Privacy Policy

Introduction

PRIVACY POLICY

This privacy policy sets out how AP Tutoring Limited, trading as Sunbeam Education, uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
4. HOW WE USE YOUR PERSONAL DATA (paragraph 4)
5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
6. INTERNATIONAL TRANSFERS (paragraph 6)
7. DATA SECURITY (paragraph 7)
8. DATA RETENTION (paragraph 8)
9. YOUR LEGAL RIGHTS (paragraph 9)
10. CONTACT DETAILS (paragraph 10)
11. COMPLAINTS (paragraph 11)
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)
13. THIRD PARTY LINKS (paragraph 13)

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Sunbeam Education collects and uses your personal data through your use of this website (which includes our web app, accessible via https://app.sunbeameducation.com/), including any data you may provide when you create an account with us or book a tutoring session.

This website is for tutors and for parents and guardians booking support for children (or for adult learners booking for themselves). It is not intended to be used by children. We do collect information about the learners that sessions are booked for, from the person who books.

Controller

AP Tutoring Limited, a limited company registered in England and Wales with company number 14617626 and registered office address at Brook Cottage, Filkins, Lechlade, England, GL7 3JQ is the controller and responsible for your personal data (collectively referred to as “Sunbeam Education”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, residential address, email address and telephone numbers.
• Financial Data includes payment card and bank account details. You give these directly to our payment provider, Stripe: customers enter card details in Stripe’s payment form, and tutors give their bank and identity details to Stripe when they set up payouts. We don’t see or store full card or bank details; we keep Stripe’s reference numbers and can see limited details, such as the last four digits of a card. Stripe also uses this data for its own purposes, such as identity checks and fraud prevention, under its own privacy policy.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us or from the tutors on our platform.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, profile picture, bookings made by or with you, your interests, preferences, educational and professional background, feedback, reviews you have given or received, and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Messages Data. Messages you send and receive, including their content.
• Learner Data includes information about the learner a booking is for: their age, education level, the subjects and support they need, your goals for the support and what led you to look for it. We also ask how you found us.
• Medical Data includes the medical diagnosis or condition of the learner and their special educational needs. This includes the type of special educational needs or health support you choose when you book (for example ADHD, autism, dyslexia, or anxiety or SEMH), what you tell us about the learner’s needs on our intake form, and the EHCP and professional reports you send us if you order an EHCP audit. We only use Medical Data with your explicit consent. When you book, we ask for your consent whenever you choose a special educational needs or health support type or describe the learner’s needs, unless you have already given it. We keep a record of your consent with your account, and it applies to your later bookings until you withdraw it. If you order an EHCP audit, you give your consent when you place your order. You can withdraw your consent at any time by contacting us (see paragraph 10). We use Medical Data to help match you with a suitable tutor, and we share it with each tutor you book, so they can prepare for your sessions. EHCP audit documents are reviewed by our own team and are not shared with tutors. We don’t share Medical Data with anyone else, except the service providers who store or process it for us, or where the law requires it or it is needed to protect a child.
• Criminal history includes the information provided via the Disclosure and Barring Service (DBS) by tutors when applying to become tutors on our website, and the results of the status checks we make through the DBS Update Service.
• Tutor Documents Data includes the documents tutors upload to show they meet our requirements, such as insurance and safeguarding training certificates, and the results of our checks on them.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

If you don’t provide personal data

Some information is needed to provide our services. Customers must give their name, email address and phone number to book, and a location for in-person sessions. Tutors must give the information and documents we ask for, including DBS, insurance and safeguarding evidence, before we can list them. If you don’t provide it, we may not be able to provide our services to you, and we’ll tell you if this is the case. Our intake form questions are optional.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms, creating accounts, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • book tutoring sessions as a customer;
  • apply to become a tutor on our website;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • use our platform and, for example, exchange messages with tutors or clients;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data, such as analytics, is collected from providers such as Google based outside the UK.
  • Contact, Financial and Transaction Data is collected from our payment provider, Stripe.
  • Criminal records data is collected via the Disclosure and Barring Service (DBS), including through status checks with the DBS Update Service.
  • Identity and Contact Data (your name, email address and Google account ID) is collected from Google if you choose to sign in with your Google account.
  • Learner and Medical Data about a child is collected from the parent or guardian who books, and from the EHCP and professional reports they send us.
  • The names and email addresses of a tutor’s former students (or their parents or carers) are collected from the tutor, when the tutor asks us to send them a request to review the tutor.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have asked for your active agreement to use your personal data for a specific purpose: your explicit consent to us using information about a learner’s health and special educational needs, a tutor’s consent to us using their DBS certificate details and checking them through the DBS Update Service, a tutor’s agreement to us promoting their profile on social media, and your agreement to non-essential cookies.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

We send marketing only to customers, not to tutors. If you are a customer, when you create an account you can tell us that you don’t want to receive news and offers from Sunbeam Education by email, and you can change your choice at any time in your profile. You will also receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us via https://sunbeameducation.com/contact.

If you opt out of marketing, you will still receive messages about your account and bookings: for example booking confirmations, session reminders, changes and cancellations, payment problems, messages from your tutor, requests to review your tutor, and changes to our terms.

Cookies

We use non-essential cookies (such as analytics and advertising cookies) only if you agree to them. For more information about the cookies we use on our website and our web app and how to change your cookie preferences, please see https://sunbeameducation.com/cookie-policy/.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Specific third parties listed in the table Purposes for which we will use your personal data above, such as tutors (if you are a customer), or customers (if you are a tutor).
• Service providers acting as processors who provide IT, hosting, payment, email, video hosting, video-conferencing, mapping, calendar, analytics and document-checking services to us.
• Professional advisers (such as lawyers, accountants and insurers), HM Revenue & Customs, regulators and other authorities, including the Disclosure and Barring Service, the police and local authority safeguarding teams, where the law requires it or it is needed to protect a child.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

What tutors can see

When you book a tutor, we give that tutor your name, email address and phone number, the booking details (date, time, subject or type of support, education level and, for in-person sessions, the location you gave us), your intake form answers, and the messages you send them. Tutors receive this by email and can see your bookings and messages in their tutor account. Each tutor sees only their own customers’ information. Tutors and Sunbeam Education are separate, independent controllers of this information: each tutor is responsible for how they use it, must use it only to deliver and manage your sessions, and must not keep it for longer than they need it. Other tutors and the public see only what is on a tutor’s public profile, including reviews.

If you are a tutor, we don’t share data generated by your use of our platform with other tutors, and we share it with third parties only as described in this privacy policy. While your agreement with us is in force, you can see the information above about your own customers in the tutor interface. After it ends, we may close your access to the tutor interface, but you can still ask us for a copy of the personal data we hold about you (see paragraph 9).

6. International transfers

We share your personal data with service providers that carry out certain functions on our behalf, some of which are based outside the UK. This may involve transferring your personal data to countries whose laws do not provide the same level of protection as UK law.

Whenever we transfer your personal data out of the UK, we make sure it receives a similar degree of protection, either by transferring it only to countries or organisations that the UK has found to provide an adequate level of protection (for example, US organisations certified under the UK Extension to the EU-US Data Privacy Framework), or by using the international data transfer agreement or addendum approved by the Information Commissioner. You can contact us for more information about these safeguards or a copy of them.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We keep your personal data only for as long as we need it:

• Account details (Identity, Contact, Profile and Marketing and Communications Data): while your account is open. If you delete your account, we delete or anonymise them within 30 days, except what we must keep for the reasons below.
• Bookings and payments (Transaction Data, including the subject or type of support booked): six years from the end of the financial year in which the booking took place, to meet tax and accounting rules and to deal with any claims.
• Intake form answers: until you withdraw your consent or delete your account, and no more than 12 months after your last session.
• EHCP audit documents: we delete the EHCP and reports you send us 3 months after we deliver our report, and keep our report for 12 months unless you ask us to delete it sooner.
• Messages: while both accounts in the conversation are open, and no more than 2 years after the last message.
• Tutor applications that don’t go ahead: 12 months after our decision.
• DBS: we delete the copy of a tutor’s DBS certificate within 6 months of our decision on it. We keep a record of the certificate number, each Update Service check and its result, and our decision while the tutor is listed with us and for six years after they leave.
• Technical Data in our logs: up to 12 months.

We may keep data for longer if there is a complaint, a safeguarding concern or a legal claim.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details, paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: info@sunbeameducation.com
• Postal address: Brook Cottage, Filkins, Lechlade, England, GL7 3JQ

Our data protection lead is Alex Pagett, who you can contact at info@sunbeameducation.com.

11. Complaints

You can complain to us about how we use your personal data by emailing info@sunbeameducation.com. We will acknowledge your complaint within 30 days and tell you the outcome without undue delay.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 4 November 2026. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.