In short: customer data is stored in London, UK. Transcript excerpts are analysed by AI providers in the US, under terms that stop them training on it. Our support team may access data from Australia. We never sell personal information. Questions: support@tutortracer.com.
1. Who we are
TutorTracer is operated by Sheppard Corporation Pty Ltd (ACN 703 043 476) (“TutorTracer”, “we”, “us”, “our”), an Australian company whose address is 1 Bondi Ave, Mermaid Beach QLD 4218, Australia.
This Privacy Policy explains how we collect, use, disclose and protect personal information when you visit tutortracer.com, contact us, request a trial or demo, or use the TutorTracer platform at app.tutortracer.com (the Service).
Questions or requests about privacy: support@tutortracer.com (please put “Privacy” in the subject line), or write to our Privacy Officer at the address above.
2. Our two roles
We handle personal information in two different capacities:
- Information about our own visitors, prospects and account users. For example, your name and email when you request a trial, or your login details as a user of the Service. We decide how this information is used, and this Privacy Policy applies to it directly.
- Information in our customers' lesson data. Tutoring organisations (our customers) connect their lesson platforms to TutorTracer. Lesson transcripts and related data about tutors and students are collected and controlled by the customer, and we process them on the customer's behalf and on its instructions, under our Account Terms or a signed agreement.
If you are a tutor, student or parent whose lessons are reviewed using TutorTracer, the tutoring organisation is responsible for telling you about that and for any consents required. Please contact that organisation first about your information. We will help them respond to your request.
When you visit our website
- Trial and demo requests: your name, work email, company name and (optionally) website. Demo bookings are made through Google Calendar's appointment scheduling, which collects the details you enter there.
- Website chat: the messages you type into the chat assistant on our website.
- Technical and analytics data: information your browser sends, such as IP address, browser and device type, pages visited and referring site. Our homepage uses Google Analytics, which sets cookies to help us understand how the site is used.
- Emails and calls: what you tell us when you contact us.
When you use the Service
- Account information: name, email address, organisation, role and login credentials of authorised users.
- Usage information: logs of how the Service is used, such as sign-ins, actions taken and errors.
- Billing information: billing contact details and payment status. Card payments are handled by our payment provider (Stripe). We do not store full card numbers.
- Integration credentials: API keys or credentials for lesson platforms you connect.
Customer lesson data (processed for our customers)
- Lesson transcripts with speaker labels and timestamps, lesson metadata (such as times, durations, subjects and join times), participant names and platform user IDs, and links to recordings held on the lesson platform.
- Documents customers upload, such as curriculum, policies and contracts.
- Outputs generated by the Service, such as flagged issues, quality assessments, engagement ratings and summaries, and notes added by customer users.
Customers must not submit information that isn't reasonably necessary for lesson quality and safeguarding purposes, in particular health records, government identifiers or financial account details of students or tutors.
- To provide, secure, support and maintain the Service, including analysing lessons and producing outputs for customers.
- To respond to enquiries, set up trials and demos, and onboard new customers.
- To manage accounts, billing and our relationship with customers.
- To send service messages, and reports a customer has asked for.
- To understand how our website and Service are used and to improve them. Where we use data derived from the Service for this, it is aggregated and de-identified.
- To send you information about TutorTracer where the law allows. You can opt out at any time.
- To comply with law, enforce our terms and protect the rights and safety of people and of TutorTracer.
We do not sell personal information.
5. AI processing
TutorTracer uses AI models from third-party providers to analyse lesson transcripts and to answer questions in our website chat and in-app assistant.
- Excerpts of transcripts and related context are sent to these providers through their APIs. This processing is transient.
- We use API terms under which the provider is contractually restrained from using the content to train its models. Providers may keep content for short periods for abuse monitoring, as described in their terms.
- We do not use customer lesson data to train foundation AI models.
- AI outputs support human decisions. They can be wrong, and the Service does not make decisions about individuals. Customers' trained staff do.
6. Where data is stored and processed
- Storage in the United Kingdom. Customer data at rest (database and file storage) is hosted in London, United Kingdom, unless otherwise agreed in writing. Backups are kept in the same region wherever practicable.
- AI processing in the United States. Our AI model providers' processing infrastructure is currently located in the United States.
- Support access from Australia. Our personnel may access data remotely from Australia to provide support and operate the Service, on a need-to-know basis.
- Other providers. Some of our service providers (for example email delivery, payments and website hosting) may process information in other countries.
Where we transfer personal information out of Australia, we take reasonable steps so that it is handled consistently with the Australian Privacy Principles. Where UK data protection law applies, transfers out of the UK are made under the UK International Data Transfer Addendum, UK adequacy regulations or another lawful transfer mechanism.
- Your organisation. Information in a customer account is visible to that customer's authorised users.
- Service providers (subprocessors) who help us run the Service, including cloud hosting and database, AI model providers, email delivery and payments. They may use the information only to provide their services to us. A current list is available on request from support@tutortracer.com.
- Lesson platforms you connect, as needed to retrieve your lesson data.
- Professional advisers and, if TutorTracer is involved in a sale or restructure, prospective acquirers, under confidentiality.
- Authorities where we are required by law, or where needed to protect someone's safety or our legal rights.
8. Security
We use administrative, technical and organisational measures appropriate to the information we hold, including encryption in transit and at rest, access controls that keep each customer organisation's data separate, hashed storage of API credentials, role-based access and logging. No system is completely secure. If we become aware of a data breach affecting customer data, we will notify the customer without undue delay and work with them on any notifications required by law.
- Customer data is kept while the customer's account is active. After an account ends, customer data is available for export on request for 30 days, then deleted or de-identified, with backups purged on rolling schedules of up to 35 days, unless the law requires us to keep it.
- Trial and demo accounts and their data may be reset or deleted at any time.
- Enquiry, billing and business records are kept for as long as we need them and as required by law (for example, tax law).
10. Children
Lessons reviewed using TutorTracer often involve children. That information is collected and controlled by our customers, who are responsible for giving notice to students and their parents or guardians and obtaining any consents required. Our website and Service are intended for business users. We do not knowingly collect personal information directly from children.
11. Your rights
Under the Australian Privacy Act
Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you may ask for access to the personal information we hold about you and ask us to correct it. You may also deal with us anonymously or using a pseudonym where that is practicable (for example, general website enquiries).
Under UK data protection law
Where the UK GDPR and the Data Protection Act 2018 apply, you may have the right to access your personal data, have it corrected or erased, restrict or object to its processing, receive it in a portable format, and withdraw consent where we rely on consent. Our legal bases for processing are: performing our contract with you or your organisation; our legitimate interests in running, securing and improving our business (balanced against your rights); compliance with legal obligations; and consent, where we ask for it (for example, analytics cookies where required).
Making a request
Email support@tutortracer.com with “Privacy” in the subject line. We may need to verify your identity. We aim to respond within 30 days. If your request concerns lesson data held for a tutoring organisation, we will refer it to, and assist, that organisation.
12. Complaints
If you have a concern about how we have handled your personal information, please contact us first so we can try to resolve it. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au) or, in the United Kingdom, the Information Commissioner's Office (ico.org.uk), or to your local data protection authority.
13. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and change the “Last updated” date. If a change is significant, we will also tell customers through the Service or by email.
Sheppard Corporation Pty Ltd (ACN 703 043 476)
Attention: Privacy Officer
1 Bondi Ave, Mermaid Beach QLD 4218, Australia
Email: support@tutortracer.com
