Privacy Policy
Avalon Education Limited, company number 14389670, registered in England and Wales
124 City Road, London, EC1V 2NX · hello@avaloneducation.co.uk · +44 20 8156 4942
Version 1.2 · Last updated 26 August 2026
​
1. About this policy
1.1 This policy explains how Avalon Education Limited ("we", "us", "our") collects, uses, shares and protects personal data. It applies
to everyone we deal with: clients, students, tutors and consultants, and anyone who contacts us through our website.
1.2 We are the data controller for the personal data described in this policy. We process it in accordance with UK data protection
law, including the UK GDPR and the Data Protection Act 2018.
1.3 If you have a question about this policy or want to exercise any of the rights in section 7, contact us at
​
2. The personal data we collect
2.1 Client information. Name, address, email address, telephone number, billing details and the contents of your correspondence
with us.
2.2 Student information. Name, date of birth, school or current stage, exam board and specification, academic performance, work
produced during or between sessions, and progress notes made by tutors. Where you give them to us, we also hold the student's
email address and telephone number so that the assigned tutor can contact them directly about their tuition.
2.3 Additional needs information. Where you tell us about a student'
s additional learning needs, access arrangements, diagnoses
relevant to how we teach, or a medical matter we should know about, we process that information so the tutor can plan properly.
Some of this is special category data — see clause 3.4.
2.4 Tutor and consultant information. Qualifications, experience, right to work and vetting information, references, availability,
feedback on their work, and a photograph where they add one to their profile on the platform we use.
2.5 Safeguarding records. Where a safeguarding concern is raised, we record the facts of the concern and the action taken. See our
Safeguarding Policy for how these records are handled.
2.6 Website information. Information you submit through an enquiry form, and technical information about your visit collected
by our website platform.
2.7 Session recordings. Where sessions are delivered through our online platform, we may record them. A recording captures the
student's image, voice and work as shown on screen, and the tutor's, for the length of the session.
2.8 Where the data comes from. Most student information reaches us from the parent or guardian who engages us, or from the
student, rather than directly from the student's school. Where a school engages us, it comes from the school.
​
3. Why we process it, and our lawful basis
3.1 To provide the services and perform our contract with you — arranging and delivering sessions, matching tutors, invoicing,
and communicating about scheduling, progress and feedback. Our lawful basis is performance of a contract.
3.2 For our legitimate interests — recruiting and assessing tutors, quality assurance, improving how we teach, keeping business
records, and establishing or defending legal claims. We balance these interests against your rights before relying on them.
3.3 To comply with our legal obligations — including accounting and tax records, safeguarding duties, and responding to lawful
requests from authorities.
3.4 Special category data. Where information about a student's health or additional needs is genuinely special category data, we
process it with your explicit consent, given when you tell us about it so that the tutor can plan properly. You can withdraw that
consent at any time, and we will stop using the information and delete it unless we are required to keep it. Where a safeguarding
concern arises and consent is not available or would not be appropriate to seek, we process the information instead where it is
necessary for reasons of substantial public interest in connection with safeguarding children and individuals at risk.
3.5 Consent. Where we rely on consent — for example, to share information with a student's school when that school is not our
client — you can withdraw it at any time by contacting us. Withdrawing consent does not affect processing that has already taken place.
3.6 Session recordings. We record sessions so that the student can revisit what was taught and so that the parent or guardian can see
what was covered. We also keep a record of sessions delivered to children, and rely on it where a safeguarding concern or a complaint
is raised. Our lawful basis is our legitimate interests in those purposes. We have balanced them against the rights of the student and
the client, and the client or the student may ask us not to record at any time.
​
4. Who we share personal data with
4.1 Tutors and consultants. Our tutors and consultants are self-employed contractors engaged by us to deliver our services. We
share the student information necessary for delivery with the assigned tutor, who must handle it in line with our instructions.
4.2 Parents and guardians. We share student information with the parent or guardian who engaged us, including progress updates
and feedback.
4.3 Schools. Where a school is our client, we share information about the students we teach for them. Where a school is not our
client, we share information with it only with your written consent.
4.4 Service providers. We use third parties for IT services, video conferencing, payment processing and administrative support.
They process personal data on our instructions and are not permitted to use it for their own purposes.
4.5 Authorities. We disclose information to a local authority, the police, or another regulatory or law enforcement body where we
are required to by law, or where it is necessary to safeguard a child or an adult at risk.
4.6 A transfer of our business. If our business is sold or restructured, personal data may transfer to the acquiring organisation,
which would remain bound by this policy.
4.7 What we never do. We never sell or rent personal data, and we do not share it with other clients without the written consent of
the person concerned.
4.8 Session recordings. A recording is available on the platform to the client, the student and the assigned tutor. The Director has
access to the platform and reviews a recording where a safeguarding concern or a complaint is raised. It is not shared with anyone
else except where clause 4.5 applies.
​
5. Transfers outside the UK
5.1 We work with students and, in some cases, tutors based outside the United Kingdom, and some of our service providers store
data outside it. Where personal data is transferred outside the UK, we make sure it is protected by an adequacy decision, by standard
contractual clauses approved for use in the UK, or by another safeguard permitted by law.
5.2 You can ask us for details of the safeguard applying to a particular transfer.
​
6. How long we keep personal data
6.1 We keep personal data for as long as we need it for the purpose we collected it for, and then delete it.
6.2 Client and student records are kept for at least three years after the engagement ends, so that we can respond to questions,
provide references or continuation support, and deal with any claim. We review our records periodically and delete those we no
longer need.
6.3 Tutor records, including vetting information, are kept for at least three years after the last session a tutor delivered for us, and
reviewed periodically with everything else. We use the last session rather than a formal end date because tutors often simply stop
taking assignments rather than telling us they have finished.
6.4 Financial records are kept for six years after the end of the accounting period they relate to, as required by law.
6.5 Safeguarding records are kept for longer, in line with our Safeguarding Policy, because the reasons for keeping them can persist
into adulthood.
6.6 Session recordings are deleted 90 days after the session, and any remaining recordings are deleted when the engagement ends.
Where a recording relates to a safeguarding concern or a complaint, we keep it for as long as our Safeguarding Policy requires. Where
a client or student downloads a recording from the platform, the copy they keep is outside our control and these timescales do not
apply to it.
​
7. Your rights
7.1 Your rights. You have the right to ask us for a copy of the personal data we hold about you; to have inaccurate data corrected; to
have data deleted in certain circumstances; to restrict how we process it; to receive it in a portable format; and to object to processing
we carry out on the basis of our legitimate interests.
7.2 Rights on behalf of a child. Where the student is under 18, the parent or guardian who engaged us normally exercises these
rights on their behalf. An older student may exercise them directly where they understand what they are asking for.
7.3 How to exercise them. To exercise any right, contact us at hello@avaloneducation.co.uk. We will respond within one month.
7.4 Complaints. If you are unhappy with how we have handled your personal data, please tell us first so we can put it right. You also
have the right to complain to the Information Commissioner's Office at ico.org.uk, or by calling 0303 123 1113.
​
8. Keeping personal data secure
8.1 Our measures. We use access controls, secure passwords and two-factor authentication to protect personal data. No method of
transmission or storage is completely secure, and we cannot guarantee absolute security.
8.2 Special category data, and data about children and adults at risk. We keep this to the minimum we need, limit access to the
Director and the assigned tutor, and do not copy it beyond what delivery requires. Session recordings are also available to the client
and the student, who they are for.
8.3 If there is a breach. We will act immediately to assess and contain it, work out what data has or may have been compromised,
tell the people affected in clear language, take steps to prevent compromised data being misused, and keep those affected informed as
our assessment of the risk changes. We will report the breach to the Information Commissioner's Office where we are required to.
​
9. Changes to this policy
9.1 We may update this policy. The current version is the one posted on our website, and the "last updated" date changes when we revise it.
9.2 Where a change materially affects how we use personal data we already hold, we will tell affected clients directly rather than
relying on the website alone.
​
10. Contact us
Avalon Education Limited
+44 20 8156 4942
124 City Road, London, EC1V 2NX