Last modified: 1st May 2020.
Since we started Tutella, we’ve aspired to build our Services with a set of strong privacy principles in mind. If you live in a country in the European Economic Area (which includes the European Union), and any other included country or territory (collectively referred to as the European Region), your Services are provided by Tutella, which is also the data controller responsible for your information when you use our Services.
Please also read Tutella’s Terms of Service (“Terms”), which describes the terms under which you use our Services.
Information We Collect
Tutella must receive or collect some information to operate, provide, improve, understand, customise, support, and market our Services, including when you install, access, or use our Services. The types of information we receive and collect depend on how you use our Services.
- Your Use Of Our Payments Services.If you use our payment services available in your country, we process purchase and transaction information.
- Customer Support. You may provide us with information related to your use of our Services, including copies of your messages, and how to contact you so we can provide you customer support. For example, you may send us an email with information relating to our app performance or other issues.
Automatically Collected Information
- Usage And Log Information.We collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services, the features you use whether you are online, when you last used our Services (your “last seen”), and when you last updated your about information.
- Device And Connection Information.We may collect device and connection-specific information when you install, access, or use our Services. This includes information like hardware model, operating system information, battery level, signal strength, app version, browser information, and mobile network, connection information including phone number, mobile operator or ISP, language and time zone, and IP, device operations information, and identifiers like device identifiers (including identifiers unique to Facebook Company Products associated with the same device or account).
- Location Information.We may collect device location information if you use our location features.
- Third-Party Service Providers.We work with third-party service providers, Instagram and the Facebook Companies to help us operate, provide, improve, understand, customise, support, and market our Services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, supply location, map, and places information, process payments, help us understand how people use our Services, market our Services , conduct surveys and research for us, and help with customer service. These companies may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues.
- Third-Party Services. We allow you to use our Services in connection with third-party services. If you use our Services with such third-party services, we may receive information about you from them. Please note that when you use third-party services or Facebook Company Products, their own terms and privacy policies will govern those services.
How We Use Information
We use the information we have (subject to choices you make) to operate, provide, improve, understand, customise, support, and market our Services.
- Our Services.We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing, and customising our Services. We also use your information to respond to you when you contact us.
- Safety And Security.We verify accounts and activity, and promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our Terms, and to ensure our Services are being used legally.
- Communications About Our Services.We use the information we have to communicate with you about our Services and features and let you know about our terms and policies and other important updates. We may provide you marketing for our Services.
- No Third-Party Banner Ads.We do not allow third-party banner ads on Tutella.
Information You And We Share
You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customise, support, and our Services.
How The General Data Protection Regulation Apply
Our Legal Bases For Processing Information
We collect, use, and share the information we have as described above:
- as necessary to fulfil our Terms;
- consistent with your consent, which you can revoke at any time;
- as necessary to comply with our legal obligations;
- occasionally to protect your vital interests, or those of others;
- as necessary in the public interest; and
- as necessary for our (or others’) legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How You Exercise Your Rights
Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can access tools to rectify, update, and erase your information directly in-app. If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages.
Managing And Deleting Your Information
We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.
If you would like to manage, change, limit, or delete your information, we allow you to do that through the app.
Law And Protection
We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, Tutella, or others, including to prevent death or imminent bodily harm.
The Data Protection Officer for Tutella can be contacted here.
If you have questions about our Policies, please contact us or write us here:
TUTELLA LANGUAGE TRAVEL(TLT) LTD
Attn: Tutella Policy Team
1 Elm Grove, Taunton, Somerset, TA1 1EG
You have the right to lodge a complaint with Tutella lead supervisory authority, The Data Protection Commissioner, or your local supervisory authority.
How We Process Your Information
Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we’ve explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data under the General Data Protection Regulation (the “GDPR”).
For all people who have legal capacity to enter into an enforceable contract, we process data as necessary to perform our contracts with you (the Terms of Service, the “Terms”). We describe the contractual services for which this data processing is necessary in Our Services section of the Terms and in the additional informational resources accessible from our Terms. The core data uses necessary to provide our contractual services are:
- To provide, improve, customise, and support our Services as described in “Our Services”;
- To promote safety and security;
- To transfer, transmit,store, or process your data outside the EEA, including to within the United States and other countries; and
- To communicate with you, for example, on Service-related issues.
We’ll use the data we have to provide these services; if you choose not to provide certain data, the quality of your experience using Tutella may be impacted.
When we process data you provide to us as necessary to perform our contracts with you, you have the right to port it under the GDPR.
The other legal bases we rely on in certain instances when processing your data are:
- For collecting and using information you allow us to receive through the device-based settings when you enable them (such as access to your GPS location, camera, or photos), so we can provide the features and services described when you enable the settings.
When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to port that data you provide to us, under the GDPR.
Our legitimate interests or the legitimate interests of a third party, where not outweighed by your interests or fundamental rights and freedoms (“legitimate interests”):
For people under the age of majority (under 18, in most EU countries) who have a limited ability to enter into an enforceable contract only, we may be unable to process personal data on the grounds of contractual necessity. Nevertheless, when such a person uses our Services, it is in our legitimate interests:
- To provide, improve, customise, and support our Services as described in Our Services;
- To promote safety and security; and
- To communicate with you, for example, on Service-related issues.
The legitimate interests we rely on for this processing are:
- To secure our platform and network, verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, and keep our Services free of harmful or inappropriate content, and investigate suspicious activity or violations of our terms or policies and to protect the safety of people under the age of majority, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable.
For all people, including those under the age of majority:
- For providing measurement, analytics, and other business services where we are processing data as a controller.The legitimate interests we rely on for this processing are:
- To provide accurate and reliable reporting to our businesses, to ensure accurate pricing and statistics on performance.
- In the interests of our business to help us understand and validate our pricing models, and evaluate the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
Compliance with a legal obligation:
- For processing data when the law requires it, including, for example, if there is a valid legal request for certain data.
Protection of your vital interests or those of another person:
- The vital interests we rely on for this processing include protection of your life or physical integrity or that of others, and we rely on it to combat harmful conduct and promote safety and security, for example, when we are investigating reports of harmful conduct or when someone needs help.