Privacy Policy
This Privacy Policy ("Policy") describes how [OPERATOR DETAILS: fill in] ("ProTutors", "we", "us") collects, uses and protects personal data of users of the ProTutors marketplace.
1. Data controller
[OPERATOR NAME: fill in โ entity name, INN, OGRN, registered address]
Contact for personal data enquiries: [EMAIL: fill in]
2. What personal data we collect
2.1. Data provided by the user on registration and use
- Email address โ for identification, authentication, notifications.
- First and last name โ to personalise the account and profile.
- Phone number โ optional, for contacting the client or specialist.
- Bio and service description (specialists only) โ for the public profile.
- Reviews and ratings โ created publicly by users.
2.2. Technical data collected automatically
- IP address, browser type, operating system โ for security and availability.
- Cookies (see section 7) โ for authentication and analytics.
- Usage data (pages, clicks, timestamps) โ to improve the product.
2.3. Payment data
ProTutors does not store card data. Payment details are processed exclusively by a certified payment provider: [PROVIDER: fill in].
3. Purposes of processing
- Registration, authentication and account management.
- Marketplace functionality (search, orders, messaging, reviews).
- Sending transactional notifications (confirmations, reminders).
- Sending marketing messages โ with user consent.
- Platform security and fraud prevention.
- Compliance with legal obligations.
- Product improvement through aggregated analytics.
4. Legal bases
- Consent โ for marketing communications, public profile publication.
- Contract performance โ for core features (registration, orders, messenger).
- Legitimate interests โ for security, fraud prevention, product improvement.
- Legal obligation โ when responding to lawful requests from authorities.
5. Storage and security
Data is stored on servers located in accordance with applicable data residency requirements.
We apply the following security measures:
- password hashing (bcrypt or equivalent);
- HTTPS/TLS for all connections;
- least-privilege access control;
- regular security audits.
Retention period: while the account is active, plus [PERIOD: fill in] years after account deletion โ for compliance with legal obligations.
6. Sharing with third parties
We do not sell personal data to third parties. Data may be shared only in the following cases:
- Service providers (payment provider, cloud hosting, email service) โ to the extent necessary for them to perform their functions, under confidentiality obligations.
- Authorities โ pursuant to a lawful request.
- Business successor โ in the event of restructuring, merger or business sale, with notice to users.
7. Cookies and analytics
The Platform uses the following types of cookies:
- Essential โ for authentication (JWT session) and language settings. No consent required.
- Analytical โ for aggregated traffic statistics: [ANALYTICS TOOL: fill in]. Require consent (cookie banner).
You can manage cookies through your browser settings. Disabling essential cookies may impair authentication.
8. Your rights
You have the right to:
- Access your personal data.
- Rectify inaccurate data โ via profile settings or by request.
- Erase your personal data โ request via the "Settings" section or by writing to us. Deletion within [PERIOD: fill in] business days, except where retention is required by law.
- Restrict processing โ on reasonable request.
- Withdraw consent to marketing communications at any time (via the "Unsubscribe" link or by request).
- Lodge a complaint with the relevant supervisory authority.
To exercise your rights contact: [EMAIL: fill in].
9. Children
The Platform is not intended for persons under 18 years of age. Data of minors is processed only with written consent from a legal representative.
10. Policy changes
We may update this Policy. For changes that materially affect your rights we will notify you by email at least 10 days before they take effect.
11. Contact
Data controller:
[OPERATOR DETAILS: fill in]
Email: [DPO / SUPPORT EMAIL: fill in]