Privacy Policy
A-Introduction
a-Top Tutor Bay is
committed to protecting the privacy of its users and visitors.
b-This policy
applies to all the situations where our role is to perform as a data controller,
i.e., determining how the personal data
of the users and visitors of Top Tutor Bay will be processed.
c-Top Tutor Bay has set
certain privacy controls. According to them, the personal data of the users of
the website is processed. When a user
creates an account, he gets to choose
whether or not he directly wants to receive marketing emails. The privacy
controls are accessible at the time of creation of the account. If a user wants
to change them later at some point in time, he can do so by signing into his
profile.
d-The words ‘we,’ ‘our’ and ‘us’ are associated with Top Tutor Bay in this policy.
B-Cookies
a-Top Tutor Bay uses
cookies to store certain data about its users. By using our website, you agree
to our cookie policy which is mentioned
below.
C-How Top Tutor Bay makes use of your personal data
a-This section
covers the following points
- The type of user’s data that Top Tutor Bay process;
- The reasons as to why we
process this data; and
- The legal bases on which this
processing is performed.
b-The first form of data that we
may process comes under the category of ‘usage data'. It refers to the data about how you use our services or what
activities you perform on our website. It
may include your geographical location, IP address, browser version and type,
referral source, operating system, languages, page views, length of visits,
website navigation paths and also the pattern, timings and frequency of visits
and service use. This data is collected by using a local analytics tracking
system of the website and also Facebook analytics, Google, and Mixpanel. This
data is mainly processed to analyze how our service and website is being used. The legal basis to justify this
processing is the legitimate interests of our website, periodical monitoring to improve our services and website so that the
user can be provided with a better
experience.
c-The second form
of data falls under the category of ‘account data’. It includes your name, contact number, and email address. This
data is collected through your account.
This data is processed to operate our website, provide writing
services and to ensure the provision of security services and also securing our
website and its data by maintaining multiple backups of the databases. The
processing of this data is legally justified
through a contract that every user agrees upon while signing up to the website.
d-The third form
of data that we may process comes under the category of ‘Service data’. It refers to the data provided by the users
during the process of obtaining services from our website. This may include all the information you
provide while placing an order and also all the data that is contained in the documents or files that you
might upload. Thus, it is recommended, not to upload any files on our website
that may contain any kind of private or
confidential information. This type of data is processed
in order to operate our website, provide writing services and to ensure
the provision of security services and also securing our website and its data
by maintaining multiple backups of the databases. The processing of this data is legally justified through a contract that
every user agrees upon while signing up to the website.
e-The fourth form of data that we
process falls under the category of ‘publication data'. It refers to the data that any user might post for publication on Top Tutor Bay. This data is
processed to enable publication on our website and also to administer our
services or site. The data is processed
on the legal basis of consent.
f-The fifth form
of data that we may process comes under the category of ‘inquiry data’. It refers to data contained in the inquiries
submitted by the users. This data may be processed with the intention of
marketing, selling and offering relevant services to the users. The processing
of this data is legally justified through
a contract that every user agrees upon while signing up to the website.
g-The sixth form
of data that we might process comes under the category of ‘transaction data’. It refers to any data related to the
transactions that a user may provide while purchasing services or goods from
our website. It includes card details, contact details and all the transaction
details of the users. This data is processed
to supply the users with their purchased
services and goods and maintain a record of all the transactions. The
processing of this data is legally justified
through a contract that every user agrees upon while signing up to the website,
also, the legitimate interests of the website. However, we ensure that we do
not save any sensitive information related to the credit cards.
h-The seventh
form of data that we may process falls under the category of ‘notification data'. It refers to the data provided by the users
while subscribing to our newsletters or email notifications. This data is processed with
the intention of sending relevant notifications to the users. The
processing of this data is legally justified
through a contract that every user agrees upon while signing up to the website
and also by consent.
i-The eighth form of data that we
may process comes under the category of ‘correspondence data’. It refers to data contained in any form of
communication that a user might send to us. It includes the content of the
message as well as all the metadata related to the communication. This data is generated through the contact forms on the
website. This data is processed with the intention of communicating with our
users and also, record-keeping. This processing is justified on the legal basis
of the legitimate interests of our website, i.e.
to administrate our business and website and to communicate with the users.
j-For all the payments to follow
similar criteria, Top Tutor Bay ask its users to provide certain
documents to prove that they are
registered account holders. It is done for the prevention of fraudulent
transactions.
k-We store any information relevant
to the performance or the negotiation of the contracts in case, if a PayPal
claim, chargeback dispute or any other such legal dispute arises. This data is
archived, and its access is strictly controlled. This data is only used
to establish facts or support a legal dispute. This data may be provided to the legal counsel or the
financial institution in charge of inquiring the transaction only in case of a
dispute.
l-In addition to
all the purposes mentioned above, the
personal data of the users may also be processed
when it is necessary, for example, in the case of a legal obligation or to
protect the vital interests of a person or our website.
m-It is recommended, not to
supply us with any unnecessary personal data that we do not ask for.
D-Sharing your
personal to others
a-The personal data of our users
may be disclosed to any of our subsidiaries. The legal basis of this provision
is set out in our privacy policy.
b-Your personal data may be
disclosed to the professional advisors of our business or website and insurers
as well. This is necessary for obtaining
professional advice, managing risks, defense of legal disputes and for
maintaining or obtaining insurance coverage.
c-Your inquiry or service data
may also be disclosed to the
subcontractors or the suppliers of Top Tutor Bay. The legal basis of
this is a contract with our users that they agree upon while signing up to the
website.
d-As the
financial transactions on our website are
managed by the payment service providers like PayPal and others. Therefore,
it is necessary to share the transaction data of our users with them. However,
this does not include any sensitive information.
e-In addition to all of the reasons mentioned above for disclosure of the
personal data of our users, it may also be disclosed in case of a legal
obligation or to protect the vital interests of a person, also, for the defense
or the exercise of a legal dispute.
E-International
transmission of the personal data of our users
a-This section
covers the reasons as to why your personal
data may be transmitted to the countries
that lie outside of the European Economic Area (EEA).
b-If a user placed an order on our website and chose to
share his personal data with us outside
of the United States, this data will be provided
to the U.S. for necessary processing. The United States can have different
protection laws compared to the country of the user. The U.S. will protect your
personal data as mentioned in this
policy. By using our services, you agree to the consent of this transmission, i.e. storage and processing of your personal data in the United States. Data
transfers occur in the United States based on an ‘adequate decision' developed
by the European Commission. This decision is
based on the Privacy Shield Framework.
c-Your
personal data may also be disclosed with our Parent company, the affiliates or
the subsidiaries, basically for operational and business purposes. We may
share, transfer or sell all our assets or some parts of it that includes your personal data, in the result of an acquisition,
merger, and sale of assets or reorganization and also in the case of
bankruptcy. A notice will be published on
the website, or an email will be sent to individual users in the case of a
change in ownership of the business.
d-When a user places an order on
the website or submits an inquiry, his service and inquiry data is made
available to all our subcontractors. It is necessary to locate the expert
related to the task assigned by the client and ensure high performance. This is only the case with service and
inquiry data. Thus, it is recommended to the users, not to share any private
information while placing an order or submitting an inquiry.
e-If the personal data of the
user is not able to be processed within the European Economic Area; Top Tutor Bay will follow all the principles
of data protection; just select a country
listed on the countries of EU commission where possible. If the data of the
user are transferred to the USA, we will
make sure that reasonable endeavors take part in Privacy Shield Program.
f-The parts of the website that
are password protected, the user is responsible for them. Do not disclose your
password to anyone and keep it confidential.
g-The data that the user provides
to publish on our website will be available all around the globe through the
internet. We are not responsible for the prevention of its use and/or misuse by other people.
h-The transmission of data that
occurs through the internet may not be secure. We are not responsible for
guaranteeing its security during the transmission. However, we try to use the
most secure channels to ensure the protection of your personal information.
F-Retaining
and deleting the personal data of the users
a-Top Tutor Bay does not
retain the personal data of the users for any longer than it is required. We
will only keep it stored in our business for a time
period that is justified by law, or as long as we require it for a valid
reason or until the user ask us to delete it.
b-We may retain a certain limited
amount of your personal information. We ensure it will not be objectionable by
you or your claims of deleting your data. For instance, we keep track of the
requests made by the users to delete their data along with all the personal
information contained in it. It is
necessary for tax purposes and others.
G-Amendments
a-This policy may be updated after a certain period of time, and
the new version will be available on the website.
b-It is
recommended to check this policy from time to time to make sure if you agree
with any changes made to it.
c-An email or
private message will be sent to the users
regarding any changes in the policy.
H-Rights of
the users
a-This section summarizes the rights
that are provided to users under all the
data protection laws. However, some of them are quite complex, so we have not included all the details here.
It is recommended to consult a regulatory authority for the complete
explanation of the rights mentioned below:
- Right to access
- Right to rectification
- Right to deletion
- Right to restrict certain processing
- Right to question the processing
- Right to the portability of data
- A right of launching a complaint to some superior authority
- Right to a withdrawal of consent
b-The user is provided with the right to allow or forbid
the processing of his personal information. Also, when accessing his personal data; he has the right to any
additional information. It includes the
reasons for the processing, the type of personal data being processed and all the recipients included in that data. We
make sure that it does not affect the freedom and rights of others. The user is also provided with a copy of his personal
information. We do not charge for the first copy, but additional copies won’t be free of cost.
c-The user has
the right to ask for rectification in any part of his personal data of it is inaccurate or incomplete.
d-The user is provided with the right to ask for deletion
of his personal data and, in some cases,
we are bound to erase it without any further delay. These cases include the
situation when the personal data is no longer
required for the specific purpose that it was collected for when the user withdraw his consent from consent-based
processing and/or when a user object
certain kind of processing of his personal
data under data protection law. However, the user might not be provided with this right under certain
circumstances. These circumstances include situations when the processing is actually required; for the purpose of establishing, exercising rights of expression,
freedom of information, and to exercise or
defense, some legal claims as well as to
comply with legal obligations.
e-Some situations provide the user
with the right to limit the processing of his personal
data. These situations include; the user doubts
the accuracy of his personal information, he finds certain processing illegal,
but does not support erasure; we do not require certain data for processing
anymore, but the user may require it for the purpose of establishing or to
exercise or defense some legal claims; the user may have objected the
processing, but its verification is pending. However, we continue to
store more of the personal data of the user, when the processing has been restricted under such circumstances. But
we still keep the right to process this information if certain situations
arise; with the consent of the user, for the
purpose of establishing, to exercise or defense some legal claims, or to
protect the right of another person or for some important public interests.
f-The user has
the right to object to the processing of his personal
data on the grounds of some legal basis. We will end the processing unless some
legal interests of our business override your legitimate interests.
g-The user can
object to the processing when his personal
data is being used for direct marketing.
We will bring an end to the processing on such an objection.
h- The user
can object to the processing when his personal
data is being used for historical,
statistical or scientific purposes. We will bring an end to the processing
unless it is necessary for some public interests.
i-The legal basis
of processing the personal data of the users are
- Either consent
- Or the situations in which the processing is required to complete a
contract of which a user is a part of, or for completing the initial steps to
enter into a contract on the request of a user. This processing is automated. The
user has the right to his personal information unless it affects the freedom or
rights of others.
j-The user can lodge a complaint against us to a superior
authority if he believes that the processing of his personal data does not comply with the data protection laws.
k-In the situations, when the
personal data of the user is being processed
on the grounds of consent; he may withdraw this consent at any point in time.
However, this withdrawal will not apply to the process done before the withdrawal