Draft — to be reviewed by a lawyer before launch. · Wersja robocza — przed startem sprawdzi ją prawnik.
Privacy Policy (Tutorfold platform)
DRAFT — to be reviewed by a lawyer before launch (P14.5). Version 2026-11-draft.
Who is responsible. For tutors' accounts and Tutorfold's own website: Tutorfold [company details] is the controller. For students' data inside a school: the school (tutor) is the controller and Tutorfold processes it for them (see the Data Processing Agreement).
What we collect. Tutor account and billing details; usage data (class hours, video minutes, AI use) to run plans and allowances; sign-in records for security; website contact messages. Inside schools: what the school and its students put in.
Why. To provide the service (contract), to bill (contract, legal duty), for security and fraud prevention (legitimate interest), and with consent for optional tracking cookies on a school's website.
How long. While the account is active, then up to 30 days; encrypted backups are kept up to 12 months, then deleted; billing records as long as tax law requires (5 years).
[LAWYER: backups are encrypted copies of the whole database kept with Cloudflare (R2) and Google (Drive) and on company-controlled encrypted equipment (not a sub-processor). Retention resolved 2026-11-06: every backup copy, monthly ones included, is deleted after at most 12 months (BACKUPS.md); please confirm the wording.]
Your rights. Access, correction, deletion, restriction, portability, objection, and complaint to the President of the Personal Data Protection Office (UODO). Students exercise their rights through their school.
Sub-processors.
| Provider | What for | Where |
| Railway | Hosting and database | EU (Amsterdam, Netherlands) |
| Cloudflare | Domains, certificates, file storage and encrypted backups (R2) | Global (SCCs) |
| Encrypted backup copies (Google Drive) | Global (SCCs) | |
| Stripe | Payments (Tutorfold plans; schools' own Stripe accounts) | EU / US (SCCs) |
| Resend | E-mail delivery | EU / US (SCCs) |
| Daily.co, LiveKit | Video classes | EU / US (SCCs) |
| Soniox | Live transcription when a school switches AI notes on | US (SCCs) |
| Anthropic | AI features (worksheets, lesson plans, notes, M assistant) | US (SCCs) |
| OpenAI | Picture generation and text-to-speech | US (SCCs) |
Cookies. Tutorfold uses only cookies needed to sign in. A school's website loads tracking pixels (Meta, Google, TikTok) only if the school sets them up and the visitor agrees in the cookie banner.