ScholarPASS Privacy Policy

Consent:

Processing is based on the consent you have given. For example, our newsletters, collection and publication of user feedback and reviews, analysis of course participation, your attendance in events and webinars, the placement of optional cookies, or the announcement of scholarship winners may rely on your consent.

Contractual necessity:

Processing is required to provide our services under the Terms of Service (and any additional terms). This includes enabling personalized learning recommendations, scheduling tools, AI-powered study plans, tutor–student matching, and other features essential to delivering our platform services.

Explicit consent for sensitive data:

In cases such as tutor identity verification, fraud prevention, or biometric verification (e.g., ID checks, facial verification), ScholarPASS may process such data only with your explicit consent and through verified third-party providers.

Legitimate interests:

Processing is necessary for the legitimate interests of ScholarPASS, provided these are not overridden by your rights and freedoms. Legitimate interests include but are not limited to:

• Compliance with financial, accounting, and tax legislation;
• Assessing ScholarPASS’s platform performance through analytics of traffic and financial indicators;
• Promotion of ScholarPASS via social networks, affiliates, and media, including the use of tutor names, profile pictures, or other details for marketing purposes under our Terms of Service;
• Performance of contracts with institutes, organizations, or scholarship sponsors, including progress reports for enrolled students;
• User session monitoring, fraud prevention, and ensuring data security;
• Tutor verification and the development of high-quality learning and teaching programs;
• Training and improvement of AI-powered tools (e.g., for learning recommendations, auto-generated study content).

Legal obligations:

Processing may be required to comply with applicable laws, such as responding to data subject requests, financial regulations, or tax reporting.

Vital interests or public interest:

In exceptional cases, processing may occur to protect your vital interests or those of another natural person, or for the performance of a task carried out in the public interest or by an authority vested in us.

(1) Account for Students

ScholarPASS collects and processes personal data submitted by you upon registration and through later edits to your account. For registration, you submit your login credentials (username and password), first name, last name, and email. You may also update your account at any time with additional information, as well as sync your Google Calendar or ScholarPASS Calendar. Such additional information may help you find suitable time slots for lessons, schedule tutoring sessions, or maintain better visibility of your learning activities. At the same time, you are not required to provide additional information that is not necessary for registration; it is your choice.

(2) Account for Tutors

ScholarPASS collects and processes personal data submitted by you upon registration and further profile edits. For registration purposes, you provide login credentials (username and password), first name, last name, and email. We also require proof of your qualifications, such as diplomas, certificates, or other teaching credentials. You may further update your profile with additional details and sync your Google or ScholarPASS Calendars. Additional information, such as your location, teaching subjects, work experience, or language skills, can improve scheduling and visibility, but it is not strictly required.

Some personal data, such as names and locations listed in your user profiles or derived from IP addresses, may be publicly visible to other users or the web. ScholarPASS may also provide you with options to control what information is visible by adjusting your privacy settings in the “Edit My Profile” section of the Service.

(3) Subscription to the ScholarPASS Blog and Updates

You may decide to subscribe to the ScholarPASS Blog, newsletter, or product updates. For this, we require your email address.

(4) Posting of Information

We process personal data that you freely submit on the ScholarPASS Platform. This may include surveys, online forms, questions or comments in our Q&A sections, or feedback you provide to us.

ScholarPASS may also process information you post on or through the Platform (including messages, uploaded files, and other user-generated content). By doing so, you acknowledge that any information you share will be visible to ScholarPASS and, in some cases, to other users (students, tutors, or institutes). You also acknowledge that certain content may not be deletable if it is linked to lessons, courses, or sessions used by others.

Unless you opt out, we retain such information as necessary to resolve disputes, provide customer support, or troubleshoot problems as permitted by law. We also reserve the right to terminate accounts that misuse the Service or violate our Terms of Service.

(5) Service Use, Cookies, and Other Similar Technologies

When you use our Services, we monitor and analyze web traffic and track your behavior for service improvement and security. Please refer to our Cookie Policy for details on our use of cookies and similar technologies.

(6) Billing Information

We process the details of transactions carried out through the ScholarPASS Platform (such as transaction ID, date, and time of payment). Payment information is handled securely by third-party providers.

(7) ScholarPASS for Organizations and Institutions

We may collect your name, email, company or institute name, and phone number to provide information about ScholarPASS for Institutions (our business-to-business services), as defined in our Terms.

(8) Sensitive Data

Unless you expressly agree, ScholarPASS does not process your sensitive data.

(9) Pages on Social Networks

We maintain official ScholarPASS pages on social networks such as Facebook, TikTok, Instagram, and LinkedIn. When you interact with these pages (e.g., subscribe, like, comment), we may analyze this data to measure our outreach effectiveness and improve our marketing campaigns, based on our legitimate interests.

(10) Tutor Community (for Tutors Only)

We maintain a Tutor Community accessible via Single-Sign-On (SSO) through our website. For purposes described in this Policy, we may collect and process your interaction and usage data within the Tutor Community.

(11) Information Required for Submitting Tax Documentation

To comply with tax and accounting laws, we may be required to collect and process personal data for tax documentation purposes (e.g., Form 1099 or other equivalent forms). This may include your full name, citizenship, permanent address, mailing address, date of birth, taxpayer identification number, or foreign tax ID.

Where applicable, regulations such as the EU Directive 2021/514 (DAC7) may require us to collect, verify, and report information on tutors and sellers operating through the ScholarPASS Platform. This may include your name, primary address, date of birth, tax identification number (TIN), VAT number, and bank account identifiers.

(12) Information Required for Marketing and Promotion

We may collect a tutor’s postal address to promote tutoring services provided via the ScholarPASS Platform and connect you with prospective students in a specific geographical area.

(13) Analysis of Speech Activity

During lessons conducted on ScholarPASS, we may analyze microphone activity and measure sound volume to provide feedback on speaking participation. We do not record your voice, words, or lesson content for this purpose. If you are based in the EEA or Switzerland, you will have the option to disable this feature.

(14) Assessments and Exams

We may process personal data (e.g., name, email, and results) when conducting language or academic assessments, placement tests, or exam simulations through ScholarPASS. These assessments may occur before or after registration.

(15) Video Lessons, Calls, Events, and Webinars

We may process recordings (audio, video, likeness, interactions) during your use of ScholarPASS services, including group classes, private lessons, sales calls, events, or webinars. You will be notified in advance and asked for consent if recording is required.

(16) Information Processed by AI-Powered Tools

We integrate certain AI-powered tools to enhance your learning experience. For example, your text prompts, audio inputs, transcripts, or lesson recordings may be used to:

• generate personalized learning recommendations,
• prepare study plans,
• provide explanations, quizzes, and exercises,
• enrich vocabulary resources,
• enable chatbots for practice or inquiries, and
• train ScholarPASS AI systems responsibly.

(17) Tutor Verification (for Tutors Only)

For identity verification and fraud prevention, we may process your ID documents and facial biometrics via secure third-party verification providers.

(18) Information about B2B Leads’/Clients’ Representatives

We process personal data of business or institutional representatives (e.g., name, email, phone number, position, company name) for purposes including:

• Sales and marketing outreach, qualification, and follow-up,
• Offering tailored services to organizations,
• Fulfilling contractual obligations, such as delivering agreements, updates, and official communications.

(1) Provision of Services

Primarily, we process your personal data to authorize access to our services and to fulfill our obligations under the Terms of Service. Specifically, we use your personal data upon registration to:

• Help others (tutors, students, guardians, or institutes) find your account or profile,
• Schedule and attend lessons, courses, or activities,
• Track your learning progress, assessments, or achievements.

To use the services, you may need to provide payment (e.g., credit card details) and billing information, processed securely through our third-party payment providers. Please see our Refund and Payment Policy for more details.

We may also ask you to complete placement tests or academic assessments to establish your learning level.

For institutions and organizations using ScholarPASS for Institutions, we may process the personal data of their authorized users to create accounts, enable access, and provide reporting on learning progress, assessments, and other performance indicators.

Please note: without the information provided by you under our Terms of Service, we cannot provide the functionality of the ScholarPASS Platform, connect you with other users, or allow you to fully participate in our services.

(2) Payment Services

We use third-party payment providers to handle billing securely. This ensures that:

• Your payment data (e.g., card details) is processed via secure providers such as Stripe, PayPal, or other authorized partners,
• Tutors, institutes, or service providers receive payment for completed lessons or services,
• Transactions are encrypted and protected by SSL.

ScholarPASS does not store your full payment information on its servers.

We may also use limited payment transaction data (e.g., date, amount, and last 4 digits of card number) to confirm eligibility for promotions or offers.

(3) Referral Programs

Student/Tutor Referral: For our “Invite a Friend” referral program, we generate a personalized referral link for you to share. We will not collect your friend’s data until they register on ScholarPASS.

Institutional Referral: For our B2B referral program, you may share the name, job title, and email of colleagues or representatives who may be interested in ScholarPASS for Institutions. We will inform them at the time of initial contact.

(4) Communications

We may contact you via email, push notifications, or other methods for service-related purposes, including:

• Welcome messages,
• Security or legal notices,
• Announcements, reminders, and ScholarPASS updates,
• Lesson or assessment notifications,
• Suggestions and personalized tips.

You may also use ScholarPASS to communicate with other users (students, tutors, or institutes), including messaging, video calls, or leaving reviews.

Push notifications can be adjusted via your mobile device settings. You may opt out of non-essential communications at any time, but legal or essential notices cannot be disabled.

(5) User Research

We may contact you to participate in surveys or feedback sessions to improve the ScholarPASS experience. Your contact data (email, phone, etc.) may be used for this purpose.

Research may be used for:

• Feature development and product updates,
• Marketing insights (including publishing anonymized feedback),
• Customer support improvements,
• General service enhancements.

Your voice or image will not be recorded without your explicit consent.

(6) Marketing and Promotion of ScholarPASS

With your consent, we may process your name and email for newsletters or promotional messages. You may opt out at any time.

If you provide your phone number, we may also contact you with promotional information.

We may run affiliate programs or influencer collaborations where participation requires registration and tracking.

Postal addresses (if provided with consent) may be used for campaigns, search engine optimization, or marketing purposes.

Feedback you provide may also be used in marketing or promotional material in accordance with our Terms of Service.

(7) Behavioral and Social Media Marketing

We may share limited data (such as your email address) with platforms like Google or Meta to deliver personalized ads or social media campaigns. These activities are carried out on the basis of our legitimate interests and with safeguards for your privacy.

(8) Identifying Influencers for Potential Collaborations

We may use third-party services (e.g., influencer analytics tools) to analyze registration data (e.g., name, social accounts) and identify students, tutors, or institutes with significant influence. If selected, we may contact you for collaboration opportunities and provide a separate privacy notice.

(9) Analytics and Development

To improve ScholarPASS, we analyze registration data, traffic, cookies, and usage behavior. This may include:

• Pages visited, duration of use, location, and device type,
• A/B testing to compare different features or layouts,
• Polls and surveys to understand satisfaction,
• Integration with third-party analytics tools (e.g., Google Analytics, Amplitude, Hotjar).

These insights help us develop new features, optimize performance, and provide personalized recommendations.

(10) Tutor Verification and Program Preparation

We process tutor data (credentials, IDs, biometrics, etc.) to:

• Verify eligibility to teach,
• Prevent fraud,
• Ensure quality of lessons,
• Assist tutors in developing programs and methodologies.

(11) Improvement of Tutors’ Ranking Algorithm

We collect and analyze tutor and student metrics to enhance our tutor ranking system. This helps optimize visibility, match efficiency, and learning outcomes.

(12) Managing Tutor Community

We process tutor emails, interactions, and usage data within the Tutor Community to:

• Facilitate collaboration and knowledge-sharing,
• Provide official updates,
• Support moderation and analytics,
• Improve community experience.

Access is limited to authorized staff and providers.

(13) Support and Platform Supervision

In case of disputes or service-related issues, we may use communications and data to:

• Investigate and resolve problems,
• Supervise user activity,
• Respond to complaints and support requests.

(14) Events and Webinars Conducted by ScholarPASS

We use registration data for events or webinars to:

• Provide access to sessions,
• Send confirmations, reminders, and follow-up materials,
• Share requested information about our services.

(15) Competitions and Scholarships

Competitions: Occasionally, we may organize learning or skill-based competitions. We collect necessary data (e.g., registration form details) to determine eligibility, select winners, and deliver prizes.

Scholarship Programs: For ScholarPASS scholarships, we may collect personal and academic details to evaluate applications, award funding, and comply with applicable reporting.

Sweepstakes: For promotional sweepstakes, we may process user ID, name, date of birth, and contact details to verify eligibility, notify winners, and fulfill legal obligations. Winners’ names may be published with consent.

(16) Compliance with Legal Requirements

We process payment and account data to comply with financial, tax, or regulatory requirements. We may also process data in response to lawful requests or to exercise, defend, or establish legal claims.

(17) Fraud Prevention

We supervise log data, payment details, and platform behavior to prevent fraud, misuse, or unauthorized access, ensuring a secure environment for all users.

(18) Platform Adaptation (for Tutors Only)

If tutors provide optional demographic data (e.g., gender), we may process it to improve platform personalization, such as adapting tutor profiles or course discovery.

(19) Changes

ScholarPASS may update this Privacy Policy periodically. We will not reduce your rights under this Policy without explicit consent. Updates will be posted on this page, and significant changes will be communicated by email.