2. What information do we collect from you and for how long?
We may collect and process the following data about you:
2.1. Information you give us
You may give us information, including information that can identify you (“Personal Data“), when you use our Platforms, by filling in forms on the Platforms (such as the sign-up form), when you enter into any of our promotions or surveys, when you correspond with us by phone, e-mail or otherwise, and when you report a problem with our Platforms.
The information you give us may include:
2.1.1. Mandatory information required to register for the service we provide on our Platforms or to access other services provided by us, including your name, email address, date of birth, mobile phone number and a password. Some of these fields are mandatory. Superprof will not be able to provide you with the services offered on our Platforms if the required information is not provided, consequently you will not be able to register for a user account on our Platforms;
2.1.2. A photograph;
2.1.3. A postal address
2.1.4. Your mini-CV and experience;
2.1.5. A record of any correspondence between you and us;
2.1.6. A record of any listings you have created or lesson requests you have made
2.1.7. Details of accounting or financial transactions including transactions carried out through our Platforms or otherwise. This may include information such as your payment card or bank account details, details of lessons you have requested or offered through our Platforms;
2.1.8. Details of your visits to our Platforms and the resources that you access;
2.1.9. Your replies to any surveys or questionnaires, such as your reviews on the lessons you have shared with other members of our community. Such information may be used for analytic & user understanding purposes;
2.1.10. Information we may require from you when you report a problem with our Platforms or our service, such as the subject of your request for support;
2.1.11. Location information when you have given consent to the collection and processing of these data; and
2.1.12. Diplomas, Certificates, ID Card and such other documents that you have agreed to provide to us.
2.2. Information we collect automatically
2.2.1. If you sign up via social media authentication methods, Superprof will access certain Personal Data (e.g. first name, surname, picture, email, number of Facebook friends, etc.) in your social media account pursuant to the applicable terms and conditions of these social media platforms.
2.2.2. With regard to each of your visits to our Platforms we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream used to come to, through and from our Platforms. We collect this information through the use of various technologies including cookies.
2.2.3. We also collect aggregated information regarding your activity on our Platform (such as the amount of lessons offered, your message response rate, etc.). Such information may be published on your public profile on our Platform.
2.3 Your data will be retained and secured indefinitely unless you explicitly request the complete deletion of all your data. To do so, please send an email to email@example.com titled Data Deletion.
3. How do we use the information we collect from you?
We will use the information we collect:
|PURPOSES ||LEGAL BASIS |
|3.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you requested from us; ||This processing is necessary for the performance of our mutual contractual obligations. |
|3.2. to send you service-related information by email and/or text message and/or any other communication means (e.g. your lesson request information); ||This processing is necessary for the performance of our mutual obligations and/or carried out with your consent. |
|3.3. to collect payments from you or to transfer to you the payments we collect on your behalf; ||This processing is necessary for the performance of our mutual contractual obligations. |
|3.4. to enable you to personalise your user profile on our Platforms; ||This processing is carried out with your consent. |
|3.5. to enable you to communicate and interact with other members about our services or about the lessons(s) you have/will share with other members and/or to organise such lessons; ||This processing is necessary for the performance of our mutual contractual obligations and/or carried out with your consent. |
|3.6. to give you access to our support services and to enable you to communicate with our member relations team; ||This processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent and/or (iii) necessary for the establishment, exercise or defence of legal claims. |
|3.8. to send you, in accordance with applicable laws and where required, with your consent, marketing materials and information necessary to facilitate the service or the lesson requesting process and to make you suggestions and recommendations about other teachers that may interest you. We also use your data to target you in order to serve our ads on social media platforms. You can learn more about how these features work, and the data that we obtain about you, by visiting the relevant sections of the third party social media platforms; and ||This processing is based on your consent and/or our legitimate interest (i.e. providing you with meaningful advertising). |
|3.9. to notify you about changes to our services; ||This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations and/or (iii) the establishment, exercise or defence of legal claims. |
|3.10. to verify the information contained in your Certifications and other Qualification documents that may be collected from you at the time of registration or at any other time during your use of our Platforms; ||This processing is based on (i) your consent, (ii) carried out for the establishment, exercise or defence of legal claims and/or (iii) for compliance with our legal obligations. |
|3.11. to administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, analytic and survey purposes; ||This processing is based on our legitimate interest (i.e. ensuring the security of our Platforms and improving its features). |
|3.12. to improve our Platforms to ensure that content is presented in the most effective manner for you and for your device; ||This processing is based on our legitimate interest (i.e. providing you with meaningful content). |
|3.13. to allow you to participate in interactive features of our service, when you choose to do so; ||This processing is necessary (i) for the performance of our mutual contractual obligations and/or (ii) based on your consent. |
|3.14. as part of our efforts to keep our Platforms safe and secure; and ||This processing is based on (i) our legitimate interest (ensuring the security of our Platforms), (ii) carried out for the establishment, exercise or defence of legal claims and/or (iii) for compliance with our legal obligations. |
|3.15 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. ||This processing is based on (i) our legitimate interest (i.e. measuring and optimising the efficiency of our advertising campaigns) and/or (ii) your consent. |
4. Who are the recipients of the Information we collect from you and for which purposes?
4.1. When you use our services, some information about you is shared with the members of our communities, either on your public profile or during the lesson requesting process (e.g. we give your telephone number to the members with whom you will share a lesson).
4.3. We are also working closely with third parties which may be the recipients of your Personal Data such as: our business partners who are social media platforms and which may provide you with connecting services, such as the connection of the information of your profile, from their social media platforms to our Platforms; our sub-contractors in technical, payment, identity verification and delivery services, or analytics providers.
4.4. We only share your Personal Data with any of these third parties in the following cases
4.4.1. Where it is necessary to involve a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. if we charge you any fees or collect any money from you in relation to any services on the Platforms);
4.4.2. As part of the lesson requesting process and in order to provide the requested services, information such as your name, photography, mobile phone number and/or email address, may be displayed on the Platforms and/or passed on to the teacher/student in question;
4.4.3. As part of our rating system, the reviews you write will be published on the Platforms. The reviews including your abbreviated name and photography are visible to all visitors of the Platforms;
4.4.4. We use analytics and search engine providers to assist us in the improvement and optimisation of our Platforms;
4.4.5. It is explicitly requested by you (e.g. with when using social media authentication methods);
4.4.6. We may distribute parts of our Platforms (including the lessons you have posted) for display on our business partners’ websites through API or widgets. In these cases, some information from your public profile may be displayed on these websites;
4.4.8. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; and
4.4.9. If Superprof or all or part of its assets are acquired by a third party, in which case Personal Data held by it about its members will be one of the transferred assets.
4.5. In accordance with applicable laws and where required with your consent, we may combine information about you, including your Personal Data and cookie information, we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above.
5. How do we use and moderate your messages?
5.1. We may review, scan, or analyse the messages you exchange with other members of our community through our Platforms for fraud prevention, service improvement, customer support purposes, enforcement of the contracts entered into with our members (such as our Terms and Conditions). For example, in order to prevent the circumventing of our online search engine, we may scan and analyse messages sent through our Platforms to check that they do not include any contact details or references to other websites.
5.2. We will never scan or analyse your messages with other members of our community for commercial and advertising purposes. We may use automated methods to carry out the moderation of these messages, but no automated individual decision-making is performed in this regard.
6. Targeted ads on social media platforms and our communications sent by e-mail and/or text messages
In accordance with applicable laws and where required with your consent, we may use the information you give us on our Platforms for electronic direct marketing purposes (e.g. (i) receiving our newsletters, invitations to our events or other communications that we think may interest you or (ii) serving you with targeted advertising on social media platforms or third parties websites).
For electronic marketing communications: You can withdraw your consent at any time by (i) unticking the relevant box in your member account, or (ii) contacting us using the contact details provided in section 12 below.
For targeted ads and content: on social media (e.g. Facebook and Twitter): you can object at any time by configuring your settings regarding advertisement via your social media account;
7. Is your Information being transferred? how and where?
In principle, we store the Personal Data that we hold about you in the European Union (“EU“). However, since for example some of our service providers are based in countries outside of the European Union (“third countries”), we also transfer some of your data to third countries. This may include third countries where the European Commission has not taken the decision that such third country ensures an adequate level of protection (for example the United States). In that case, we ensure that the transfer is performed in accordance with the applicable legislation and that appropriate safeguards have been put in place (especially standard contractual clauses as issued by the European Commission) in order to guarantee a sufficient level of protection of individuals’ private life and fundamental rights.
By sending a request to our Data Protection Officer (firstname.lastname@example.org), we can provide you with the details regarding such appropriate safeguards (for example, the standard contractual clauses issued by the European Commission).
8. What are your rights in respect of your personal data?
8.1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).
8.2 You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so (e.g., our legitimate interest to keep the platform safe and secure for other users).
8.3 You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) to the processing of your personal data for other purposes on grounds relating to your particular situation (your right to object to processing). Please note that in the latter case, this right only applies if the processing of your personal data is based on our legitimate interest.
8.4 You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether our legitimate grounds to process your personal data in that case override your interests, rights and freedoms; or (iii) your personal data has been processed by us in an unlawful way but you either oppose the erasure of the personal data or want us to keep your personal data in order to establish, exercise or defend a legal claim.
8.5 You have the right to receive and/or have us transfer to another data controller a subset of personal data, that concern you and that you provided us with, and which we process for the performance of our contract, or because you previously consented to it, in a structured, commonly used and machine-readable format (your right to data portability).
8.6 To exercise your rights, please contact the Group Data Protection Officer (see under Article 12).
8.7. You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.
9. Confidentiality of your password
Where you have chosen a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
10. Links to other websites and social media
Our Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
12. Contact & Data Protection Officer
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data, please use one of the following means:
via our contact page; or
via email to our Data Protection Officer under email@example.com; or
by letter to:
Data Protection Officer
85 Rue d’Amsterdam
75008 Paris, France
Version 24 May 2018