Thank you for visiting Tutling app

This Privacy Policy is subject to the terms and conditions contained on Tutling Mobile app ("this App"),

and all definitions contained in such terms and conditions shall apply equally to this Privacy Policy.

References to "this app", "we", "us", "our" and "ours" in this Privacy Policy mean tutling app. The

terms "you", "your" and "yours" when used in this Privacy Policy mean any user of this app.

By continuing to use this app, you agree to the terms and conditions set out in this Privacy Policy.

Please note that by submitting information via this app, you consent to the collection, collation,

processing and storing of such information and the use and disclosure of such information in

accordance with this Privacy Policy. We recommend that you read this Privacy Policy together with

our terms and conditions prior to submitting information to this app.

The Privacy Policy below to help you to understand better how we use your personal information. In

it, we explain in more detail the types of personal information we collect, how we collect it, what we

may use it for and who we may share it with.

Within the Privacy Policy you will find some specific examples of why and how we use your personal

information. If you have further questions please get in touch with us by contacting the Tutling Data

Protection Officer, using the below contact details.

Head Office Tutling (Pty) Ltd

Email address Info@tutling.co.za

At: Data Protection Officer

We are committed to respecting your privacy and protecting your personal information.

 We will be transparent about the information we are collecting and what we will do with it.

 We will use the information you give us for the purposes described in our Privacy Policy, which

include providing you with products and/or services you have requested and enhancing your

experience with this app.

 We will also use the information to help us understand you better and, if permitted to do so

in terms of applicable law, give you information on relevant offers.

 If you tell us that you don’t want to receive marketing messages, we will stop sending them.

We will, of course, continue to send essential information relating to a product or service you

have purchased to keep you informed about your order.

 We will put in place measures to protect your personal information and keep it secure.

 We will respect your data protection rights and aim to give you control over your own personal

information.

Within the Privacy Policy you will find some specific examples of why and how we use your personal

information. If you have further questions please get in touch with us by writing to the Data Protection

Officer.

Without prejudice to your rights under applicable laws, the above and the Privacy Policy are not

contractual and do not form part of your contract with us.

Controller of / Responsible Party for Personal Information:

Any personal information processed by tutling in connection with this Privacy Policy is controlled by

tutling which is considered the "controller" or "responsible party" of your personal information South

African data protection law.

What do we mean by Personal Information?

Personal information means details which identify you or could be used to identify you, such as your

name and contact details and purchase history. It may also include information about how you use

our websites and mobile applications.

When does this policy apply?

This Privacy Policy applies to personal information about you that we collect, use and otherwise

process regarding your relationship with us as a customer or potential customer, including when you

purchase products or use our services, use our websites or mobile applications, contact our offices.

Where we reference that others are controllers or responsible parties in the sections "Controller of /

Responsible party for personal information" and "Who do we share your personal information with?"

you should consult their privacy policies for further information.

Additional terms and conditions or policies may apply if you elect to take additional products or

services from us.

How can you keep your Personal Information Secure?

We are committed to implementing leading data security safety measures and we take great care to

protect the personal information you provide to us.

We have specialized security measures in place who constantly review and improve our measures to

protect your personal information from unauthorized access, accidental loss, disclosure or

destruction.

Here are some things you can do to keep your information secure.

Keep your email correspondences confidential.

When you book a lesson and other activities, you will be sent information and reminders. This will

appear on the email confirmation sent to you or push notifications. You should always keep these

details and login details confidential.

Giving your login details to others may allow them to access your booked lessons.

Keep your registered customer log-in details confidential.

To make sure your access to our app, other online services, and website is secure, you should not

share your log-in details with anyone else. When you finish using the website, online services or mobile

app you should log out if others may be able to access your computer or device. This is especially

important if you are using a publicly accessible computer.

Be aware of and protect yourself against Internet fraud and "phishing".

There is an Internet fraud practice known as "phishing" which is the illegal gathering of personal

information by deception. Unsolicited emails are sent to individuals from lists illegally gathered by a

third party, and recipients are asked to enter or reconfirm bank or password details into a "cloned” or

website.

We will only ask you for your bank or credit card details on a secure platform and will never ask you

for your password or PIN. Make sure you are dealing with tutling when you are asked for your bank or

credit card details for refund purposes and never share your password or PIN with anyone, including

us.

When do we collect Personal Information about you?

We collect personal information about you whenever you use our products and services (whether

these products or services are provided by us or by other companies or agents acting on our behalf),

including when you use our Website or mobile applications; interact with us through email or our

contact center.

We may also collect information about you from other companies within our group, or third parties,

if this is appropriate and allowed by law. These include fraud-prevention agencies, business

directories, credit reference agencies and business partners.

For additional details see "What types of personal information do we collect and retain?" below.

In addition, we may receive personal information about you from third parties, such as:

 Companies contracted by us to provide products or services to you.

 Companies that participate in our customer programmes.

 Companies who provide details to us under privacy polices providing for information to be

shared with tutling.

What types of Personal Information do we collect and retain?

When you use our products or services, you will need to provide us with your personal details.

We collect the following categories of personal information:

 Information you provide for tutling to complete and manage a booking you have made with

us or a service you have requested from us, such as your name, date of birth, home language,

address, account information and email address.

 Information about your bookings and trends.

 Information about the products or services we have provided to you in the past.

 Information about online registration and other interactions.

 Information about your use of our websites, contact center and mobile applications.

 Information about your device and your location if you have been browsing on our website,

for example your "Internet Protocol" or "IP" address (i.e. a numeric code that can act as a

unique identifier for your computer or other device, which can be turned off from your device)

or unique device ID.

 Your preferences for particular products or services when you tell us what they are - or when

we assume what they are, depending on how you use our products and services.

 Your contact with us - such as a note or recording of a call you make to one of our contact

centers, an email or letter you send to us or other records of any contact you have with us.

When and why do we collect "Special Personal Information"?

Certain categories of personal information, such as that about race, ethnicity, religion, health,

sexuality or biometric information are special categories of data requiring additional protection under

South African data protection law and are referred to here as "special personal information".

Generally, we try to limit the circumstances where we collect and process special personal

information.

Examples of where we may collect and process special personal information includes the following:

 Where you have requested specific services from us with specific requirements. (i.e.

requesting a tutoring session)

 Where you have otherwise chosen to provide such information to us or it has been passed

onto us by a third party, such as one of our Suppliers.

 Information relating to promotions that may be applicable.

In addition, you may have requested products or services which is not special personal information

data, but may imply or suggest your religion, health or other information.

What do we use your Personal Information for?

The main purposes for which we use your personal information are:

 To fulfil your requests and deliver the products or services you have asked for.

 To manage the list of products by analyzing market trends.

 To send relevant communications to you.

 To help us to meet certain legal and regulatory requirements which apply to Tutling.

 To provide products or services tailored to your requirements and to treat you in a more

personal way.

 To carry out analysis and market research.

 To, subject to applicable law, carry out marketing including targeted online advertising and

keep you informed of Tutling's products and services.

 To send you status updates and service communications

 To improve our websites, products and services.

 For management and administrative purposes.

 For internal business & operational purposes.

 To respond to any questions or concerns you may have about our products or services.

 To carry out research and statistical analysis including to monitor how customers use our

products or services.

 To prevent and detect fraud or other crimes, recover debts or trace those who owe us money.

 To provide aggregated reports to third parties (such reports do not contain any information

which may identify you as an individual).

 To provide loyalty type and usage reports to third parties

When will we send you Direct Marketing?

We will not use your personal information for electronic direct marketing purposes unless we are

permitted to do so by law. With your consent, we may sometimes send direct marketing

communications that include a business partners' products and services related to the bookings you

may place.

We will only allow third parties or other members affiliated to us to send direct marketing

communications to you when you have agreed to receive marketing from third parties.

We will respect your choice as to what communications you wish to receive and how these are sent.

How can you change what Direct Marketing Communications you receive, how you receive them

and unsubscribe?

If you decide you would no longer like to be sent direct marketing communications, you can

unsubscribe or opt out at any time. In each direct marketing communication, we send by email will

have an unsubscribe option at the bottom of each email, which will allow you to stop receiving further

direct marketing emails. You may also stop any further text messages by replying with the word

"STOP". We aim to action requests to stop being sent direct marketing communications as soon as

possible, but it is possible that you will receive some marketing in the period prior to that change being

made.

If you ask us to stop sending direct marketing communications, please note we will retain your

personal information for the purposes of indicating that you do not want to receive direct marketing

communications.

Please note that if you tell us that you do not wish to be sent further direct marketing communications,

you will still receive service communications (as described above) which are necessary, for example,

to confirm your booking or to provide you with an update on its status. If you have subscribed to any

of our loyalty programmes, or if you are a member of any of our brands, we will continue to keep you

informed about your membership and other important service information relating to that

programme or brand.

If you wish to change how we use your personal information, including exercising your right to be

forgotten or have your personal information destroyed or deleted, please see section:

"What are your legal rights in relation to the personal information we hold about you?" and "How can

you exercise your legal rights and change how we use your personal information?".

What is our Legal basis for using your Personal Information?

Tutling will only process your personal information where we have a legal basis to do so. The legal

basis will depend on the reason or reasons that Tutling has collected and needs to use your

information. Under South African data protection laws in almost all cases the legal basis will be:

 Because we need to use your personal information so that we can process a booking and

otherwise perform the contract we have with you.

 Because it is in Tutling 's legitimate interests to use your personal information to operate and

improve our business.

 Because Tutling needs to use your personal information to comply with a legal obligation.

 To protect the legitimate or vital interests of you or another person.

 Because you have consented to Tutling using your personal information for a particular

purpose.

How long do we keep Personal Information?

We will keep your information for as long as we need it for the purpose it is being processed for. For

example, where you place a booking with us, we will keep the information related to your booking, so

we can fulfil the booking you have placed. After that, we will keep the information for a period which

enables us to handle or respond to any complaints, queries or concerns relating to the booking. The

information may also be retained so that we can continue to improve your experience with us and to

ensure that you receive any loyalty rewards which are due to you.

We will actively review the information we hold and delete it securely, or in some cases anonymize it,

when there is no longer a legal, business or customer need for it to be retained. If you stop interacting

with us as a customer, we will remove or anonymize your information after 7 years.

Completion of a Contract with you:

It will be necessary for Tutling to use your personal information to complete a booking you have made

with us. For example, we will need to use information such as your contact details and payment

information, to provide you with the service that you have requested and paid for.

Legitimate Interests:

Tutling has a legitimate business interest to use the personal information we collect to offer an

effective service and carry out our business.

Compliance with Legal Obligations:

There are situations where Tutling is subject to a legal obligation and needs to use your personal

information to comply with those obligations, including cases where we are required to share your

personal information with regulators.

To Protect the Legitimate or Vital Interest of You or Another Person:

There are situations where we may need to use your personal information to protect the vital interests

of you or another person.

Consent:

We may collect and use your personal information where you have given your specific consent to us

doing so.

However, if you withdraw your full consent, in some circumstances, and subject to applicable law, we

may not be able to provide all or parts of the products or services you have requested from us and

you will not be able to cancel your booking or obtain a refund of any charges you have paid.

Who do we transfer to, disclose or share your Personal Information with?

Your personal information may be shared within our group with entities or brands Suppliers and all

legitimate business partners. We share information with them, so they can assist us in providing

products and services to you and to understand more about your requirements.

We may also disclose your personal information (subject to applicable law) to the following third

parties for the purpose described here:

 Service providers needed to deliver the products and services you have asked for.

 Credit and charge card companies, credit reference agencies and anti-fraud screening service

providers to process payments and (where necessary) to carry out fraud-screening.

 In response to a valid, legal request from government or a law enforcement agency, such as a

customs and immigration authority.

 Third party Suppliers we use to provide products and services that involve data processing,

for example, to carry out marketing initiatives or run customer surveys on our behalf.

 Third parties, such as law firms and law courts, to enforce or apply any contract with you.

 Third parties, such as the police and regulatory authorities, to protect our rights, property, or

the safety of our customers, staff and assets.

 We may provide usage information (but not your personal details) to other websites so that

they know that you have visited our websites.

 We may provide usage information including your personal details if we have your consent,

to marketing agencies to deliver online advertising on websites or social networks.

 Online or social media platforms, such as Google (AdWords, YouTube etc.), Instagram, Twitter

and Facebook, in order to facilitate target segmentation with online advertising. Should you

no longer wish to be targeted, you can opt out through the preference settings on the

respective platforms.

 If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where

that obligation arises because of a voluntary act or decision by us.

 If we are reorganized or sold to another organization, we may transfer any personal

information we hold about you to that organization.

Where appropriate, before disclosing personal information to a third party, we contractually require

the third party (such as Tutling’s suppliers and vendors) to take adequate precautions to protect that

data and to comply with applicable law.

What Countries will your Personal Information be sent to?

Your personal information may be sent to and stored by us and third parties in South Africa.

In the unlikely event where your personal information is transferred because we are using a service

provider in another country, we will implement safeguards so that your personal information

continues to be protected to the standards set out in this Privacy Policy.

If you would like more information on these safeguards, please contact the Data Protection Officer.

What are your Legal Rights in relation to the Personal Information we hold about you?

Under data protection laws in South Africa, you have certain rights in relation to your personal

information. Responses to exercise your rights will be provided within one month and generally there

is no fee for making these requests. If your request is particularly complicated we may extend the

deadline for responding to 3 months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you

wish to exercise, and the nature of the personal information involved, there may be legal reasons why

we cannot grant your request. Further explanation of those rights and the exceptions to them are set

out below.

Details of how to exercise your rights are set out in the section below "How can you exercise your legal

rights and change how we use your data?"

Your rights include the following:

 You may request us to stop sending you direct marketing. To see how to change your

permission to receive direct marketing please reach us on info@tutling.co.za If you do so, we

will no longer be able to send you direct marketing communications. However, if you

subsequently order with us, we will need to send you communications about the products or

services you have booked. These communications will help you get the most from the

products and services we provide and may also contain options and other details about the

products or services you will be using.

 You may request us to stop using your personal information where we are doing so under

legitimate interests (see the section "What is our legal basis for using your personal

information" for examples of when that applies) unless it is needed for dealing with legal

claims or we have other compelling legitimate reasons that override your rights.

 Also see "Who do we transfer, disclose or share your information with" in respect of online or

social media platform settings.

 You may access the personal information we hold on you. There are some limited exceptions

to this right, such as information relating to others who have not consented to the disclosure

of their information and information which is legally privileged. Please see "Accessing your

personal information" which can be located within "How can you exercise your legal rights

and change how we use your data?" for more details.

 You may ask us to correct your personal information (the "right of rectification") if that

information is inaccurate.

 You may ask for personal information which identifies you to be erased (or forgotten). To do

this we will remove the information that identifies you from the data we hold in our active

systems ("anonymize"). However, a separate and restricted copy of the identifying

information will (subject to applicable law) be kept for 7 years to meet the obligations we have

to law enforcement, national authorities and legal proceedings.

Considerations when you submit a request to have your personal information erased:

o We may need to retain certain elements that relate to a contract between you and

Tutling because we need it for our own legal and auditing purposes (for more

information on the basis on which we process your personal information see the

section "What is our legal basis for using your personal information?").

o A record of your request including the personal information you supplied will be

retained in the application used to carry this out for 3 years.

o In some circumstances it may mean we will not be able to provide all or parts of the

products or services you have requested from us in relation to previous orders or

retain any preferences you have previously shared with us.

o We cannot erase your personal information if you are a member of one of our loyalty

programmes or brands, as we require this information to deliver our contract with

you. If you wish to proceed you will need to resign from such loyalty programme or

membership.

o We cannot erase your personal information if we have identified that you either have

an open complaint with us or we hold a previous case for you within the past 6 years.

We are required to retain this information in case there is a need to re-open the

complaint.

How can you Exercise your Legal Rights and Change how we use your Data?

If you wish to change how we use your personal information, please contact our Data Protection

Officer on info@tutling.co.za .

We will ask for some information to identify you, which will only be used to process your request. We

will verify your identity by email before processing your request.

Accessing your Personal Information:

If you wish to receive a copy of your information, you can make your request in writing to the Data

Protection Officer at info@tutling.co.za and (subject to such internal requirements by Tutling, prior to

divulging same), include the following information with your request:

 Your name and postal address.

 Details of your request.

 A photocopy of your passport, photo identification or driving license, so that we can verify

your identity.

 Your signature and the date of the request.

 If you are applying on behalf of another person then signed authority from the individual is

required.

Any details which may help us locate the information which is the subject of your request, for example:

 booking details.

If you wish the information to be provided to you in a machine-readable copy, please indicate that at

the time of making your request.

How will we inform you of Changes to this Privacy Policy?

If we change this Privacy Policy, we will let you know about the changes by publishing the updated

version on www.tutling.co.za and via email. We are committed to protecting and respecting your

privacy and will continue to do so in any future changes we make to this Privacy Policy.

This Privacy Policy came into effect on 1 July 2020. This Privacy Policy applies to all information we

process about you in connection with your relationship with us as a customer or potential customer.

How to get in touch with us and your Right to Complain:

If you have any questions or complaints about this Privacy Policy, or how we handle your personal

information, please contact the Data Protection Officer on info@tutling.co.za

We work hard to handle your information responsibly. We hope that we will be able to resolve any

concerns you may have, but in the unlikely event that we do not, you have the right to contact the

relevant data protection supervisory authority or regulator. For example, the Information Regulator

in South Africa, once operational, can be contacted at inforeg@justice.gov.za