Version: 1.0
Effective date: 27 August 2026
This Privacy Notice explains how Quantum Brain Tutoring Ltd collects, uses, stores and shares personal information in connection with private tutoring, academic mentoring and related pastoral educational support.
This Notice is written mainly for parents, guardians and adult learners. A shorter Student Privacy Summary is available for children and young people. Children have their own data-protection rights and should be helped to understand how their information is used.1
Privacy at a glance
| Topic | Our approach |
|---|---|
| Who controls the information? | Quantum Brain Tutoring Ltd is the controller for the tutoring activities described in this Notice. |
| Whose information do we use? | Enquirers, Customers, Students, parents or guardians, emergency contacts and people named in complaint or safeguarding records. |
| Why do we use it? | To respond to enquiries, arrange and provide tutoring, personalise learning, manage payments, protect Students, communicate, handle complaints and comply with law. |
| Sensitive information | We collect health, SEND, disability, wellbeing or safeguarding information only where relevant and with an additional legal condition where required. |
| Recordings | Tutoring Sessions are not routinely recorded. Any planned recording requires prior written arrangements and a defined purpose and retention period. |
| Marketing | We do not use children’s information for direct marketing. Adults can opt out of marketing at any time. |
| Selling data | We do not sell personal information. |
| Automated decisions | The personality or learning assessment informs human Tutor decisions. It is not used to make solely automated decisions with legal or similarly significant effects. |
| Safeguarding | We may share necessary information without consent where this is appropriate to protect a child or another person. |
| Your choices and rights | Depending on the circumstances, you may ask for access, correction, deletion, restriction, portability or object to certain uses. |
| Contact | Email quantumbraintutoring@gmail.com and mark the message “Privacy”. |
1. Who we are
Quantum Brain Tutoring Ltd is a company registered in England and Wales under company number 16347406. Its registered office is Knoll House, Knoll Road, Camberley, Surrey, GU15 3SY.
For the tutoring activities covered by this Notice, Quantum Brain Tutoring Ltd is normally the controller. This means that we decide why and how personal information is used.
Our privacy contact is:
Privacy Lead
Quantum Brain Tutoring Ltd
Knoll House, Knoll Road, Camberley, Surrey, GU15 3SY
Email: quantumbraintutoring@gmail.com
Please use the subject line “Privacy”.
2. What this Notice covers
This Notice applies to personal information used for:
- enquiries about private tutoring or pastoral educational support;
- onboarding and Booking Confirmations;
- one-to-one or group tutoring supplied online or in person;
- academic mentoring, examination preparation and homework support;
- personality-style or learning assessments used to personalise tutoring;
- routine progress, attendance and Customer communications;
- invoices, payment administration, cancellations and credits;
- complaints, disputes, safety incidents and safeguarding; and
- the tutoring pages of https://learnwithqbt.co/.
This Notice does not cover the QBT Revision application, digital-resource purchases, school licences, school accounts, recruitment, or Tutor employment and contractor administration. Those activities require separate or additional privacy information. Where a school engages QBT, the school and QBT may have different controller or processor roles, which should be explained in the school contract and relevant school privacy information.
3. The people whose information we use
We may use information about:
- a parent, guardian or other adult who enquires, contracts or pays for Services;
- an Adult Student who contracts directly;
- a Student under 18 who receives Services;
- an emergency contact or another authorised family contact;
- a person who makes, is affected by, or is named in a complaint;
- a person named in a safeguarding disclosure, concern, incident or referral; and
- website visitors who submit a form or use our tutoring pages.
Where a parent or guardian provides information about a Student or emergency contact, they should give that person this Notice or the appropriate Student Privacy Summary where it is safe and reasonable to do so.
4. Information we may collect
The information we use depends on the Services requested and what happens during the relationship.
| Category | Examples |
|---|---|
| Identity and relationship | Name, title, age, date of birth, Customer/Student relationship, parent or guardian status and signature or electronic acceptance |
| Contact and emergency | Postal address, email, telephone number, emergency contact and authorised contacts |
| Education and learning | Subject, academic level, examination board, school year, prior attainment, goals, availability, homework, Student work, lesson notes, attendance, progress, feedback and Tutor allocation |
| Assessment and preferences | Responses to personality-style, learning-preference or academic assessments and the Tutor’s educational interpretation |
| Contract and payment | Booking Confirmation, policy versions, Fees, invoices, payment status, credits, cancellations, transaction reference and correspondence about amounts due |
| Online and technical | Videoconferencing display name, Session link/access record, IP address, device/browser information, security logs, form metadata and cookie choices |
| Communications | Emails, messages, telephone notes, requests, feedback and records of material agreed changes |
| Service and conduct | Punctuality, non-attendance, behaviour, adjustments, safety or venue information and relevant incident records |
| Complaints and claims | Complaint, response, supporting material, settlement, insurance, legal and regulatory correspondence |
| Special-category information | Health, disability, SEND, allergies, mental or emotional wellbeing, racial or ethnic origin, religion or other sensitive information where relevant and lawfully used |
| Safeguarding and criminal-offence information | Concerns, disclosures, allegations, observed behaviour, referral details, risk decisions, police/local-authority involvement and limited DBS-related information where lawful and necessary |
| Images, audio and video | Only where a Session or specific activity is recorded or photographed under an agreed, lawful arrangement, or where incident evidence is lawfully retained |
We aim to collect only information that is reasonably necessary. Please do not send detailed medical, safeguarding or criminal information through a general website enquiry form unless it is necessary to protect someone. Contact us so that we can provide an appropriate and secure route.
5. Where information comes from
We receive information directly from adult Customers and Adult Students. We may also receive Student information from a parent or guardian, from the Student during tuition, from Tutors and authorised QBT personnel, or from an emergency contact.
Where appropriate and lawful, information may come from a school, SENCO, counsellor, health or education professional, local authority, police, safeguarding body, payment provider, communications provider, professional adviser or another person involved in a concern or complaint.
We may create information through our work, such as lesson notes, attendance records, educational assessments, progress observations, invoices, safeguarding decisions and complaint outcomes.
If we receive personal information from someone other than the person concerned, we will provide appropriate privacy information within the period required by law unless an exemption applies—for example, where doing so would seriously prejudice safeguarding or another lawful purpose.2
6. How and why we use information
UK data-protection law requires a lawful basis for each use of personal information. More than one basis may apply depending on the facts.
| Purpose | Information normally used | Main lawful basis |
|---|---|---|
| Respond to an adult’s enquiry and prepare an offer | Identity, contact, Student, subject, level, availability and requested support | Steps requested before a contract for the adult; legitimate interests in understanding and responding to the Student’s needs |
| Form and administer the tutoring contract | Customer, Student, contact, Booking Confirmation, timetable, Fees and acceptance | Contract for Customer information; legitimate interests for related Student administration |
| Deliver and personalise tutoring | Education, learning, attendance, assessments, Student work and progress | Contract with the Customer; legitimate interests in providing effective and appropriately tailored tutoring to the Student |
| Allocate, support or replace a Tutor | Student needs, availability, relevant progress and safety information | Contract and legitimate interests in providing a suitable, continuous and safe service |
| Provide learning or accessibility adjustments | Relevant SEND, disability, health, communication and environmental information | Contract and legitimate interests, together with an additional special-category condition where required |
| Provide pastoral educational support | Goals, communications, session notes and relevant wellbeing information | Contract and legitimate interests, together with an additional special-category condition where required |
| Arrange online or in-person Sessions | Contact, timetable, access, technical, venue and attendance information | Contract and legitimate interests in secure and effective service operation |
| Invoice, collect payment and maintain financial records | Customer, invoice, payment, transaction and account information | Contract, legal obligation and legitimate interests in fraud prevention and debt recovery |
| Manage cancellations, complaints, disputes and claims | Communications, contract, attendance, payment and supporting evidence | Contract; legitimate interests in resolving disputes and establishing, exercising or defending legal claims; legal obligation where applicable |
| Protect Students and others | Safeguarding, emergency, health, incident and referral information | Legitimate interests; legal obligation where applicable; vital interests in an emergency; additional sensitive-data conditions as required |
| Maintain quality, security and records | Feedback, audit, technical, security and minimised service information | Legitimate interests in safe, reliable and effective Services and in demonstrating compliance |
| Send optional marketing to adults | Adult name, contact, service interest, consent and opt-out | Consent, or legitimate interests where appropriate, together with the Privacy and Electronic Communications Regulations requirements |
| Comply with law and cooperate with authorities | Relevant contract, financial, identity, safety, complaint and safeguarding information | Legal obligation, legitimate interests, vital interests or legal claims as appropriate |
Our legitimate interests include responding to enquiries; delivering, tailoring and improving education; allocating Tutors; protecting Students, Tutors and QBT; securing systems; preventing fraud; maintaining proportionate records; resolving complaints; and establishing or defending legal claims. Before relying on legitimate interests for children’s information, we must give particular weight to the child’s interests, rights and reasonable expectations.1
7. Sensitive information
7.1 Special-category information
Information about health, disability, racial or ethnic origin, religion and certain other matters receives additional legal protection. Where we use it, we need both an ordinary lawful basis and an additional condition under Article 9 of the UK GDPR.3
Depending on the purpose, we may rely on:
- explicit consent, particularly for optional health, SEND or wellbeing information used only to personalise or adjust tutoring;
- vital interests, where necessary to protect someone who cannot give consent;
- establishing, exercising or defending legal claims; or
- substantial public interest, together with an applicable Data Protection Act 2018 condition, such as safeguarding a child or person at risk.
Where explicit consent is used, it is voluntary and may be withdrawn for future use. Withdrawal does not make earlier lawful processing unlawful and does not require us to erase information that we must retain under another legal basis. If relevant adjustment information is not provided, we may be unable to provide the requested tailoring safely or effectively.
7.2 Safeguarding information
Data-protection law does not prevent necessary and proportionate information sharing to safeguard a child. Consent is not normally required where another lawful basis is more appropriate.4
We may record and share information where reasonably necessary to prevent harm, assess a risk, respond to a disclosure or allegation, seek advice, make a referral, manage an emergency or cooperate with an investigation. Depending on the circumstances, recipients may include a parent or guardian, a school safeguarding lead, local-authority children’s services, the police, emergency services, the Disclosure and Barring Service, professional advisers, insurers or another appropriate body.
We may decide not to tell a person before or after sharing where notice could place someone at risk, prejudice an investigation, disclose another person’s confidential information or conflict with a lawful exemption. We document safeguarding decisions and limit disclosure to what is necessary for the protective purpose.
7.3 Criminal-offence information and DBS records
We use criminal allegations, convictions or DBS-related information only where authorised by law and necessary for safeguarding, safer working, legal obligations or claims. We maintain the additional safeguards and policy documentation required for the condition relied on.
QBT should not ordinarily keep a copy of a DBS certificate. It may keep limited check information, such as the date, level, certificate reference and recruitment decision. If a copy is needed to resolve a dispute, it should normally be deleted within six months after the purpose has ended.5
8. Personality and learning assessments
QBT may ask a Student to complete a personality-style, learning-preference or academic assessment. We use responses to help a human Tutor understand possible learning preferences, communication approaches and areas for support.
These tools are educational aids. They are not medical or psychological diagnoses. We do not use them to make decisions solely by automated means that produce legal or similarly significant effects. A Tutor should consider the assessment alongside discussion, observation, academic information and the Student’s changing needs.
Participation in a personality-style assessment is voluntary unless it is clearly identified as an agreed part of a particular Service. A Customer or Student may ask us to explain, correct or stop using assessment information, subject to other lawful retention needs.
9. Children’s information and rights
Children merit particular protection because they may be less aware of the risks and consequences of data use. We aim to put the Student’s best interests first, use high privacy settings, minimise collection and explain our practices in age-appropriate language.1
A parent or guardian normally manages the tutoring contract, but the Student remains an individual with their own data-protection rights. Depending on the Student’s age, understanding and circumstances, we may respond directly to a capable Student, involve a parent, or both.
A parent does not automatically have an unrestricted right to every item of a child’s information. Before disclosing information, we may consider the Student’s competence, confidentiality, safeguarding, another person’s privacy and any legal restriction. We may withhold or redact information where disclosure could cause serious harm, prejudice safeguarding or reveal another person’s confidential data.
We do not use children’s information for direct marketing, behavioural advertising or unrelated commercial profiling under this tutoring Notice. We do not use a Student’s name, image, testimonial or identifiable work for publicity without separate, specific permission and an age-appropriate explanation.
10. Session recordings and photographs
Tutoring Sessions are not routinely recorded. If QBT proposes a recording, we will explain in advance:
- the purpose;
- what will be captured;
- who may access it;
- the lawful basis and, where needed, consent;
- the intended retention period; and
- how to withdraw consent where consent is the basis.
For a Student under 18, we will obtain the parent’s or guardian’s written agreement where appropriate and explain the recording to the Student in accessible language. We will also take the Student’s views into account.
Our normal period is deletion within 30 days, unless a different educational period was agreed or the recording must be retained for a safeguarding concern, complaint, incident, legal claim or lawful instruction.
11. Who we share information with
We do not sell personal information. We share it only where there is an appropriate purpose and lawful basis. Recipients may include:
| Recipient | Why information may be shared |
|---|---|
| Assigned Tutors and authorised QBT personnel | To arrange and provide safe, personalised Services on a need-to-know basis |
| Website, form, email, communications, cloud-storage and document providers | To host enquiries, communications and records under contractual and security controls |
| Videoconferencing and educational-platform providers | To operate online Sessions and agreed learning activities |
| Banks, accountants and payment providers | To process payment, keep accounts, meet tax duties and prevent fraud |
| IT, security and support providers | To maintain systems, backups, access controls and incident response |
| Professional advisers and insurers | To obtain legal, accounting, safeguarding, risk or claims support under duties of confidentiality |
| Parents, guardians and authorised school contacts | To administer tutoring, discuss progress and support the Student where appropriate |
| Police, emergency services, schools, local authorities, DBS and safeguarding bodies | To protect a child or another person, make or respond to a referral, or comply with law |
| Courts, regulators and public authorities | Where required by law or necessary for claims, enforcement or regulatory cooperation |
| A purchaser or successor to QBT’s business | For confidential due diligence and lawful business transfer, subject to appropriate safeguards |
Service providers that process information on our instructions must be subject to appropriate data-protection terms. Some recipients, such as banks, schools, safeguarding authorities or professional advisers, may act as independent controllers for their own legal purposes.
12. International transfers
Some technology or support providers may store or access information outside the United Kingdom. Where this creates a restricted international transfer, we will use a method permitted by UK data-protection law. This may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses, or another lawful safeguard, together with any required data-protection assessment.6
You may contact us for information about the relevant safeguard or how to obtain a copy, subject to necessary confidentiality redactions.
We will not state that all tutoring information remains in the UK or EEA unless this has been confirmed for every relevant provider, support-access location and onward transfer.
13. How long we keep information
We keep identifiable information only for as long as reasonably necessary for the stated purpose, including legal, accounting, safeguarding, insurance and claims requirements. We may retain information longer where litigation, a regulator, insurer, official inquiry or legal hold requires it. We may keep genuinely anonymised information because it no longer identifies a person.
Our working retention periods are:
| Record | Normal period |
|---|---|
| Enquiry where no contract follows | 12 months after the last meaningful contact |
| Booking Confirmation, contract, core service, invoice and payment records | 6 years after the contract ends or final payment, whichever is later |
| Detailed routine lesson notes, progress records and personality/learning assessments | 3 years after tutoring ends; essential contract evidence may be kept with the 6-year core record |
| Routine communications | 2 years after tutoring ends, unless needed for another record category |
| Optional health/SEND adjustment information | While needed for Services and normally 12 months afterwards, unless a safeguarding, complaint, claim or legal reason requires longer |
| Complaints, disputes, claims and insurance records | 6 years after closure, or longer while an active matter or legal hold continues |
| Child safeguarding file in England, Scotland or Wales | Normally until the Student reaches age 25 |
| Child safeguarding file in Northern Ireland | Normally until the Student reaches age 30 |
| Concern or allegation about an adult working with children | Until normal retirement age or 10 years after conclusion, whichever is longer, subject to safeguarding exceptions |
| Session recording | Normally 30 days, unless another period was agreed or a safeguarding/claim hold applies |
| Website security and technical logs | Normally up to 12 months; cookie durations appear in the Cookie Notice |
| Privacy-rights request | Normally 3 years after closure, longer if disputed or legally required |
| Marketing preference or suppression record | As long as reasonably needed to honour the opt-out |
The safeguarding periods reflect recognised child-protection recordkeeping guidance and may be extended where an inquiry, claim, insurer or public authority requires it.5 QBT will maintain a more detailed internal retention and deletion schedule and review it periodically.
14. Security
We use proportionate technical and organisational measures designed to protect information from unauthorised access, loss, alteration or disclosure. Measures should include role-based access, strong authentication, secure devices and communications, backups, confidentiality requirements, staff and Tutor training, secure deletion, processor due diligence and incident procedures.
Safeguarding records should be stored separately from routine educational records where practicable, with access limited to people who need the information. Sensitive information should not be kept indefinitely in personal Tutor devices, informal messaging histories or unapproved personal accounts.
No method of storage or transmission is completely risk-free. If a personal-data breach creates a risk to individuals, we will assess, record and notify it in accordance with applicable law.
15. Marketing and communications
Service messages about bookings, payments, Sessions, safety, policies and contractual changes are not marketing and may be sent where necessary to provide or administer the Services.
We may send marketing about QBT tutoring to an adult where the adult has consented or where the limited existing-customer exception applies and all legal conditions are met. Every electronic marketing message will identify QBT and provide a simple way to opt out. We do not send tutoring marketing directly to children.
Your right to object to direct marketing is absolute. You can ask us to stop at any time by using the unsubscribe method in a message or emailing quantumbraintutoring@gmail.com. We will stop marketing and may keep minimal information on a suppression list so that we respect your choice.7
16. Website, forms and cookies
When someone visits the tutoring website or submits a form, the website and its service providers may receive technical data such as IP address, device/browser information, security logs, form metadata and cookie choices. Enquiry form information is used to respond to the request and, where applicable, take steps toward a contract.
Essential cookies may be used for security and website functions. Non-essential analytics, embedded-media or advertising technologies require the legally appropriate choice before use. Details of specific cookies, providers, purposes and durations are available through the Cookie Settings or Cookie Notice on our website.
17. When information is required
We need enough Customer identity, contact, Student, scheduling and payment information to form and perform a tutoring contract. We may also need relevant safety or accessibility information to provide Services appropriately.
If required information is not provided, we may be unable to respond, accept a booking, allocate a suitable Tutor, process payment, make an adjustment or continue a Session safely. Optional information will be identified where practicable. We will not make access to ordinary tutoring conditional on unrelated marketing or publicity consent.
18. Your data-protection rights
Depending on the purpose, lawful basis and circumstances, an individual may have the right to:
- receive clear information about processing;
- request access to personal information;
- correct inaccurate or incomplete information;
- request erasure;
- request restriction of use;
- receive certain information in a portable form;
- object to processing based on legitimate interests;
- object absolutely to direct marketing;
- withdraw consent for future use where consent is relied on; and
- request safeguards relating to solely automated decisions with legal or similarly significant effects.
These rights are not all absolute. For example, we may need to keep information for legal claims or safeguarding, protect another person’s confidentiality, or apply a lawful exemption. We will explain our decision where required.
To make a request, email quantumbraintutoring@gmail.com with the subject line “Privacy request”. A request may also be made verbally. We may ask for proportionate information to confirm identity and authority. We normally respond without undue delay and within one calendar month; the law allows an extension in some complex cases.7
A capable child may exercise rights personally. A parent or representative may also make a request, but we will consider the Student’s age, understanding, wishes, safeguarding and confidentiality before disclosing information.
19. Complaints
You may make a data-protection complaint to QBT through any reasonable contact channel. Please email quantumbraintutoring@gmail.com with the subject line “Privacy complaint” where possible so that our Privacy Lead can investigate promptly.
We will acknowledge a data-protection complaint within 30 days, take appropriate steps to investigate it, keep you informed without undue delay and communicate the outcome without undue delay.8
You also have the right to complain to the Information Commissioner’s Office (ICO). Current contact and complaint information is available at https://ico.org.uk/make-a-complaint/data-protection-complaints/. The ICO can also be contacted through https://ico.org.uk/global/contact-us/.
Complaining to QBT first does not remove the right to contact the ICO or seek another legal remedy.
20. Changes to this Notice
We will review this Notice when our Services, systems, providers or legal obligations change. The current version and effective date will be displayed on the website. If a change materially affects an existing Customer or Student, we will take reasonable steps to bring it to their attention.
We will keep prior versions so that we can identify which Notice applied at a particular time.
21. Contact details
Quantum Brain Tutoring Ltd
Company number: 16347406
Registered office: Knoll House, Knoll Road, Camberley, Surrey, GU15 3SY
Privacy email: quantumbraintutoring@gmail.com
Website: https://learnwithqbt.co/
