the Client/Student and Tutors or our admin team, where conducted through platforms we provide or monitor
Assessment results, mock exam scores, and progress-review notes

Special Category Data and Children’s Data

Where a parent/guardian voluntarily discloses information about a Student’s health, disability, or special educational needs so that we can arrange appropriate tutoring support, this is “special category data” under Article 9 UK/EU GDPR. We only process this data with the explicit consent of the parent/guardian (or the Student, if aged 18 or over), and only for the purpose of matching an appropriate Tutor and adapting teaching support.
We provide Services to Students under 18. Where a Student is under 18, we rely on the consent and authority of a parent or legal guardian to collect and process the Student’s personal data, and that parent/guardian is treated as the primary point of contact for data protection purposes.
We collect only the minimum information reasonably necessary about a Student to deliver tutoring safely and effectively, and we take particular care to keep children’s data secure and to limit its use to the purposes set out in this Policy.

How and Why We Use Your Data

We use personal data for the following purposes, relying on the legal bases indicated:

Purpose	Legal basis
Registering Clients and Students, matching Students with a suitable Tutor, and delivering tutoring Sessions	Performance of a contract with you
Processing payments and maintaining financial records	Performance of a contract; legal obligation (tax/accounting records)
Responding to enquiries and providing customer support	Performance of a contract; legitimate interests
Safeguarding and child welfare, including DBS checks on Tutors and handling safeguarding concerns	Legal obligation; legitimate interests; vital interests where relevant
Processing special category data (e.g. SEN/health information relevant to tutoring)	Explicit consent (Article 9 UK/EU GDPR)
Sending service-related communications (booking confirmations, scheduling, progress updates)	Performance of a contract
Sending marketing communications about our Services	Consent (opt-in), or legitimate interests for existing clients with an opt-out, as applicable
Improving the Site and our Services, and analysing usage trends	Legitimate interests; consent for non-essential cookies
Preventing fraud, misuse of the Site, or breach of our Terms and Conditions	Legitimate interests; legal obligation

Cookies and Similar Technologies

4. Our Site may use cookies and similar technologies to operate correctly, remember preferences, and understand how visitors use the Site.

5. Strictly necessary cookies are used without consent, as permitted under the UK Privacy and Electronic Communications Regulations (PECR) and the EU ePrivacy Directive, because the Site cannot function properly without them.

6. Non-essential cookies (for example, analytics or marketing cookies) are only set with your consent, given via our cookie banner/consent tool, and you can withdraw consent at any time through your browser or cookie settings.

7. Further detail on the specific cookies used, their purpose, and their duration is set out in our [insert link to separate Cookie Policy, if one exists].

Who We Share Your Data With

8. We do not sell personal data. We share personal data only where necessary, with:

Tutors engaged by Elephant Connect, to the extent necessary to deliver tutoring Sessions (e.g. Student name, subject, level, and relevant learning needs)
Payment processors, to process fees securely (they receive only the data necessary to complete payment)
IT, hosting, email, and video-conferencing service providers who support our Site and Services
Professional advisers (e.g. accountants, auditors, legal advisers) where necessary for legitimate business purposes
Regulators, law enforcement, or other authorities where we are legally required to do so, or where necessary to protect the safety of a Student

Any third party processing personal data on our behalf does so under a data processing agreement that requires them to protect your data in line with UK/EU GDPR standards.

International Data Transfers

9. We provide tutoring to Students in a number of countries, and some of our service providers may process data outside the UK and European Economic Area (EEA).

10. Where we transfer personal data outside the UK or EEA, we ensure an appropriate safeguard is in place, such as the UK’s International Data Transfer Agreement (IDTA), the EU Standard Contractual Clauses (SCCs), or a recognised adequacy decision covering the destination country.

11. You can request further information about the safeguards used for a specific transfer by contacting us using the details in Section 12.

Data Retention

12. We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy any legal, accounting, or reporting requirements.

13. As a general guide: Client and Student records are typically retained for the duration of an active tutoring relationship and for [insert retention period, e.g. 2 years] afterwards, to handle any follow-up enquiries or legal obligations; financial records are retained for the period required by UK tax law (currently 6 years); safeguarding records may be retained for longer where required by law or regulatory guidance.

14. When personal data is no longer needed, we securely delete or anonymise it.

Data Security

15. We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, including access controls, secure storage, and staff/Tutor confidentiality obligations.

16. While we take data security seriously, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

17. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority, and affected individuals where required, in accordance with UK/EU GDPR.

Your Rights

18. Subject to applicable law, you have the right to:

Access the personal data we hold about you
Request correction of inaccurate or incomplete data
Request erasure of your data, in certain circumstances
Request that we restrict the processing of your data, in certain circumstances
Object to processing based on legitimate interests or for direct marketing purposes
Request portability of data you have provided to us, in certain circumstances
Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal

Where a request relates to a Student under 18, it should ordinarily be made by the Student’s parent or legal guardian. To exercise any of these rights, please contact us using the details in Section 12. We will respond within one month, as required by UK/EU GDPR, and may ask you to verify your identity before actioning a request.

Your Right to Complain

19. If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve the issue. You also have the right to lodge a complaint with a supervisory authority:

In the UK: the Information Commissioner’s Office (ICO), ico.org.uk
In the EU: the data protection authority in your country of residence, or the authority in the EU member state most relevant to the processing

Contact Us

20. For any questions about this Privacy Policy or how we handle your personal data, please contact us:

Email: administrator@elephantconnect.com
Telephone: +44 7825 698416 | +44 7570 353281 | +44 7825 739659

Changes to This Privacy Policy

21. We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or legal requirements. Any updates will be posted on the Site with a revised “last updated” date. We encourage you to review this Policy periodically, and we will notify affected individuals directly of any material change that significantly affects how their data is used.