Privacy Policy

Who we are and how to contact us

TutorWrap is operated by Sigil Digital Limited, a private limited company registered in Nigeria with the Corporate Affairs Commission under number RC 9590426, of 28B Alhaji Kareem Street, Olowora, Kosofe, Lagos State, Nigeria. Questions, requests and complaints about this policy go to [email protected]. We aim to answer within 30 days.

We are established in Nigeria and do not yet have an establishment or an appointed representative in the European Economic Area or the United Kingdom. People in those regions can exercise every right in this policy directly with us at [email protected], and can complain to their local data protection authority as described under "Your rights and choices". We will update this section when a representative is appointed.

Our role: when we decide and when the tutor decides

For tutor accounts, billing, security, analytics and the technical data described below, we decide why and how personal information is used. In data protection terms we are the controller.

For information about students and guardians, the tutor decides who to add, what to record and who to send updates to. The tutor is the controller of that information and we process it on the tutor's instructions, under the Data Processing Addendum that forms part of our Terms of Service. We use it only to provide the features the tutor turns on, and for nothing else.

Two features involve us using student information on our own initiative, and we want to be clear about them: the weekly goal digest email to the tutor, which may include a one-line AI suggestion about what to focus on next, and the private product analytics described under "Analytics". Neither sends anything to parents and neither includes names or contact details in analytics.

Information you give us as a tutor

• Account details: your name, email address and sign-in credentials. Sign-in is handled by Clerk. If you choose Google sign-in, Google sends us your name, email address and Google account id.
• Profile and preferences: country, timezone, subjects, roster size, how you heard about us, preferred parent channel and delivery mode, report cadence and email preferences.
• Billing details: plan, billing country and currency, subscription status, invoice history and the customer id our payment provider assigns to you. Card and bank details go directly to Lemon Squeezy or Paystack and never reach our servers.
• Referral and partner codes you enter or share.
• Support messages you send us.

Information tutors give us about students and guardians

Tutors enter this information. We never collect it from students or guardians directly, except for the check-in and replies described below.

• Students: the name the tutor gives the student, year group or grade, curriculum, subject, an optional cartoon avatar choice, learning goals and the steps toward them, progress levels, and any custom attributes or notes the tutor records. Custom attributes are free-form fields the tutor defines; we ask tutors not to use them for sensitive information.
• Guardians: name, email address, mobile number, country and timezone, preferred channel (email, SMS or WhatsApp), whether SMS or WhatsApp consent has been recorded and when, and unsubscribe or bounce status.
• Session records: date, time and length, delivery mode, topics covered, engagement rating, homework set, the note to parents and the summary that was sent.
• Reports: periodic progress reports built from a template, with ratings, free-text answers and the sessions they cover.
• Private notes: notes a tutor writes for themselves on a session, report or student. These are stored but, by design, never included in anything sent outside the app. Automated tests check this on every release.
• Evidence: photos of a student's written work, or scores, attached to a learning goal. Photos are re-encoded on upload, which removes location and camera metadata, and are stored in a private bucket in the EU. A photo appears on the progress page only when the tutor chooses to share it, and the tutor can unshare it at any time.

Information parents and students give us directly

• Replies: if a tutor's messaging number supports replies, a parent can answer an SMS or WhatsApp update. The text, and any photo attached, is stored and shown only to that tutor. Photos are re-encoded and stored privately in the EU. A reply from a number we do not recognise is kept, unlinked, until a tutor claims it or we delete it.
• STOP, START and HELP keywords, which update consent for the channel they are sent on.
• Student check-in: the progress page has an optional check-in where a parent may hand the phone to the student, who picks a confidence level for each goal and may add a photo of their work. The check-in collects no name, no typed text and no account, runs no analytics, and is visible only to the tutor. Parents start it and can stop it at any time; tutors can turn it off per student.

Information collected automatically

• Technical data: IP address, approximate country (Cloudflare tells us the country so we can show prices in your currency), browser and device type, pages requested, and the time of each request.
• Server logs and error reports, which carry account ids rather than names, and are scrubbed of names, contact details, notes and message content before they are stored.
• Delivery data from our email and messaging providers: whether a message was delivered, bounced, failed or was opted out of.
• Calendar data, if you connect a calendar: the start time, end time and title of events on the calendars you tick. See "Calendar connections".
• Product analytics as described under "Analytics" and in our Cookie Notice.

How we use personal information

• To run the service: logging sessions, writing the parent summary, sending it by email, SMS or WhatsApp, showing the private progress page, building reports and tracking goals.
• To remind you to log a session shortly after a connected calendar event ends.
• To provide AI assist when you ask for it, and the weekly goal digest. See "AI features".
• To bill you, apply referral and partner discounts, grant and debit message credits, enforce plan limits and detect fraud or abuse.
• To answer support requests and send service email about your account: welcome and getting-started tips during the trial, trial and billing reminders, grace-period and limit notices, and the weekly goal digest. Tips and the digest can be turned off in Settings or from the link in the email.
• To keep the service secure, investigate incidents and comply with the law.
• To understand how tutors use TutorWrap and improve it, using the limited analytics described below.

We do not sell personal information, share it with advertisers, use it for advertising, or use it to train artificial intelligence models, and our providers are contractually prohibited from training models on it. We do not make automated decisions about you that have legal or similarly significant effects.

AI features

AI assist is optional and only runs when a tutor presses a Suggest or Dictate control, with one exception: the weekly goal digest, which may include a one-line focus suggestion for each student whose goals have stalled. There is a daily cap per tutor. Suggestions are drafts for the tutor to review; nothing an AI writes is sent to a parent unless the tutor chooses to send it.

What leaves our servers for these features is deliberately narrow. For goal steps and focus lines we send the student's first name, subject, curriculum, year group, the goal wording and progress level, and recent lesson topic titles to Anthropic, which provides the language model. Guardian details, surnames, contact details, session notes and private notes are never included, and automated tests check that.

For dictation, the tutor's voice recording is sent to Deepgram for transcription and then deleted from our storage. The transcript is sent to Anthropic together with the student's first name, subject and active goals, so it can be turned into session fields. Anything in the transcript that sounds personal or sensitive is placed in the private-notes suggestion, which never leaves the app. Please do not dictate information about a student's health, family circumstances or other sensitive matters that you would not want processed by these providers.

Both providers process the data only to return a result to us, are contractually prohibited from using it to train or improve their models, and may retain inputs briefly for abuse monitoring under their terms. Results are stored in the tutor's account so the same suggestion is shown on the goals page and in the digest. The transcript itself is removed from our records 30 days after the dictation; the fields the tutor accepted stay with the session.

Calendar connections

Calendar connections are optional. When you connect a Google or Microsoft account we request read-only access to your calendars, through our calendar provider Nylas. We use that access for one purpose only: to notice when an event on a calendar you ticked has ended, so we can remind you to log the session. We never create, edit or delete events, never read attendees, descriptions or locations, and never send anything to anyone from your calendar.

TutorWrap's use and transfer to any other application of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In practice this means Google calendar data is only used to provide the reminder feature you asked for, is never used for advertising, is never sold, and is not read by people except with your permission, for security reasons, or where the law requires it.

You can disconnect at any time from Settings. Disconnecting revokes our access and deletes the stored connection and any pending reminders. You can also revoke access from your Google Account permissions page or your Microsoft account privacy settings.

Analytics

We use PostHog, hosted in the EU, in two ways. In the browser, and only after you accept analytics cookies in the banner, we record which pages you view. Nothing loads on the parent progress pages or the unsubscribe pages, whose visitors are parents and children.

On our servers, when you are signed in, we record product events against your account id, such as a session being logged, a plan being changed, or a message being delivered or failing. The properties we attach are limited to an allow-list (plan, country, currency, channel, counts and statuses). They never include student names, guardian contact details, session content or private notes. We rely on our legitimate interest in understanding and improving the service for this. You can object by emailing us.

Session replay, heatmaps, autocapture and surveys are switched off.

Legal bases (EEA and UK)

Where the EU GDPR or UK GDPR applies, we rely on the following bases.

We do not ask for, and ask you not to enter, special category data such as health, religion, ethnicity or biometric data about students or guardians. If a tutor records such data in notes, the tutor is responsible for having a lawful basis for it.

Who we share information with

Service providers. We use a small number of providers to run TutorWrap, each under a contract that limits them to the purpose listed and prohibits model training on your data. The current list, with locations, is on our Subprocessors page and summarised here:

Payment providers. Lemon Squeezy is the merchant of record for USD, GBP and EUR purchases, and Paystack processes NGN payments. They collect your payment details directly and use them under their own privacy policies, including for tax, fraud prevention and chargebacks.

The tutor. Replies and photos a parent sends, and check-ins a student completes, are shown to the tutor who sent the update.

Authorities and others. We may disclose information where the law requires it, to respond to lawful requests, to protect our users, the public or the service from fraud, abuse or harm, or to establish or defend legal claims.

Business transfers. If we are involved in a merger, acquisition, financing or sale of assets, personal information may be transferred as part of that transaction. This policy will continue to apply to it, and we will tell tutors before their data becomes subject to a different policy.

We do not share personal information with advertisers, data brokers or social networks.

Where information is stored and international transfers

Our application, worker and database run on servers in Germany. Evidence photos, parent-sent photos and encrypted backups are stored in Cloudflare's EU region. Error monitoring, product analytics and calendar connections use our providers' EU regions.

Some providers process data in the United States: Clerk (sign-in), Resend (email), Twilio (SMS and WhatsApp), Anthropic and Deepgram (AI features) and Lemon Squeezy (billing). Cloudflare's network edge is global. Where personal information of people in the EEA, the UK or Switzerland is transferred to a country without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the EU-US, UK-US and Swiss-US Data Privacy Framework where the provider is certified. Where Nigerian personal information is transferred abroad, we rely on the adequacy and contractual mechanisms permitted by the Nigeria Data Protection Act 2023. You can ask us for a copy of the relevant safeguards.

How long we keep information

Security

All traffic is encrypted in transit. The database is not reachable from the internet. Every record is scoped to the tutor who owns it. Progress page links use long random tokens stored only as hashes; they are rate-limited, hidden from search engines and can be revoked on request. Media links expire after ten minutes. Private notes are excluded from every outbound message by design, and that rule is covered by automated tests on every release. Backups are stored encrypted at rest in the EU and restore-tested.

No system is perfectly secure. If we become aware of a breach affecting your personal information we will tell affected tutors and, where required, the relevant regulator without undue delay, and will help tutors meet their own notification duties.

Parents and guardians

If you received an update from TutorWrap, it is because your child's tutor entered your contact details and chose to send it. The tutor is responsible for having a lawful basis to contact you and, for SMS and WhatsApp, for recording your consent before the first message.

Every email includes an unsubscribe link, which stops updates on every channel. Replying STOP to an SMS or WhatsApp message stops further messages on that channel, whether or not the message says so; replying START opts you back in. The tutor is told when you opt out and must not re-add you.

Progress page links are private to you. They do not expire and are not indexed by search engines, but anyone holding the link can open the page, so please do not share it. If a link has been shared, ask your tutor or email us and we will revoke it.

To access, correct or delete your details or your child's, contact the tutor first: they control the record. You can also email us and we will pass the request on and action it ourselves where we are able to, for example by removing your contact details from every tutor account that holds them.

Children

TutorWrap accounts are for adults aged 18 or over. We do not knowingly let children create accounts.

Students are usually children. Information about them is entered and controlled by their tutor, who must have the parent's or guardian's permission to record it and to share photos of their work. We keep it to what a progress record needs, keep it out of analytics and logs, never use it for advertising or profiling, and delete it on the schedule above.

The student check-in is the only place a child interacts with TutorWrap directly. It is started by the parent from the parent's own link, asks for no name, text or account, and collects only a confidence rating and an optional photo of the student's work. We ask tutors and parents to make sure photos show the work rather than the child. If you believe a child's information has been entered without appropriate permission, email us and we will remove it.

Your rights and choices

Depending on where you live, including under the EU GDPR, the UK GDPR, the Nigeria Data Protection Act 2023 and several US state privacy laws, you can ask to access, correct, delete or export your personal information, restrict or object to how we use it, withdraw consent where we rely on it, and appeal a decision we make on a request. We will not treat you differently for exercising these rights.

• Tutors can update account details in Settings, export their student list as a CSV from the Students page, archive students, turn tips and the goal digest off, change the cookie choice on this page, and delete their account from the bottom of the Settings page. Deleting the account removes sign-in immediately and the data on the schedule above. If you sign up again with the same email within the 30-day deletion period, the account is restored rather than recreated.
• Guardians can unsubscribe from any email, reply STOP to any text, and ask the tutor or us to correct or delete their details.
• Anyone can email us at the address above. We may ask for enough information to confirm you are the person the data is about, or that you are authorised to act for them, before we act. We answer within 30 days, or tell you if we need longer.

If you are unhappy with our response you can complain to your data protection authority: in the UK the Information Commissioner's Office (ico.org.uk), in the EEA the authority of the country where you live, and in Nigeria the Nigeria Data Protection Commission (ndpc.gov.ng).

US state privacy rights

If you live in a US state with a comprehensive privacy law (such as California, Colorado, Connecticut, Virginia, Texas or Oregon), you have the rights listed above. For clarity: we do not sell personal information, do not share it for cross-context behavioural advertising, do not use it for targeted advertising, and do not use it for profiling that produces legal or similarly significant effects, so there is nothing to opt out of in those categories. We do not knowingly collect personal information from children under 16 for any of those purposes. We treat Global Privacy Control signals as an opt-out of any such sale or sharing, which in practice changes nothing because none takes place. California residents can request the information described in the "Shine the Light" law by emailing us; we have not disclosed personal information to third parties for their own direct marketing.

Cookies

Essential cookies keep you signed in, remember your sidebar choice and record your cookie decision. Analytics cookies are optional and only set if you accept them in the banner. Our Cookie Notice lists every cookie, who sets it and how long it lasts. You can change your analytics choice at any time using the control below.

Changes to this policy

If we make material changes we will email tutors at least 14 days before they take effect and update the date at the top of this page. Continued use after that date means the new policy applies. Previous versions are available on request.