Who is responsible
Joshua Gordon Jones, a sole trader trading as Toucan Learn, is the controller responsible for your personal information.
Correspondence: hello@toucanlearn.co.uk or 07309 639095. We can provide a postal address for formal correspondence on request.
For privacy questions or requests, email hello@toucanlearn.co.uk.
What we collect
The enquiry forms collect your name, email address or phone number, who the learner is, their age or school year, subject, message, preferred lesson format, town or postcode area, reply method and optional desired lesson rate, depending on the form and your choices. The Vietnamese form also asks for a preferred teacher and an optional phone or Zalo number; it sets the format to online, location to Vietnam and reply method to email.
Hidden fields include campaign source, traffic source and medium, campaign name and the time the form loaded. A hidden website field helps detect spam.
When you email us, we receive your email address, any name you give, your message and the usual email delivery details.
A parent or carer should make the first enquiry for a child. Please do not send diagnoses or medical records through the form.
If tutoring goes ahead, we also use necessary contact and billing details, lesson arrangements, learning goals, progress notes and communications. Information usually comes from you; during tutoring it may also come from the learner, their parent or carer, their tutor, or someone you ask us to speak with.
You are not legally required to enquire or provide information. Without a reply address and enough detail about the goal, we may be unable to respond or assess a suitable match. Agreed tutoring needs enough contact, scheduling and billing information to run the service.
Why we use it
| Use | UK GDPR lawful basis |
|---|---|
| Answer your enquiry and discuss a possible booking | Steps you request before entering a contract, for the adult learner or contracting parent or carer |
| Arrange and deliver your agreed tutoring | Performance of our contract with the customer |
| Understand a child's learning goal, match a tutor and keep useful lesson notes | Legitimate interests in providing suitable, personal support, with particular care for the child's rights |
| Handle service questions, complaints and security issues | Legitimate interests in running a reliable service, protecting information and resolving concerns |
| Keep tax records or meet another applicable legal duty | Legal obligation |
We use only information needed for these purposes and balance our legitimate interests against your rights. An enquiry is not consent to unrelated marketing. We do not add enquirers to a marketing list.
Health, disability and other sensitive information needs an additional legal condition. Before requesting it, we explain the purpose, lawful basis and applicable condition, including how to withdraw consent if we rely on it. Sending an enquiry is not blanket consent to this use.
Who receives it
Joshua handles first enquiries. Tutors receive only the details needed to check availability and fit; we do not routinely forward the whole enquiry. Once support is agreed, the tutor receives the information needed for the lessons.
Our email, website hosting and record-storage providers process information to run those services. If relevant, limited information may also go to payment providers, accountants, professional advisers or insurers. We may share information with emergency services, local authorities or other public bodies where necessary and lawful to protect someone or meet a legal duty.
We do not sell your information. The enquiry form sends your details through Google Apps Script, run in Toucan Learn's own Google account, straight to our inbox; the form keeps no separate copy. Google acts as our processor. Form enquiries follow the same retention periods as other enquiries. Campaign details (for example, which ad brought you here) are included if you arrived from one. You can also call or WhatsApp us; WhatsApp messages are handled through WhatsApp (Meta) under its own privacy terms, and phone and WhatsApp enquiries follow the same retention periods as email enquiries.
How long we keep it
- Unsuccessful or withdrawn enquiries: six months after our last contact, then deleted.
- Routine client records: while tutoring continues and for two years after the last lesson, then deleted or anonymised. We keep only necessary information when an enquiry becomes a client record, and remove redundant enquiry copies within three months of setting up that record.
- Financial and tax records: at least five years after the 31 January submission deadline for the relevant tax year. This follows GOV.UK guidance for self-employed records. HMRC enquiries or another applicable rule may require longer retention. This period does not automatically apply to lesson notes.
- Routine complaints: two years after the complaint is resolved. A legal claim or safeguarding concern may need longer retention.
Safeguarding records are kept separately for as long as needed to protect the people concerned or meet an applicable legal or authority requirement. We review that need at least annually. If a dispute, legal duty or safeguarding concern requires us to keep another record longer, we retain only what is necessary, review the reason annually and delete it when that reason ends.
We do not automatically collect campaign details with an email enquiry. If you tell us how you heard about Toucan Learn, that information follows the same retention period as your enquiry or client record.
Security and information outside the UK
We restrict access to people who need the information and keep sensitive records separate from routine enquiries. Please avoid sending sensitive attachments in your first email.
Email and hosting services may process information outside the UK. Where this is a restricted transfer, we use an applicable UK adequacy arrangement or appropriate contractual safeguards. You can ask us for details of the providers, countries and safeguards relevant to your information, and a copy of those safeguards.
No tuition connected with Russia is publicly offered.
Your rights
You can ask to see or correct your information, or ask for deletion or a restriction on its use. These rights have limits, for example where we must keep tax records. Where we use information you provided electronically for a contract or with consent, you may also have a right to receive it in a portable format.
If we rely on consent, you can withdraw it at any time; this does not affect lawful use before withdrawal. Email hello@toucanlearn.co.uk to make a request. We may need to check your identity before disclosing information.
Your right to object
You can object to use of your information based on legitimate interests. Tell us your circumstances and we will consider the request and explain our response. You can also object to direct marketing at any time.
If you are unhappy with how we handle your information, you can contact us and you can complain to the Information Commissioner's Office.
Website visits and changes
We use Microsoft Clarity to see how visitors use the site, such as which pages they open, where they click and how far they scroll, so we can improve it. Clarity runs without cookies, records each page on its own and hides anything typed into forms. Microsoft provides Clarity and handles this information under its privacy statement. We use no advertising trackers or cookies.
Our hosting provider may process technical request logs, such as IP addresses and requested pages, to deliver and secure the site. Opening an email link does not send information until you choose to send the email.
We use sessionStorage to remember campaign source and enquiry context during your browsing session, and Clarity uses it for a temporary tab ID. We use localStorage to remember your theme choice, whether you turned off Clarity and, when the launch offer is active, when it was last shown so it is not repeated within 14 days.
We do not make decisions about you solely by automated processing or use automated profiling. We keep this notice up to date and tell existing clients directly about material changes affecting them.