PRIVACY NOTICE

Intelligent Learning Tutoring – www.intelligentlearningtutoring.com

Last updated: July 2026

This Privacy Notice explains how Intelligent Learning Tutoring (“we”, “us”, “our”) collects, uses, shares, and protects personal data when you use our website at www.intelligentlearningtutoring.com and our tutoring services (the “Services”). It applies to prospective clients (parents/guardians and students) who submit our Intake Call form or Get Started form, to prospective tutors who submit our Become a Tutor form, and to other visitors to our website.

We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG).

1. Who we are

Data controller: Intelligent Learning Tutoring (“Intelligent Learning”), registered with the Dutch Chamber of Commerce (KvK) under number 85724041, Amsterdam, the Netherlands.

Contact: intelligentlearning.nl@gmail.com, +31 (0)6 4292 9733.

Data Protection Officer: We have not appointed a DPO, as we are not required to under Article 37 GDPR. Privacy queries can be sent to the contact details above.

2. What personal data we collect

We collect personal data through three forms on our website, plus general website usage data from all visitors.

2.1 Intake Call Form (prospective clients)

This form is used to request a free intake call. It opens by asking whether a parent/guardian or a student is signing up, and collects:

Full name
Phone number (with country code)
Date of birth
The reason for your call – a free-text field which may include information about the student, such as the subjects, IB/MYP level, or academic needs they want support with
Your availability for an intake call
Optionally, your consent to subscribe to email updates and exclusive subscriber content

Like the Get Started form (Section 2.2), this form captures who is completing it and the date of birth of the person signing up, which gives us the information needed to apply the age-based consent rules in Section 4 automatically.

2.2 Get Started form (prospective clients – full sign-up)

This form collects the most detailed information from prospective clients and is used once a family decides to proceed with tutoring. It opens by asking whether a parent or a student is signing up, and collects:

Student's full name, email, and phone number
Parent/guardian 1 (and parent/guardian 2) full name, email, and phone number
Full postal address: street address, postal/zip code, city, and country
Subject(s) requested and level of education/grade (e.g. MYP3 or DP2)
Student's date of birth
Preferred type of tutoring: online, in person, hybrid, or flexible
Additional information or requests – a free-text field which may include special educational needs or accessibility information
How the enquirer heard about us

Because this form asks upfront whether a parent or a student is signing up, and separately requires the student's date of birth, it gives us the information needed to apply the age-based consent rules in Section 4 automatically, rather than relying on staff judgement during a call. Because it also collects a parent/guardian's own email and phone number regardless of who completes the form, we can use these details to obtain and record verifiable parental consent when a student signs up directly.

2.3 Become a Tutor form (prospective tutors)

This form is used by prospective tutors to apply to join our team. It collects:

First and last name
Date of birth
Email address and phone number
Zip code, city, and time zone
Prior tutoring experience
Academic qualifications: IB grades or, if applicable, university GPA, for the subjects the applicant wishes to tutor

Tutor applicants are expected to be current or former university students and are therefore treated as adults; the date of birth collected is used to confirm eligibility. If a tutor is later engaged, we separately collect bank details to pay tutoring compensation, and, where relevant to working with minors, background-check information.

2.4 Website usage data (all visitors)

IP address, browser type, and device details
Pages visited and how you interact with our website
Cookies and similar technologies set by our website platform, Wix.com (see Section 9)

3. How we use your data and our legal basis

We only process personal data where we have a valid legal basis under Article 6 GDPR (and Article 9 for any special category data, such as special educational needs information mentioned in an enquiry).

To respond to Intake Call Form submissions and arrange an intake call – pre-contractual steps taken at your request (Art. 6(1)(b))
To process Get Started sign-ups and match a prospective student with a suitable tutor – pre-contractual steps and performance of a contract (Art. 6(1)(b))
To deliver tutoring services, including scheduling by student location, subject, and level – performance of a contract (Art. 6(1)(b))
To assess Become a Tutor applications and, where relevant, engage a tutor – pre-contractual steps taken at the applicant's request (Art. 6(1)(b))
To carry out safeguarding or background checks on engaged tutors – legal obligation and/or legitimate interests in protecting minors (Art. 6(1)(c)/(f))
To invoice clients and pay tutors, and to comply with Dutch accounting/tax obligations – legal obligation (Art. 6(1)(c))
To record special educational needs or accessibility information, where volunteered in an enquiry – explicit consent (Art. 9(2)(a)), as this may be special category data
To send email updates to subscribers who opt in via the Intake Call Form – consent (Art. 6(1)(a)), which you may withdraw at any time
To understand how prospective clients hear about us and improve our website – legitimate interests (Art. 6(1)(f))
To respond to enquiries, complaints, or legal claims – legitimate interests and/or legal obligation

4. Children's data

Many of our students are minors, so we apply additional care to student information submitted through our forms. Both the Get Started form and the Intake Call form now ask upfront whether a parent/guardian or a student is signing up, and both require the student's date of birth. This gives us the information needed to apply the age-based consent rules below automatically, rather than relying on staff judgement during a call.

Parent-completed form: where a parent or guardian signs up, they provide the student's information directly and are responsible for ensuring they have authority to do so.
Student-completed form, Get Started: where a student below the age of digital consent in their country of residence (16 in the Netherlands, or as low as 13 in some other EU member states) signs up themselves, we use the parent/guardian contact details also collected on this form to obtain verifiable parental consent – for example, confirmation by email or phone – before arranging any tutoring session. Students at or above the relevant age of digital consent may consent directly.
Student-completed form, Intake Call: the Intake Call Form identifies that the enquirer is a student and their date of birth, but does not separately collect a parent/guardian's contact details on the same form. Where a student below the age of digital consent submits this form, staff obtain a parent/guardian's contact details and verifiable consent during the follow-up call, before arranging any tutoring session.
We do not knowingly process personal data submitted directly by a child below the applicable age of digital consent without verified parental consent, and we will delete any such data if we discover it was collected in error.

5. Who we share your data with

We do not sell personal data. We share personal data only with the following categories of recipients, where necessary:

Tutors, to the extent needed to deliver a booked session (e.g. student name, phone number, subjects, level, and relevant learning needs); tutors contact families directly using their own personal WhatsApp account (see Section 10)
Wix.com Ltd, our website and forms hosting provider, which processes form submissions and website usage data on our behalf
Google LLC, as our email provider (Gmail), through which form submissions, enquiries, and correspondence are received and stored
WhatsApp (Meta), which we use on our business WhatsApp account to arrange logistics and contracts with clients and tutors following a Get Started or Intake Call submission
Professional advisers (e.g. accountant) for invoicing and Dutch tax/accounting compliance
Regulators, law enforcement, or other parties where required by law, or to protect the safety of a minor

All third-party processors are bound by data processing agreements requiring them to protect personal data in line with the GDPR.

6. International data transfers

Wix.com Ltd is based in Israel, which benefits from an EU adequacy decision, meaning the European Commission considers it to offer an equivalent level of data protection to the EU. Google LLC and Meta Platforms, Inc. (WhatsApp) are based in the United States; where form, email, or messaging data is processed there, we rely on the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses as a transfer safeguard. You can request further details of these safeguards by contacting us.

7. How long we keep your data

Intake Call Form and Get Started form data where no tutoring relationship results: 12 months, after which it is deleted unless you have opted in to email updates
Client and student data: kept as long as the client tutors with us, and deleted 7 years after the end of the service contract, to comply with our record-keeping obligations under Dutch tax law (Article 52 AWR)
Become a Tutor applications where no role results: kept in our database for 3 years in case future positions arise, unless you ask us to delete it sooner
Engaged tutor records, including background-check, safeguarding, and payment information: kept as long as the tutor works with us, and deleted 7 years after the end of their engagement, to comply with our record-keeping obligations under Dutch tax law (Article 52 AWR)
Email subscriber data: until consent is withdrawn
Website usage/analytics data: for 14 months, typically in an aggregated or anonymized form thereafter

These periods are reviewed periodically and may be shortened where a shorter period is sufficient for the purpose.

8. Your rights

Under the GDPR, you have the right to:

Access the personal data we hold about you (Art. 15)
Request correction of inaccurate data (Art. 16)
Request erasure of your data in certain circumstances (Art. 17)
Request restriction of processing in certain circumstances (Art. 18)
Object to processing based on legitimate interests or for direct marketing (Art. 21)
Request data portability, where processing is based on consent or contract and carried out by automated means (Art. 20)
Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal
Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), or with the supervisory authority in your own EU country of residence

A parent or guardian may exercise these rights on behalf of their child. To exercise any of these rights, contact us at intelligentlearning.nl@gmail.com. We may need to verify your identity before responding, and we will respond within one month as required by Article 12 GDPR.

9. Cookies and similar technologies

Our website is built on the Wix platform, which sets cookies needed for the site and forms to function correctly (e.g. loading pages, submitting the Intake Call Form, Get Started form, and Become a Tutor form, and basic security). Depending on how the site is configured, Wix or embedded tools may also set analytics or marketing cookies.

Strictly necessary cookies – required for the website and forms to function; set regardless of consent
Analytics cookies – help us understand site usage (e.g. via Wix Analytics or Google Analytics); only set if you consent via the cookie banner
Marketing cookies – used to deliver relevant advertising, where applicable (e.g. via Meta/Instagram or Facebook integrations); only set if you consent via the cookie banner

We use the Usercentrics cookie consent banner, provided through Wix, to obtain your consent before any non-essential cookies are set. On your first visit, you can accept or reject analytics and marketing cookies, and change your choice at any time using the cookie preferences link on our site. Strictly necessary cookies are set regardless, as they are required for the website and forms to function and do not require consent.

10. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or misuse, including relying on our hosting provider's security measures, restricting access to enquiry and application data to tutors who need it, and tutors’ awareness of data protection and safeguarding obligations. No system is completely secure.

We use a dedicated business WhatsApp account to arrange logistics, contracts, and scheduling with clients and tutors, which we control directly. Separately, individual tutors contact families using their own personal WhatsApp accounts to arrange or discuss sessions. This means some student and parent contact details (e.g. phone numbers, session-related messages) are stored on tutors' personal devices and personal WhatsApp accounts, outside our direct control. Tutors are expected to handle any personal data received this way in line with our confidentiality expectations and to delete it if they stop tutoring for us.

11. Changes to this notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. We will post the updated version on this page with a revised “Last updated” date, and where changes are significant, we will notify you directly.

12. Contact us and complaints

If you have questions about this notice or how we handle personal data, contact us at intelligentlearning.nl@gmail.com or +31 (0)6 4292 9733.

If you are not satisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), autoriteitpersoonsgegevens.nl, or with the supervisory authority in your own EU country of residence.