Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how Torus Academy works, look through the list of tutors, read the Torus Academy Blog, review the variety of services etc.). However, whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on
the Website. You can always opt out from cookies except from those, without which the Website cannot work.
When you are a registered User Torus Academy may collect from you and process Cookie identifiers and those data you specifically provide us with upon registration, including first name, last name, email, phone number, Skype ID or social network ID (if assigned through Facebook or Google+ or if accessing Google Calendar), time zone, interface language, IP address, and device type, as well, whereas in case of Telegram subscription, your Telegram ID may also be processed by Torus Academy.
Specifically, if you are a tutor, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip-code, gender, year of birth, city of living, and education experience.
Registered Users may additionally provide us with added profile pictures as well as chosen currency to perform actions pursuant to our Refund and Payment Policy.
Any questions regarding this Policy and our services should be sent to email@example.com
What Is Personal Data and the Processing of Personal Data? Main Definitions
Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual.
Processing of the personal data means any operation with your personal data, whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of Torus Academy.
Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Torus Academy's Lawful Bases for Processing
Torus Academy processes your personal data only when we have lawful bases. Specifically, Torus Academy processes your personal data if:
processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, your participation in our events and webinars, and placement of different types of cookies is based on your consent;
processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of Torus Academy;
processing is necessary for the purposes of our legitimate interests. Those legitimate interests are:
compliance with the U.S. financial and accounting legislation;
the assessment of Torus Academy's business efficiency by analyzing website traffic and financial performance indicators;
promotion of Torus Academy through social media networks, media outlets, and affiliates, such as bloggers or influencers;
performance of the contracts with enterprise clients and provision of reports on their employees’ performance.
user session control and fraud prevention, ensuring the appropriate protection of personal data;
tutor verification and development of high-quality learning programs with tutors.
where necessary, compliance with applicable legislation (e.g., data subject request processing);
in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you about the applied legal basis for processing and other relevant details, before we start processing of your personal data on the specific legal basis, unless we are not able to do so in accordance with our obligations under any applicable legislation.
Torus Academy collects from you only the following information and only for the stated below purposes:
Torus Academy collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For the registration purposes, you submit your login credentials (username and passwords), first name, last name and email. You may edit your Account with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding a necessary tutor. At the same time you are not required to provide additional information, not specifically necessary for the registration, it is your choice.
Torus Academy collects and processes personal data submitted by you upon registration and further editing of your Profile. For the registration purposes, you submit your login credentials (username and passwords), first name, last name and email. You may edit your Profile with additional information at your sole discretion. Additional information may help you to get more from the Services, for instance, finding students. At the same time, you are not strictly required to provide additional information, not specifically necessary for the registration. Therefore, it is your choice whether to include additional data to your profile, or not, such as zip code, country, language skills, education and work experience.
Some personal data, such as users’ names, and location that is listed in your user profiles or derived from IP Addresses may be publicly visible to other users on the Services or to the web.
We may implement a feature that permits you to choose what information is made public by changing your privacy setting in “Edit My Profile” within the Service.
Torus Academy may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By so doing, you acknowledge that any information you share through the Services will be available to Torus Academy and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/tutors).
From our turn and unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.
When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive the information about your IP address, proxy server and operating system, the web browser or your mobile carrier and location based on phone settings.
Details of transactions you carry out through our Website (as ID, date and time of transaction).
When you wish to share your contact details for more information regarding Torus Academy Enterprise one-on-one online language training for international teams, as name, email, company name and phone number.
Unless you expressly agree, Torus Academy does not process your sensitive data.
Pages on Social Networks and Torus Academy Tutors Community on Facebook (for Tutors Only)
We maintain Torus Academy's official pages in social networks, such as Facebook or LinkedIn. When you make interactions with our social network pages, such as subscribe to the pages, leave comments or preferences (e.g., ‘like’ our posts), we can analyze these data for measuring our efficiency and conduct an analysis of our social media marketing in our legitimate interests.
We maintain a “Torus Academy Tutors Community” group on Facebook. To join the group, you shall provide your email address, with the one you are registered at Torus Academy, and answer the questions
of the Tutors Community rules. As this group is deployed on Facebook, we will process your Facebook profile information.
We may process your personal data you provided us voluntarily with for the purposes defined below. From our perspective, we process your personal data to personalize the use of Torus Academy to the fullest extent possible and to provide you with the high-quality Services under the Terms of Service.
Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) to find your account or profile, schedule, give and/or take lessons, and track your learning progress.
In order for you to use the Services you will need to provide payment (e.g. credit card details) and billing information through our partners – third party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.
For enterprise customers, we process personal data of their employees to create their accounts and connect with the most suitable tutors for further learning. Based on the data about lessons taken by such students, we provide the enterprise customer with statistical reports on their employees’ performance.
Please note, that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of our platform, connect you with other users, allow you to communicate with them and take/give lessons.
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated frame for checkouts from our partners- payment providers (Jazz cash, Easy paisa) and tutors get payment for each confirmed lesson securely through third-party payment providers (Jazz cash, Easy paisa). Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by Jazz and Easy paisa service. We do not store your payment information on our servers.
We may also contact you via email and other ways, including through publicly available notices, for the Services-related purposes (welcoming letter, security and legal notices, announcements, Torus Academy updates, reminders, suggestions etc.). We could also use your data to enable you to communicate with other users through Torus Academy.
We may contact you by email and other ways, including through publicly available notices, for service related purposes (welcome letter, security and legal notices, announcements, updates, reminders, suggestions etc.). We may also use your data to enable you to communicate with other users through Torus Academy, including exchanging messages, conducting video calls, and/or leaving feedback about other users.
Your contact data (including email, phone number, Skype name, Teams ID etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:
-Feature development and product updates;
-Marketing activities, including publishing them on Torus Academy on other information resources;
-Customer Support updates;
-Other service updates for improving your experience.
Your feedback will not be video recorded, audio recorded, or webcast by the Interviewer without obtaining consent from you first. The same applies to your voice and/or image recording.
Having received the communications from us, you are always able to opt-out to such communications in each message, excluding legal notices, or change of user settings on Torus Academy.
We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry, we will request your consent first, and you may always opt-out from our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on Torus Academy.
To promote Torus Academy platform through blog and influencer channels, we allow individuals to participate in the affiliate program on our Website. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of our platform.
Also, please pay attention that we may use the information provided by you as feedback. The latter, under Section 12 of the Terms of Service, may be used by Torus Academy without any additional compensation to you.
In order to find the points of interest in our Services and for the purposes of analytics, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification. For these purposes, we use Google Analytics for Firebase, Hotjar Heat Maps & Recordings, Amplitude Analytics, Branch.io, Braze, and Intercom, the use of which ensures compliance with our privacy commitments.
We may also carry out polls and surveys through Torus Academy using external GDPR-compliant services. You are not obliged to respond to them and you may opt-out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on
your past use of our Services, we may process your Usage Data and Cookies. Please, follow our Cookies Policy for additional information.
To ensure a high quality of lessons given by tutors on Torus Academy, we collect and process tutor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the tutors and use their information to help them develop the learning programs.
We process data of Torus Academy Tutors Community participants to manage our Facebook group and provide tutors with an ability to come together and share their best practices, get official up-to- date information, and interact with each other and with Torus Academy based on our legitimate interest in community building. We also use the collected information to supervise tutors’ participation and behavior within the group.
In case of any disputes on Torus Academy and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the platform, and respond to any complaints or requests.
We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events or webinars, as well as to send you registration confirmation, reminders, associated useful materials or the information you have requested about our Services.
From time to time, we conduct learning-focused competitions for individuals that meet certain criteria. Participants are required to fill in the registration forms to register for the competition and prove they are eligible. We process this information exclusively to organize and conduct the competition, determine the winner(s), and contact them regarding the results and prizes.
We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.
Certain information, such as your log information, payment information and your behavior on the platform are subject to our supervision to prevent fraudulent activities on the platform and assisting you in managing your user sessions.
If Torus Academy decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification on such changes will be sent to your email and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.
In case you do not want to provide us the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.
In order to provide high-quality services, Torus Academy hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under data processing agreement (DPA). For those reasons, some of your personal data can be passed to the persons mentioned. Torus Academy uses only secure places of storage, such as provided by AWS (Amazon, the USA) with servers located in Ireland and the United States, and other services and applications listed below.
As we mentioned above, we also use some services to collect, manage, analyze or otherwise process your data:
These are payment providers and services enabling your transfer and receipt of funds as payment for services provided via our Services.
We use this service to send emails and push notifications.
We use this service to enable meetings and webinars for registered participants.
We use social media platforms to maintain our public pages and communities, who are, in this case, joint controllers with Torus Academy. Please, be advised that Facebook is a joint controller for the processing of personal data of the “Torus Academy Tutors Community” group. In particular, Facebook and Torus Academy are joint controllers for the group insight data and statistics, and the general data of your Facebook profiles.
More information on Facebook joint controllership arrangement you may find under the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
To exercise your data subject rights in respect of the “Torus Academy ” Facebook Page, you may contact us regarding any questions related to your participation in “Torus Academy” and Facebook regarding all questions devoted to your Facebook profile.
These well-known service providers will help us to ensure that your data is secure within Torus Academy.
How Long Will the Personal Data Be Processed and Stored by Torus Academy?
Your personal data will be stored by Torus Academy no longer than is necessary for the purposes for which the personal data is processed.
Generally, Torus Academy retains your personal data as long as your account is active. In case your account expires or you decide to delete your account Torus Academy retains your personal data not longer than 90 days after the account is expired.
However, in case of conflict situations in progress Torus Academy may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data gets deleted.
In case your last activity on Torus Academy, as of the last payment date, was more than 180 (one hundred eighty) days ago, your account will be considered expired and gets deleted. Along with your account or profile all personal data processed by Torus Academy will be erased.
As you are entitled to delete your account or profile after such a request it will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your account or profile all your personal data will be removed as well within 90 days.
Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or from the newsletter by clicking the respective link contained in each of our emails.
If you have registered for any of our events or webinars using your account credentials, we will merge and store this information along with your account data. If you have used other contact details, we will delete them within 30 days after conducting the event or webinar.
After the expiration of the retention period, Torus Academy shall terminate the processing of your personal data, unless otherwise is set by the relevant legislation.
Your Rights as Data Subject Regarding Your Personal Data Torus Academy Processes
You can obtain the confirmation from Torus Academy as to whether personal data concerning you is being processed.
You can access your personal data processed by Torus Academy.
You can ask Torus Academy to have incomplete personal data requiring corrections completed.
You can request Torus Academy to erase personal data. In most cases Torus Academy will erase it unless otherwise required by legislation.
Right of Restriction of Processing
You can contest the accuracy of your personal data or in case Torus Academy is not interested in processing your personal data any longer, but you want Torus Academy to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.
Right to Data Portability
You can have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
Right to Object to Processing of Your Personal Data by Torus Academy
You can object to our processing of your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.
Right to Withdraw Consent at any Time by Contacting Us
After we at Torus Academy receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.
If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.
Please note that when the processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.
Torus Academy will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Torus Academy is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Torus Academy will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.
Torus Academy takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, Torus Academy uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.
The privacy of children is one of our concerns. Torus Academy Services are not intended for use by children under the age of 18 without the express permission of their parent or legal guardian. If you are under the age of 18 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to Torus Academy. We may process the personal data of children under the age of 18, provided that data has been consensually provided by parents/legal guardians for the express purpose of using Torus Academy Services.
If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risks.
Torus Academy does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.
In case you are a resident of California, the California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by Torus Academy, Inc. or its subsidiaries to a third party for the third party's direct marketing purposes. This right granted to California residents applies only to their activities within the State of California.
To make such a request, please send an email to firstname.lastname@example.org
Torus Academy considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, in order to:
comply with the law or legal process served on us;
investigate potential fraudulent activities; or
protect the rights, property, or safety of Torus Academy, its employees, its customers or the public.