Privacy Notice

Last updated 18 September 2026

This policy explains how Aoden Learning collects, uses, shares and
protects personal information when you enquire about tuition, attend a
free trial, receive lessons, apply to tutor or use our website. It also
explains your choices and your data protection rights.

1 Who we are and how
to contact us

For the purposes of this Privacy Policy, “Aoden Learning”, “we”, “us”
and “our” refer to Aoden Learning trading under i-Creatives Ltd.
i-Creatives Ltd is the data controller responsible for deciding how and
why personal information is used for Aoden Learning’s services.

For privacy questions, concerns or requests, contact Ishan Shah at info@aodenlearning.uk You
do not need to use a particular form or subject line to exercise your
rights.

2 Information we
collect

We collect information relevant to your relationship with us. This
can include:

• Enquiry and contact information: names, email addresses,
  telephone numbers, parent or carer details, and the information you
  provide when asking about tuition.

• Learner information: age or date of birth where needed, year
  group, subjects, examination board, learning goals, relevant attainment,
  work submitted, attendance and tutor progress reports.

• Support and safety information: relevant learning needs,
  accessibility requirements, health information, emergency contacts and
  location information needed to respond to an emergency.

• Service records: bookings, cancellations, account details,
  messages, support requests, complaints and feedback.

• Financial records: billing details, invoices, payment and refund
  records, and tutor bank details needed to make payments. Payment
  providers also process the payment details submitted through their
  services.

• Tutor information: contact details, experience, qualifications,
  references, identity and suitability information, and relevant
  background-check information.

• Technical information: information generated when accessing our
  website or online services, such as IP address, browser or device
  information, access times and error or security logs, where collected by
  the services used.

We obtain information from you, parents or carers, learners and
tutors. Where relevant, we also receive it from referees,
background-check services, payment and technical service providers, or
authorities dealing with a safeguarding concern. We explain any
additional collection when it occurs.

Please provide only relevant information. Contact us before sending
detailed medical reports, identity documents or other particularly
sensitive material so we can arrange an appropriate way to receive
it.

3 Why we
use information and our lawful bases

We use personal information under UK data protection law for the
following purposes:

• Enquiries, bookings and tuition administration: to take steps
  towards or perform our contract with the parent, adult learner or tutor
  concerned. This includes arranging free trials, lessons, payments and
  service communications.

• Children’s tuition and progress: our legitimate interests in
  providing the tuition requested by their parent or carer, supporting
  learning and communicating progress. A contract with a parent does not
  by itself provide a contractual lawful basis for using the child’s
  information. We consider the child’s interests and rights when deciding
  what information is necessary.

• Service management and security: our legitimate interests in
  responding to complaints, maintaining reliable services, preventing
  misuse and protecting accounts and information.

• Safeguarding and suitability: our legitimate interests in
  protecting learners and assessing tutor suitability, or a legal
  obligation where a specific duty applies. In an emergency, vital
  interests may apply where processing is necessary to protect someone’s
  life.

• Financial and legal administration: compliance with applicable
  accounting, tax and other legal duties, and our legitimate interests in
  establishing, exercising or defending legal claims.

• Optional publicity and marketing: consent for optional
  promotional messages, photographs, identifiable testimonials or other
  optional uses for which we request permission.

Where we rely on legitimate interests, we assess necessity and the
effect on the people concerned, giving particular weight to children’s
rights. Where we rely on consent, it must be a genuine choice and can be
withdrawn without affecting the lawfulness of earlier use.

We will explain when information is necessary to provide a service or
meet a legal requirement. Without essential contact, booking or safety
information, we may be unable to arrange or continue tuition safely.

4 Sensitive
information and background checks

Health, disability and some learning-support information require
additional protection. For optional support information, we seek
explicit consent from the learner or someone able to consent on their
behalf, as appropriate to the learner’s understanding and circumstances.
Withdrawing consent may limit the support we can offer; we will discuss
available alternatives.

For sensitive safeguarding information, we may instead rely on the
substantial public interest condition for safeguarding children and
individuals at risk, where its requirements are met. This can allow
necessary processing without consent where consent cannot reasonably be
obtained or seeking it would prejudice protection. In a life-threatening
emergency, the vital interests condition may apply where the person
cannot physically or legally consent. We must identify and document the
applicable additional condition and safeguards.

Criminal-record information, including relevant DBS information, is
subject to separate legal restrictions. We process it only where
authorised by UK law and with an applicable condition, such as
safeguarding children where its requirements are met. Access is
restricted to authorised people assessing suitability or handling the
relevant concern. We avoid retaining full certificates where a limited
verification record is sufficient.

5 Lessons and
communications

We use a secure messaging and management service for tuition
administration, approved communications and online meetings. Company
email may also be used for enquiries, support and authorised
communications.

Live lessons involve transmitting participants’ voices, video and any
shared lesson content through the meeting service. Aoden Learning does
not record lessons or use stored lesson transcripts or AI meeting notes.
Written attendance records, lesson reports and relevant messages are
separate service records and may be retained. Agreed live captions may
support accessibility without being stored.

Authorised Aoden Learning personnel may access relevant
communications to administer tuition, resolve complaints or respond to
safeguarding concerns. This does not mean messages are continuously
monitored or that every platform interaction is automatically captured.
Routine communications involving children are subject to the parent or
carer and Aoden oversight arrangements described in our Safeguarding
Policy.

6 Safeguarding
information

We may record concerns, disclosures, relevant communications,
decisions and referrals when necessary to protect a learner.
Safeguarding records must be kept separately from routine tuition
records, with access limited to authorised people who need the
information.

We may share necessary and proportionate information with children’s
services, police, relevant safeguarding authorities or other appropriate
professionals. Consent is not always required. We may withhold
notification where informing someone could increase risk or interfere
with an investigation, where the law permits.

Our Safeguarding Policy explains how to report concerns and how Aoden
Learning responds. This privacy policy explains the associated use of
personal information; it does not replace those procedures.

7 Who receives
information

We share information only where relevant to the purpose
concerned:

• Assigned tutors receive the learner and booking information
  needed to provide tuition and relevant support. They must use it only
  for authorised purposes and keep it confidential.

• Parents or carers receive appropriate booking information,
  attendance updates and progress reports about their child. They are not
  automatically entitled to every record or disclosure. We consider the
  child’s rights, understanding and safety. An adult learner’s information
  is not routinely shared with a parent without authority.

• Service providers process information needed for our messaging
  and management service, online meetings, website hosting, company email,
  payments, accounting and storage. Providers acting on our behalf must
  have appropriate data protection terms and access limited to their role.
  Some providers, such as banks, may also act as independent controllers
  for their own legal purposes.

• Professional advisers, insurers, regulators and authorities may
  receive relevant information where necessary for advice, a claim, a
  legal obligation or a safeguarding response.

We do not sell personal information. Any optional public use of a
learner’s name, image or identifiable testimonial requires separate
permission; agreeing to tuition is not permission for publicity.

8 Where information is
processed

Aoden Learning is based in the UK. Our policy is not to knowingly
transfer personal information outside the UK, and our intended
arrangement is for information to be stored and accessed within the
UK.

This intention also applies when choosing our software, hosting,
email and payment services. UK-based tuition does not itself establish
where these providers store information or allow support access. We must
verify their processing arrangements before giving an assurance that all
information remains in the UK.

If a provider’s arrangements involve processing outside the UK, we
will assess them before using that provider for personal information.
Any proposed change to our UK-only approach requires the applicable data
protection safeguards and an update to this privacy policy before the
transfer begins. Contact info@aodenlearning.uk for information about the
processing locations and safeguards that apply to your information.

9 Keeping information
secure

Access to personal information must be limited to those who need it
for their work. Tutors and other authorised personnel must protect
accounts, keep lesson links private, use approved communication channels
and avoid unnecessary copies or downloads.

We require appropriate organisational and technical safeguards for
the information being handled. No online service can guarantee absolute
security. If a personal data breach occurs, we will assess it, take
appropriate action and notify the regulator and affected people where
legally required.

Report a suspected privacy or security incident to
info@aodenlearning.uk promptly. Please do not include unnecessary
sensitive information in the initial message.

10 How long information is
kept

Retention depends on the record’s purpose and the circumstances. We
do not apply a single period to every record:

• Enquiries are kept while responding and for a proportionate
  follow-up period, taking account of whether tuition proceeds or a
  complaint remains unresolved.

• Learner, booking and progress records are kept during tuition and
  afterwards only where needed for outstanding administration, continuity
  of learning, complaints or relevant legal claims.

• Invoices, payments and accounting records are kept for the period
  required by applicable tax and accounting rules.

• Tutor applications and suitability records are retained according
  to the recruitment outcome, the duration of the relationship, relevant
  complaints and legal requirements. Detailed criminal-record material
  requires a separate, shorter assessment of necessity.

• Safeguarding records are assessed separately, taking account of
  the learner’s age, continuing risk, referrals, authority guidance and
  relevant legal requirements. Closing an account does not automatically
  delete these records.

• Technical logs are retained according to their security or
  troubleshooting purpose. Consent and marketing-suppression records are
  kept as needed to demonstrate and respect your choices.

Records must be reviewed and securely deleted or anonymised when no
longer needed. A relevant investigation, unresolved rights request or
legal hold may require longer retention. You can ask us about the
retention period or criteria applying to a particular record.

11 Marketing and
cookies

Booking tuition does not automatically enroll you in marketing. Where
we send optional promotional messages on the basis of consent, you can
withdraw it through the unsubscribe option or by contacting us.
Essential booking, billing and service messages are separate from
marketing.

Cookies and similar technologies can support functions such as
sign-in and remembering preferences. Where consent is required, it must
be obtained before the technology is used. Visiting the website or
accepting tuition terms does not itself constitute cookie consent.

Information about any cookies used, their purposes, providers and
duration must be available when they are used. You can also manage
cookies through your browser; blocking some cookies may affect requested
functions. This policy does not authorise undisclosed advertising or
tracking technologies.

12 Your rights and
complaints

Depending on the circumstances, you can ask to access your
information, correct inaccuracies, delete information, restrict its use
or receive certain information in a portable format. You can object to
processing based on legitimate interests and object at any time to
direct marketing. You can withdraw consent where processing relies on
it. Rights are subject to applicable legal conditions and
exemptions.

Contact info@aodenlearning.uk We may need proportionate information
to confirm identity or authority to act for someone else. Requests are
normally free and answered within one month, subject to any lawful
extension or adjustment; we will explain any applicable delay or
refusal.

Children have their own information rights. A parent’s request on a
child’s behalf is assessed with regard to the child’s understanding,
authority to act and best interests. Learners can contact us directly
and ask for an explanation in language they understand.

You may complain to us about how your information is handled. You
also have the right to complain to the Information Commissioner’s Office
at https://ico.org.uk/make-a-complaint/
or on 0303 123 1113.

If we introduce automated decision-making that has legal or similarly
significant effects, we will first provide the required information
about how it works, its consequences and applicable safeguards and
rights.

13 Changes to this
policy

We will update this policy when our services or information-handling
arrangements change and make the current version available. Where a
change materially affects how we use your information, we will provide
an appropriate notice before the new use begins and obtain fresh consent
where required.

Last Updated: September 2026