Privacy Policy
Introduction and Scope
This Privacy Policy explains how Wadjet Tutor collects, uses, discloses, and protects personal data relating to parents, adult students, tutors, and other users. It should be read alongside the Terms and Conditions, Cancellation and Refund Policy, and Rescheduling Policy. This draft must be checked against the platform’s actual data practices before publication.
Data Controller and Contact Details
Data controller: [legal company name]. Registered address: [address]. Privacy email: [email]. Other contact channels: [details]. Complete these fields before publication and identify a data protection contact or officer where required by law.
Personal Data We May Collect
Account data: name, email, contact details, credentials, and verification details. Booking data: subject, curriculum, grade, session date and time, lesson mode, in-home lesson address, and student information provided for each booking. Tutor data: identity, qualifications, specialization, availability, reviews, and verification or contractual records. Transaction data: amount, payment status, transaction reference, refunds, and balances; full card numbers and security codes should not be stored by Wadjet Tutor where processed by a payment provider. Technical and security data: device, sign-in events, IP address, error logs, and relevant usage data. Support data: complaints, messages, and attachments voluntarily submitted.
Children’s Personal Data
Only a parent, legal guardian, or student aged 18 or over may create an account. One account may book for multiple students; student details are supplied for each booking without requiring a permanent standalone student profile. Users booking for another person’s minor child must obtain the appropriate parent or guardian consent. Children’s data is processed only as necessary to provide lessons, safeguard students, and handle service issues, subject to applicable legal safeguards and consents.
Purposes and Legal Grounds
We process data to create and secure accounts, match bookings with tutors, deliver lessons, enable in-app communications, process payments and refunds, provide customer support and the satisfaction guarantee, prevent fraud, protect student safety, comply with legal obligations, and maintain the service. Each activity must have a valid legal ground under applicable Egyptian law. Separate consent is obtained where required, including for certain marketing and children’s data activities.
Direct Booking and Open Booking
For Direct Booking, the selected tutor receives the booking information necessary to consider and deliver the lesson. For Open Booking, matching tutors may receive limited educational requirements, timing, and approximate location needed to prepare offers. Student identity and full home address should not be disclosed more widely than necessary before a tutor is selected and the booking is confirmed. After confirmation, the selected tutor receives information necessary to deliver the lesson.
In-Home Lessons and Location
The lesson address is used to coordinate attendance and safety for in-home sessions. Detailed addresses should be disclosed only to authorized parties when required for the booking. This policy does not imply that continuous or live location tracking is enabled. Any future location-tracking feature would require specific disclosure and any applicable permissions.
Messages, Calls, and Recording
The app supports in-app text messages and voice calls. Users and tutors are prohibited from recording lessons by audio, video, or screen capture. Wadjet Tutor does not represent that lesson or call content is recorded; any such practice would require prior disclosure, legal assessment, and necessary consent. Operational metadata, such as call time or duration and message delivery status, may be processed where implemented. The final published policy must state whether message content is stored and for how long.
Payments and Wallet Balances
Card payments are processed through [payment provider]. Wadjet Tutor may receive limited transaction details, including status, amount, and reference, to reconcile payments and refunds. Wallet records distinguish refundable customer funds from non-withdrawable promotional or compensation credits. The actual custody and settlement arrangements must be confirmed before publication.
Sharing Personal Data
We may disclose the minimum necessary data to the selected tutor, hosting and technology vendors, payment processors, notification and support providers, professional advisers, and authorities where legally required. Appropriate processor contracts, confidentiality, and security safeguards should be in place. We do not sell students’ personal data to advertisers.
Marketing Communications
Students’ personal data is not used for advertising or targeted marketing except as permitted by law and with separate consent where required. Essential service messages about bookings, payments, and safety are distinct from optional marketing. Users must have an appropriate means to withdraw marketing consent where applicable without losing access to core services.
Cookies, SDKs, and Analytics
The app may use necessary authentication, security, and performance technologies. Any analytics, advertising, or tracking SDKs actually deployed must be disclosed with their purposes and recipients, and consent obtained where required. This paragraph is not authorization to deploy undisclosed trackers.
International Data Transfers
If hosting or service providers process data outside Egypt, cross-border transfer requirements, legal approvals, and safeguards must be assessed before transfer. Relevant countries and recipients should be identified where required. This draft does not assume that international transfers currently take place.
Retention and Deletion
We retain personal data only as long as necessary for service delivery, legal compliance, dispute handling, and security. Before publication, Wadjet Tutor must adopt actual retention periods for account records, bookings, messages, complaints, financial records, and backups, and document deletion or anonymization rules and legal exceptions. Data should not be retained indefinitely without justification.
Information Security
Appropriate risk-based measures may include access controls, encryption in transit, account protection, restricted staff access, audit trails, and incident response, as supported by the deployed systems. No online service can guarantee absolute security. Relevant incidents are assessed and reported or notified where required by applicable law.
Your Privacy Rights
Subject to applicable Egyptian law and the conditions for each right, individuals or authorized representatives may request access, correction, updating, deletion, restriction, withdrawal of consent where applicable, and may raise objections or complaints. Some records may need to be retained to comply with law or protect legal claims. Submit requests to [privacy email]; identity verification may be required.
Account Closure
Certain records may be retained after account closure where necessary for refunds, accounting, complaints, student safety, or legal compliance, subject to documented retention periods. Account suspension does not extinguish valid financial or privacy rights.
Policy Changes
We may revise this policy when our services or legal obligations change. Material changes will be communicated as required, and renewed consent sought where legally necessary. The effective date and last-updated date should be displayed.
Governing Law and Complaints
This policy is governed by applicable laws of the Arab Republic of Egypt, including Personal Data Protection Law No. 151 of 2020 and applicable implementing measures, without excluding other relevant mandatory rules. Privacy complaints may be sent to [privacy email], without limiting access to competent authorities.
Publication Checklist
[Legal entity, address, contact details]; [payment provider]; [hosting provider and storage country]; [actual technology recipients]; [retention periods by data category]; [message content and call metadata practices]; [analytics, notification and tracking tools]; [privacy request process and response times]; [data protection officer/contact if applicable].
