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Privacy Policy

Tutor AI
Last Update Date: 10.09.2024

1. Objective

HARBOUNDS LIMITED (“Company” or “we”), CRN: 77715937, aims to process personal data of users in accordance with general privacy principles and applicable data protection laws, including the Turkish Law on Personal Data Protection No. 6698 (“PDP Law”), as well as other relevant regulations. Where applicable, the Company also observes the rights granted under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Your personal data, which you provide or which we obtain from external sources, may be processed by HARBOUNDS LIMITED as the “Data Controller” under the following conditions:

  • Within the scope of the stated purposes for processing, in a manner that is relevant and proportionate to those purposes;

  • While ensuring that the personal data we hold are accurate and up to date, as provided by you;

  • Where necessary, personal data may be recorded, stored, preserved, reorganized, and transferred to institutions authorized by law to request such data. They may also be transferred, classified, and shared with third parties, domestically or abroad, under the conditions set out by legislation and upon your explicit consent if required. They may be processed by other lawful means allowed by legislation.

This Privacy Policy is adopted to ensure the continuity and enhancement of the Company’s activities in line with the principles set forth under the PDP Law. It explains which data we collect, how we intend to use, store, protect, and share such data, how you can withdraw consent, and how you can correct or revise your personal data.

Capitalized terms used herein shall have the meanings assigned to them in the Terms and Conditions, unless otherwise defined in this Privacy Policy.

2. Collection of Personal Data and Method

HARBOUNDS LIMITED may process personal data for the purposes specified in this Privacy Policy.

Categories of Personal Data We Collect

  1. Identity Information: Examples include your name and surname (if you contact us).

  2. Contact and Profile Information: Such as phone number, email address, username, password, user ID, nickname, profile picture, user token, and Open ID.

  3. Social Media Information: If you register using your social media accounts (e.g., Google, Apple, or Facebook), we may collect identifiers provided by those platforms, including user ID, nickname, profile picture, phone number, user token, and Open ID.

  4. Process Security Data: This includes Internet traffic data (IP address, browser type, date/time stamps, visit data, etc.), device type and name, operating system, screen size, purchase history, token IDs (if you allow notifications), and, with your permission, the identifier for advertisers (IDFA) or for vendors/developers (IDVF).

  5. User Content: Any messages, posts, communications, statements, text, images, photos, videos, audio recordings, or other content that you provide, upload, or share within Tutor AI.

  6. Customer Transaction Data: Such as order information if you make a purchase.

  7. Marketing Data: This may include IDFA or IDVF for analytics and marketing, where permitted.

We may collect the above data directly from you through physical or electronic means, including your mobile device, web browsers, websites, or third-party applications (e.g., WhatsApp). We do so to fulfill legal obligations, enhance our services, administer your account usage, and provide a more convenient and personalized experience. We may also collect log data during your usage of Tutor AI, which can include IP address, device details, operating system version, and the time/date of service usage.

General Principles of Personal Data Processing

As a data controller, HARBOUNDS LIMITED follows the fundamental principles of:

  • Compliance with laws and the principle of good faith

  • Accuracy and up-to-date data

  • Processing for specific, explicit, and legitimate purposes

  • Relevance, limitation, and proportionality (data minimization)

  • Retaining data only for the period required by law or for which they are processed

3. Purposes of Processing Personal Data and Legal Bases

Your personal data may be processed by automated or non-automated means for the purposes listed below, in accordance with applicable legislation and Articles 5 and 6 of the PDP Law. The legal bases for processing include explicit legal authorization, necessity for contract performance, or legitimate interests of HARBOUNDS LIMITED, provided these do not infringe upon your fundamental rights and freedoms.

a) Purposes of Processing Personal Data

  1. Identity Information, Contact/Profile Information, Social Media Information

    • Ensuring compliance with legislation and safeguarding individuals’ rights, privacy, and security

    • Fulfilling company, product, or service commitments

    • Communication activities

    • Management and auditing of business operations

    • Providing after-sales support and notifications about the Services

    • Executing goods/services sales processes

    • Conducting storage and archiving

    • Contract processes

    • Operating the product (user account creation, etc.)

    • Marketing activities (with your explicit consent)

  2. Process Security Data

    • Executing information security processes

    • Conducting audits or ethical checks

    • Managing and auditing business activities

    • Ensuring business continuity

    • Providing information to authorized entities or authorities when legally required

  3. Customer Transaction Data

    • Managing and auditing business activities

    • Providing after-sales support for goods/services

    • Executing sales processes

    • Conducting customer satisfaction activities

    • Handling contract processes

  4. User Content

    • Operating our product (e.g., generating responses)

    • Offering after-sales support and communication

    • Complying with applicable laws; protecting rights, privacy, and safety

    • Preventing illegal acts

    • Managing contract processes

    • Conducting storage and archiving

    • Ensuring business continuity

    • Fostering customer satisfaction

    • Improving our services (including AI model training). To opt out of data usage for AI model training, please email support@tutorai.tech.

  5. Marketing Data

    • Marketing analysis

    • Advertising, campaign, and promotion processes

We may adapt or update these purposes according to new obligations under our policies or law (e.g., digital subscription handling, app personalization, promotional communications, information security, governmental requests, etc.).

b) Legal Reasons

  1. Identity, Contact, Profile, Social Media, and Customer Transaction Data

    • Necessary for the performance of a contract or directly related to contractual obligations

    • Necessary for establishing, exercising, or protecting legal rights

    • Your explicit consent (e.g., for marketing communications)

  2. User Content

    • Necessary for performing a contract with you

    • Necessary for establishing, exercising, or protecting legal rights

    • Required for our legitimate interests, as long as your rights are not violated

    • Your explicit consent

  3. Process Security Data

    • Explicitly allowed or required by law

    • Fulfilling legal obligations

    • Necessity for performance of a contract or related obligations

    • Consent

  4. Marketing Data

    • Your explicit consent

Third-Party Websites and Applications

Tutor AI may include links to websites or apps that are not controlled by HARBOUNDS LIMITED. We are not responsible for content or privacy practices on those sites or apps. Your use of third-party websites or apps is subject to their own terms and conditions. HARBOUNDS LIMITED bears no liability for any damage caused by or in connection with such third-party services.

4. Cookies

Cookies are small text files stored in your browser or device’s memory when you visit a website. They help websites function more efficiently and personalize your experience. We may use cookies to operate our services, enhance performance and functionality, and deliver relevant content or ads. You can manage or disable cookies in your browser settings, though some features may be affected.

5. Push Notifications

We may occasionally send you push notifications related to your account or Tutor AI services. You can control push notification preferences through your device or account settings. We store your data for as long as necessary for the relevant purpose or as mandated by law, and we may continue storing data if required by law or if you have given explicit consent for extended storage.

6. Technical and Administrative Measures

HARBOUNDS LIMITED implements necessary measures (technical and administrative) to protect personal data against unauthorized access, disclosure, or destruction. These include antivirus software, firewalls, VPNs for remote access, user-access management, real-time threat monitoring, encryption, transaction logging, two-factor authentication, penetration testing, an Information Security Management System (ISMS), staff training, physical security measures, regular backups, NDAs for personnel, and secure data transfer protocols.

If any breach or illegal data access occurs despite our safeguards, we will promptly inform affected users and relevant authorities and take steps to minimize damage.

7. Age Limitation

Tutor AI is not intended for use by individuals under 16. We do not knowingly process data from users under 16. If you suspect someone under 16 has provided personal data, please notify support@tutorai.tech. Users under 18 must have parental or guardian consent.

8. Transferring Personal Data to Third Parties

We may transfer personal data, including sensitive data where applicable, to domestic or foreign third parties (e.g., if we use servers located abroad). Such transfers may be for storage, archiving, business activities, after-sales support, and customer management. HARBOUNDS LIMITED may also share identity, contact, and transaction data with authorized public institutions or third parties like Facebook SDK, Adjust, or Firebase Analytics for legal compliance, business operations, or customer relationship management.

9. Your Rights as a Data Subject

Under Article 11 of the PDP Law, you may request to:

  • Learn whether your personal data has been processed;

  • Request information about how and why it is processed;

  • Learn who the data is transferred to;

  • Request corrections if data is incomplete or inaccurate;

  • Request deletion or anonymization if the reasons for processing no longer apply;

  • Be notified of any such actions taken regarding third parties;

  • Object to negative outcomes from purely automated processes (including profiling);

  • Claim compensation for damages resulting from unlawful processing of your data.

Where the GDPR applies, you may also have the right of access, rectification, erasure, restriction of processing, objection, data portability, and freedom from automated decision-making with significant effects.

To exercise these rights, email support@tutorai.com. HARBOUNDS LIMITED will respond within 30 days, free of charge, unless your request is declined for a lawful reason. If you believe your rights are violated, you may lodge a complaint with relevant data protection authorities.

10. Changes to This Policy

We may amend this Privacy Policy whenever necessary. Changes are effective immediately upon posting, unless otherwise specified. Continued use of Tutor AI after updates constitutes your acceptance of the new terms.

Company Name: HARBOUNDS LIMITED (CRN: 77715937)
Address: ROOM 511, 5/F, MING SANG IND BLDG, 19-21 HING YIP STREET, Kwun Tong Hong Kong
Email: support@tutorai.com