Legal Policies

Effective: 27/07/2026 · Version 3.0 · globaltutors.co and globaltutors.co.za

1. Who we are

Global Tutors is a tutoring agency. We match students with independent tutors, arrange and support lessons, and facilitate access to independently registered practitioners for educational psychology, assessment and career guidance.

Global Tutors Pty Ltd, registration number 2025/188667/07, registered at 222 Smit St, Braamfontein, Johannesburg, 2017, is the responsible party for the personal information described in this policy, except where section 3 says otherwise.

Global Tutors Information Officer Privacy contact: info@globaltutors.co Postal address: 222 Smit St, Braamfontein, Johannesburg, 2017

We comply with the Protection of Personal Information Act 4 of 2013 (POPIA), and with the UK and EU GDPR where it applies to our international clients.

2. Who this policy covers

Students, including children under 18; parents and guardians; tutors and tutor applicants; website visitors and enquirers.

Section 6 deals specifically with children. Section 13 deals with tutors and applicants.

3. Who is responsible for what

We're an agency, so three different parties hold information about you. This matters for who to contact about it.

Global Tutors is the responsible party for your enquiry, account, bookings and payments; session recordings and session summaries; safeguarding records and concerns; tutor vetting records, including police and reference checks; and your communications with our team.

The tutor, as an independent contractor, is the responsible party for their own lesson notes, marked work and teaching materials.

The registered practitioner, under their own professional obligations, is responsible for assessment responses, scores, clinical observations and practitioner reports.

Some information we're responsible for is held for us by the providers listed in section 11. Using a provider doesn't transfer our responsibility to them - if you have a question about your information, come to us.

We do not request or receive practitioner reports from the practitioner. Assessment reports go from the practitioner to you directly. If you choose to send us a copy, we treat it under section 7.

4. Where we get your information

From you, when you enquire, book, pay or message us; from a parent or guardian, on a student's behalf; from your tutor, in the form of session feedback and progress notes; automatically, from our website and platform (see section 12 and the Cookie Policy); from referees, when we check a tutor applicant's references; and from background check providers, when we vet tutors.

5. What we collect

Identity and contact: name, email address, phone number including WhatsApp number, country and time zone, billing address.

Educational: curriculum and exam board, subjects, grade or year level, school, learning goals, academic performance information you share with us, session summaries and feedback.

Session recordings and summaries: every tutoring session is recorded, and an automatically generated written summary of each session is produced. See section 8.

Communications: emails, WhatsApp messages including messages in client groups, support conversations, call notes, and correspondence with our team or a tutor through our channels.

Payment: billing details and transaction records. We do not store card numbers - see section 11.

Technical: IP address, device and browser information, pages visited, referral source, cookie identifiers.

Referral information for practitioner services: where you ask us to arrange an appointment, we collect the reason for the referral, the student's age and year level, and scheduling details - enough to make an appropriate match. We do not collect or hold the assessment itself.

6. Children's personal information

Most of our students are under 18. POPIA restricts the processing of a child's personal information, and we process it only where a parent or legal guardian - a "competent person" - has given consent.

We obtain guardian consent at enrolment, covering lesson arrangement, session recording and summaries, communication including WhatsApp groups, and progress reporting.

We do not knowingly collect a child's personal information directly without that consent.

A parent or guardian may exercise all rights in section 14 on the child's behalf, and may withdraw consent at any time - though we may then be unable to continue arranging the service.

We follow WhatsApp's current minimum age as set by the platform. Where a student is below that minimum, the guardian's device is the participant in any group, not the child's.

We do not use children's personal information for marketing, profiling or automated decision-making.

7. Special personal information

If you choose to send us an assessment report, psychological report or medical information, it is special personal information under POPIA section 26. We process it only with your explicit consent, only for the purpose you gave it to us for, share it only with the tutor you nominate, and delete it on request.

Criminal record information about tutors is also special personal information - see section 13.

8. Session recordings and summaries

Recordings. Every tutoring session is recorded, for child protection, quality assurance and dispute resolution. Recording is arranged and controlled by Global Tutors, not by the tutor, and a tutor cannot switch it off.

• Recordings are made and stored on our behalf by Lessonspace, our online classroom provider, under a written agreement requiring them to process recordings only on our instruction.
• Retained for 90 days, then deleted, unless preserved for an active investigation, complaint or legal claim.
• Access is restricted to Global Tutors administrators.
• Tutors do not receive copies.
• Never used for marketing, never shared publicly, never used to train third-party systems.
• You may request access to a recording of your own sessions while it is still retained. Contact us and we'll retrieve it.

Summaries. Lessonspace also generates an automatic written summary of each recorded session, used for progress tracking and continuity between tutors. Summaries are produced by automated means and may contain errors - tell us if one is inaccurate and we'll correct it.

• Retained for 2 years.
• Access restricted to Global Tutors administrators.
• Summaries persist after the underlying recording is deleted.

Guardian consent to recording and summarisation is obtained at enrolment. It can be withdrawn, but we cannot arrange sessions without recording.

9. Why we process information, and on what basis

• Matching students with tutors and arranging lessons - performance of contract.
• Scheduling, reminders, invoicing and payment collection - performance of contract.
• Session recording, summaries and safeguarding - legal obligation and legitimate interest in child protection; guardian consent.
• Vetting tutors, including police and reference checks - legal obligation and legitimate interest in child protection; tutor's explicit consent.
• Referring you to a registered practitioner - consent.
• Client communication, including WhatsApp groups - performance of contract; consent for group participation.
• Marketing our other services - consent, or the existing-customer basis under POPIA section 69, always with opt-out.
• Website analytics - consent (cookies).
• Security, fraud prevention, dispute resolution - legitimate interests.
• Tax, accounting and legal compliance - legal obligation.

10. WhatsApp and messaging

WhatsApp is our primary channel for client communication. If you communicate with us this way:

• Messages are processed by WhatsApp Ireland Ltd / Meta Platforms under their own terms and privacy policy. We are not responsible for Meta's processing.
• Message content passes through Meta's infrastructure and may be stored outside South Africa.
• In any group, all participants can see each other's phone numbers and profile photos. By joining a group you consent to that. Tell us if you'd prefer one-to-one contact instead - the service is identical.
• We retain business-relevant message records for 5 years.
• We contact you only from our published official numbers. Tutors are prohibited from using personal numbers.

11. The systems we use, and who we share information with

Our own systems. Our CRM holds tutor profiles, enquiries and leads, bookings and payment records. It is operated by us, hosted at Heroku (Region: United States), with access restricted by role.

Service providers acting as operators under written contract:

• Lessonspace - online classroom, session delivery, recordings, session summaries.
• TutorCruncher (Huddle) - lesson records, scheduling, invoicing data.
• Koalendar - tutor interview bookings.
• WhatsApp / Meta - messaging.
• PayFast / Wise - payment collection and card processing.
• Brevo - transactional and marketing email.
• Google Analytics - website analytics.

Each is contractually required to process personal information only on our instruction, keep it secure, and notify us of any compromise.

Card details. We do not store card numbers. Payment is processed by PayFast and card data goes directly to them.

Tutors: we share only what a tutor needs in order to teach - student first name, year level, curriculum, subject, learning goals and scheduling. Tutors do not receive billing information, practitioner reports, recordings, or a parent's full contact record unless you ask us to share it.

Registered practitioners: where you ask us to arrange a referral, we share your contact details and the referral information in section 5. Nothing further.

Authorities: where required by law, or where we have a safeguarding concern, we may share information with police, child protection authorities or regulators in South Africa or the student's country.

We do not sell personal information, and we do not share it with third-party tutoring agencies or advertisers.

12. International transfers

We serve students worldwide, so personal information crosses borders in two ways:

To tutors outside your country. Your tutor may be in South Africa, the United Kingdom, the United States, Australia, Colombia or elsewhere. Tutors are bound by written agreements requiring confidentiality and protection equivalent to POPIA.

To the service providers in section 11, several of which process data outside South Africa.

Transfers are made under POPIA section 72, on the basis of standard contractual clauses providing substantially similar protection, and where necessary for performance of our contract with you.

13. Tutors and tutor applicants

If you apply to tutor with us, we process:

• Identity and contact details, and right-to-work information where relevant
• Qualifications, transcripts, teaching experience and CV
• Interview notes and assessment of your application
• Criminal record and background check results, and reference check responses
• Payment and invoicing details for fees we collect and pass on to you

Criminal record information is special personal information under POPIA section 26(b). We process it with your explicit consent, solely to assess suitability to work with children. Results are recorded as a status - cleared, not cleared, or pending. The underlying report is stored securely, accessible only to Global Tutors administrators, and never shared with clients or published.

As an independent contractor you are a separate responsible party for the lesson notes, marked work and teaching materials you create and keep yourself. Your obligations are set out in your Tutor Agreement.

Retention: if engaged, we keep your records for the duration of the engagement plus 5 years. If not engaged, we keep your application for 24 months so we can consider you for future openings, then delete it. You may ask us to delete it sooner.

We do not add tutors or applicants to any public directory, and we do not share your details with other agencies, without your separate, specific and freely given consent.

14. Your rights

You may ask us to: confirm what personal information we hold, and give you access to it; correct or complete inaccurate information; delete information we no longer have a lawful reason to keep; restrict or object to certain processing; withdraw consent - including consent to recording, marketing or group participation; provide your information in a portable format; and stop sending you direct marketing.

Send requests to info@globaltutors.co. We respond within 30 days, free of charge, though we may charge a reasonable fee for a further copy of the same information.

For information held by a tutor or practitioner rather than by us, we'll tell you who to contact and help you reach them.

Parents and guardians may exercise these rights on a child's behalf.

15. How long we keep information

• Session recordings - 90 days.
• Session summaries - 2 years.
• Client account and lesson records - duration of the relationship + 2 years.
• WhatsApp and email correspondence - 5 years.
• Enquiries that don't become clients - 24 months.
• Referral records for practitioner services - 2 years.
• Tutor records (engaged) - duration of the engagement + 5 years.
• Tutor applications (not engaged) - 24 months.
• Background check reports - 2 years.
• Financial and tax records - 5 years (statutory).
• Website analytics - 14 months.
• Safeguarding records - 5 years.

Where a record is needed for an active investigation, complaint or legal claim, we keep it until that concludes.

16. Security

We protect personal information with access controls, encryption in transit and at rest, role-based permissions, vetted staff, and written contracts with every service provider, tutor and practitioner. No system is completely secure.

If a security compromise occurs affecting your personal information, we will notify the Information Regulator and you as soon as reasonably possible after establishing its extent, as required by POPIA section 22, and tell you what happened and what you can do about it.

17. Cookies

See our Cookie Policy. Non-essential cookies, including analytics, are set only after you consent. You can change or withdraw that at any time.

18. Automated decision-making

We do not make decisions with legal or similarly significant effects about you by automated means alone. Tutor matching is assisted by our systems but decided by a person. Session summaries are automatically generated but are not used to make decisions about you.

19. Complaints

Please talk to us first: info@globaltutors.co. If you're not satisfied, you may complain to the Information Regulator (South Africa). Complaints must be made in writing, using POPIA Form 5, and are lodged through the Regulator's eService portal or by email to POPIAComplaints@inforegulator.org.za. General enquiries: enquiries@inforegulator.org.za · inforegulator.org.za

20. Changes

We post material changes here and notify you by email or WhatsApp at least 7 days before they take effect.