Privacy Policy

• This Privacy Policy defines the principles of processing and protection of personal data of TutLive platform users.

• The controller of your personal data is MEETZ SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (MEETZ LIMITED LIABILITY COMPANY) headquartered in Poznań (ul. Juliusza Słowackiego 55/1, 60-521 Poznań, Poland), registered in the National Court Register under number 0001051530, share capital: PLN 8,700.00, VAT ID: 7812055176, REGON: 526056312.

• Contact with the Controller is possible at email address: [email protected]

• Identity data: name, surname, email address, age (for personalization of educational content)

• We do not collect sensitive data within the meaning of art. 9 GDPR (e.g. health data or beliefs). Voice recordings are processed solely to conduct your conversation with the tutor - they are not used for biometric identification.

• Educational data: learning level, subjects, AI lesson history, learning progress, educational preferences

• Audio data: during voice lessons your voice is streamed in real time to the Google Gemini service, which powers the conversation with your tutor; we also store transcripts of these conversations

• Technical data: IP address, browser information, cookies, device data

• Payment data: transaction information (processed by payment provider Stripe)

• AI interaction data: questions asked to AI tutor, responses, quality ratings (for algorithm improvement)

• Performance of contract - provision of AI tutoring services and personalization of educational content (art. 6 sec. 1 lit. b GDPR)

• Legitimate interest - analysis of AI service quality, platform security, algorithm development (art. 6 sec. 1 lit. f GDPR)

• Consent - marketing, Google Analytics 4 (currently disabled), non-essential cookies (art. 6 sec. 1 lit. a GDPR)

• Legal obligation - accounting, consumer protection, children's online safety (art. 6 sec. 1 lit. c GDPR)

• Provision of AI tutoring services - content personalization, difficulty level adjustment, progress tracking

• User account management, payment and subscription handling

• Communication with users, technical and educational support

• Development and improvement of AI algorithms - analysis of teaching method effectiveness in anonymous and aggregated manner (basis: legitimate interest)

• Marketing (with consent) - newsletter, educational offers, information about new features

• Google Analytics 4 (with consent) - traffic analysis, functionality optimization - CURRENTLY DISABLED

• Ensuring platform security, abuse detection, minor protection

• Account data: until account deletion or 2 years from last activity

• Educational data and interactions (including lesson messages and transcripts): 2 years from last lesson (necessary for algorithm improvement and security)

• Payment data: in accordance with tax regulations (5 years, counted from the end of the tax year in which the transaction took place)

• Marketing data: until consent withdrawal or 2 years from last contact

• System and security logs: 12 months (protection against abuse)

• Users aged 13-17: Parents/guardians may request access to account information or deletion by contacting [email protected]

• Deletion: after the above periods, data is deleted or anonymized

• After account deletion request: personal data deleted immediately (maximum 30 days), accounting data according to legal requirements

• IMPORTANT: TutLive requires users to be at least 13 years old. We do not knowingly collect data from children under 13. If we discover a user is under 13, we will delete their account immediately.

• Payment providers (Stripe) - transaction processing, PCI DSS compliant

• IT service providers - Fly.io (application hosting, servers in the EEA - Frankfurt) and Google (email and infrastructure)

• AI providers - Google (Gemini service) for tutoring functionality, including voice conversations

• Safeguards - Google reCAPTCHA (protection against bots and abuse)

• Government authorities - only based on legal provisions or court order

• All providers operate under GDPR-compliant data processing agreements and ensure appropriate level of protection

• INTERNATIONAL DATA TRANSFERS:

• TutLive uses third-party services that may transfer data outside your country:

• • Google Gemini (United States): your questions, messages, voice recordings from voice lessons and session transcripts are processed by Google services located in the United States. This is necessary to conduct the conversation with your tutor. Google adheres to standard contractual clauses approved by the European Commission.

• • Stripe (United States/EU): payment processing. Stripe is PCI DSS compliant and applies appropriate safeguards for international transfers.

• • Hosting: application data is hosted on servers in the European Economic Area (Frankfurt). Only data passed to Google (AI services) and Stripe (payments) leaves the EEA, on the terms described above.

• For users in the European Economic Area (EEA), the UK and Switzerland: we rely on adequacy decisions, standard contractual clauses (SCCs) or other transfer mechanisms approved by the relevant authorities.

• You can obtain information about these safeguards by contacting [email protected].

• TutLive requires all users to be at least 13 years old.

• CHILDREN'S PRIVACY:

• TutLive is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected] and we will delete such information.

• For users aged 13-17, we recommend parental awareness and supervision. Parents/guardians of users aged 13-17 may request access to their child's account information or request deletion by contacting us.

• UNDER-13 DETECTION: If we discover that we have collected personal data from a child under 13, we will delete that information immediately and terminate the account.

• AGE DECLARATION: By creating an account you declare that you are at least 13 years old. Providing false age information may result in account termination and data deletion.

• Parents or guardians can contact us regarding their child's privacy at: [email protected]