Privacy policy

1. Who we are

Sino Tutor ("Sino Tutor", "we", "us" or "our") operates an online tutoring marketplace that connects students and parents in South Africa with vetted tutors, and provides an AI study assistant, learning resources and session bookings. For the purposes of the Protection of Personal Information Act, 2013 (POPIA), we are the responsible party for the personal information processed through the platform. This document serves both as our privacy policy and as the notification to you, as a data subject, of how your information is handled.

2. What personal information is

Personal information is any information that identifies you or relates to you as an identifiable person. On Sino Tutor this can include your name, contact details, the role you sign up under, the content you create such as messages and reviews, and information about how you use the platform. Some information, such as identity documents and qualifications, is more sensitive and is treated as special personal information, which we describe in its own section below.

3. Information we collect

• Account information. When you register we collect your name, email address, a securely stored password and the role you choose (learner or parent, or tutor).
• Tutor profile and verification information. If you apply to tutor, we collect the subjects and grades you teach, your hourly rate, your biography and location, your availability, and the qualifications and identity or supporting documents you upload so that we can verify you.
• Learner and parent information. The grades, subjects and preferences you tell us about so we can help you find suitable tutors and resources.
• Activity information. Your bookings, reviews and ratings, your conversations with the AI study assistant, the resources you access and download, and notifications.
• Payment information. Records of the plan you are on and the transactions associated with it. Card and banking details are handled by our payment provider and are not stored by us.
• Technical information. Information about the device and browser you use, and information collected through cookies and similar technologies, which is explained in our Cookie policy.

4. Is providing your information voluntary or mandatory?

Most of the information we ask for is voluntary, but some of it is necessary for us to provide the service. If you do not give us the information needed to create an account, verify a tutor, or process a booking, we may not be able to offer you that part of the platform. Where the law requires us to collect or keep certain information, we will tell you when that is the case.

5. When and why we process your information

We process personal information where we have a lawful basis to do so, including:

• where you have given us your consent;
• where it is necessary to perform our contract with you, such as creating your account and managing your bookings;
• where it is necessary to comply with a legal obligation;
• where it protects your legitimate interests or those of another person;
• where it serves our legitimate interests in running, securing and improving the platform, balanced against your rights.

The main purposes for which we process your information are to:

• create and manage your account and keep you signed in;
• match students and parents with suitable tutors and resources;
• verify tutors and maintain trust and safety across the community;
• arrange, confirm and keep a record of bookings and reviews;
• provide the AI study assistant and the documents it generates;
• process your subscription and enforce plan limits;
• send you service messages and, where you have agreed, updates;
• detect, prevent and address fraud, abuse and security issues;
• comply with our legal and regulatory obligations.

6. Special personal information and children

Some of what we handle is more sensitive. When tutors upload identity documents or qualifications for verification, we process that special personal information only as permitted by POPIA, for the specific purpose of vetting, and with appropriate safeguards.

Because Sino Tutor supports learners from Grade 1 upwards, some of our users are children. Where a user is a minor, we expect a parent or guardian to set up and oversee the account and to provide consent for the processing of the child's personal information. If you believe a child has provided us with information without the consent of their parent or guardian, please contact us and we will take appropriate steps.

7. Marketing

We will only send you marketing messages where you have agreed to receive them or where the law otherwise allows it. You can opt out at any time using the unsubscribe link in our emails or by changing your notification preferences in your settings. Opting out of marketing does not stop essential service messages, such as a booking confirmation or a security notice.

8. How and with whom we share your information

We share personal information only where it is necessary to run the service, and never sell it. We share information between a student or parent and a tutor where that is needed to arrange and carry out a booking. We also use trusted third-party operators who process information on our behalf and under our instructions, such as our hosting and database provider, our email provider, our payment provider and the provider of the AI study assistant. These operators are bound by agreements that require them to keep your information secure and to use it only for the purposes we specify. We may also disclose information where we are required to do so by law or to protect our rights or the safety of others.

9. International transfers

Some of the operators we rely on may process information outside South Africa. Where personal information is transferred across borders, we take steps to ensure it continues to enjoy a level of protection consistent with POPIA, for example through contractual safeguards or because the recipient is subject to laws that provide adequate protection.

10. How we keep your information secure

We use appropriate technical and organisational measures to protect your personal information against loss, unauthorised access and misuse. These include access controls, encryption in transit, database-level security rules and the principle of giving people access only to what they need. No system can be guaranteed to be completely secure, so we also ask you to play your part by keeping your password confidential and letting us know promptly if you suspect any unauthorised use of your account.

11. How long we keep your information

We keep personal information only for as long as it is needed for the purposes set out in this policy, or for as long as the law requires us to. When information is no longer needed, we delete it or anonymise it. The exact period depends on the type of information and the reason we hold it, such as the life of your account, our legal and tax obligations, and the need to resolve disputes or enforce our agreements.

12. Your rights

You have the right to be told what personal information we hold about you and to access it, to ask us to correct information that is inaccurate or out of date, and to ask us to delete information that we no longer have a reason to keep. You may object to certain processing, withdraw any consent you have given, and lodge a complaint with the Information Regulator of South Africa. You can manage most of your information directly in your settings, including exporting your data, or you can contact us.

13. Changes to this policy

We may update this policy from time to time as the platform and the law evolve. When we do, we will revise the date shown above, and where the changes are significant we will take reasonable steps to bring them to your attention.

14. How to contact us

If you have any questions about this policy or about how we handle your personal information, or if you wish to exercise any of your rights, please contact us using the details on our contact page. For more on how we comply with South African data protection law, see our POPIA notice.