Privacy Policy.

1. Introduction

This Privacy Policy is provided by Sophyra Limited, a company registered in Ireland under company number 817595 and trading as Sophyra Tutors (registered business name No. 790687), with registered office at First Floor, Penrose 2, Penrose Dock, Cork, T23 YY09, Ireland ("we", "our", or "us"), for use of our products and services including our website (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use, and share any information relating to you or your child's personal data (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use, and sharing of your personal data is regulated by law, including under the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used. Given the nature of our Services, we may collect the personal data of children under 18 years old with explicit consent from you, the Parent or Guardian of that child.

2. What this policy applies to

This privacy policy relates to your use of the Services only. The Services may link to or rely on other websites, APIs, or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other websites, APIs, or services may also gather information about you in accordance with their own separate privacy policies.

3. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

• Identity and account data you input into the Services. Registration is mandatory in order to use the Services: name, email address, address, education level, and your account details such as username and password.
• Data collected when you use specific functions in the Services: data you store online with us using the Services including your usage history or preferences.
• Other data the Services collect automatically: your activities on, and use of, the Services which reveal your preferences, interests, or manner of use of the Services and the times of use.
• Data collected when you make an enquiry: your name and email address.
• Data collected when you book or pay for tuition: the payer's name, email address, and billing address, the student's name, and records of payments, invoices, and receipts. Card details are entered directly with our payment processor, Stripe, on its secure payment pages and never reach our systems.

If you do not provide personal data we ask for where it is required, it may prevent us from providing services to you.

4. Special category personal data

Certain personal data we collect is treated as a "special category" to which additional protections apply under data protection law. This is also known as "Sensitive Data". Where we process Sensitive Data, we will ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent.

Sensitive personal data means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person's sex life; and data concerning a person's sexual orientation. We may collect sensitive personal data or information about criminal convictions from individuals as required from a DBS or equivalent police check.

5. How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly, reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

We collect only limited information using cookies and similar technologies, and only with your consent where the law requires it. Section 11 below and our Cookies page set out exactly what we use and the choices you have.

6. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

7. Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including tutors, developers, and cloud storage providers. These include Stripe, which processes payments on our behalf; Lessonspace, which provides our online classroom; and Anthropic, whose AI model assists with drafting as described in section 8. We also share limited advertising measurement data with OpenAI, as described under Advertising measurement in section 11.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with external auditors, professional advisors (such as lawyers), law enforcement agencies, courts or tribunals, regulatory bodies, or other parties in connection with a significant corporate transaction or restructuring. In all cases, recipients will be bound by confidentiality obligations.

8. Online lessons: recording and AI assistance

Lessons delivered through our online classroom are recorded as a safeguarding measure. Recording playback is restricted to authorised staff, is resolved individually for each viewing, and is logged. Recordings are not released to students, parents, or tutors.

Lessons are not transcribed. No written record of what is said in a lesson is produced or kept.

Tutors plan their own lessons. The tutor uploads their lesson plan, writes notes after each session, and records the examination board and specification being followed. At the five-week and ten-week points, and at other times on request, a progress report for the parent is drafted with the assistance of an AI model provided by Anthropic, working from those lesson plans, those notes and the specification, so that progress is measured against what the course is meant to cover. The tutor reviews, edits and approves every progress report before a parent sees it. Lesson recordings are never sent to any AI system and are not used to produce reports. We minimise the personal data the model receives: it sees a student's first name and initial only, and never surnames or contact details. Tutor vetting records are never processed by any AI feature. Consistent with section 11, no decision producing legal effects is made by automated processing.

9. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a need-to-know basis have access to such data. Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

10. Transferring your personal data out of the European Economic Area

As part of providing the website and Services, we may share your personal data with third parties based outside of the European Economic Area (EEA). Under EU data protection law, we can only transfer your personal data to a country outside the EEA where: the European Commission has decided the particular country ensures an adequate level of protection of personal data (an "adequacy decision") further to Article 45 of the GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law.

In practice, personal data reaches three kinds of recipient outside Ireland. Our online classroom provider holds lesson recordings on servers in the United Kingdom. Our assigned tutors work from a number of countries, currently Poland, Belgium, the United Kingdom, India, Pakistan and Azerbaijan, and access student information remotely through our portal. Our other service providers are contracted directly by us and are covered by their own agreements with us.

Access from within the European Economic Area, such as Poland and Belgium, is protected by the GDPR and needs no additional transfer mechanism. For the United Kingdom we rely on the European Commission's adequacy decision for the United Kingdom, renewed on 19 December 2025, while it remains in force and covers the transfer. For countries with no adequacy decision, including India, Pakistan and Azerbaijan, we put the European Commission's standard contractual clauses in place, complete an assessment of the transfer, and apply additional safeguards before any access is switched on. Those safeguards include showing tutors a student's first name only, withholding contact details, keeping all access and communication inside the portal, prohibiting downloads and subcontractors, logging access, and revoking accounts promptly.

11. Cookies and analytics

We measure visits to this website and how quickly its pages load. The analytics we use are cookieless: they do not store your IP address, and the short-lived identifier used to count a visit is discarded within 24 hours. If you enable advertising cookies in the cookie preferences panel, we also use the Meta Pixel to measure how our advertising performs and to reach people who have shown interest in our services on Meta platforms (Facebook and Instagram); Meta Platforms Ireland Limited then acts as a joint controller for that data. The Meta Pixel is off unless you enable it, and you can withdraw that choice at any time in the same panel.

Advertising measurement. If you accept advertising cookies and arrive from one of our adverts in ChatGPT, we tell OpenAI, which runs ChatGPT's advertising, when you start our enquiry or course registration form. We send the advert reference OpenAI added to the link, the name of the event and the time. We do not send your name, email address, anything you type into the form, or your IP address. The advert reference is kept in your browser for the current session only. You can withdraw consent at any time in the cookie preferences panel, and we stop straight away. OpenAI handles this information as an independent controller under its Conversion Terms, except for limited processing it carries out for us as our processor. For visitors in the European Economic Area it is handled by OpenAI Ireland Limited, which uses a valid transfer mechanism for any onward transfer outside the EEA; for visitors in the UK it is handled by OpenAI OpCo, LLC under the UK standard contractual clauses.

You can turn analytics off at any time in the cookie preferences panel on this website, and we will honour that choice. The portal uses strictly necessary session and security technologies needed to sign you in and keep the service secure. We will provide a cookie notice and choices before using any non-essential cookie where the law requires it. Our Cookies page sets this out in full.

12. Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the Data Protection Commission website.

• Access to a copy of your personal data. The right to be provided with a copy of your personal data.
• Correction (rectification). The right to require us to correct any mistakes in your personal data.
• Erasure (right to be forgotten). The right to require us to delete your personal data in certain situations.
• Restriction of use. The right to require us to restrict use of your personal data in certain circumstances.
• Data portability. The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format.
• To object to use. The right to object at any time to your personal data being used for direct marketing, including profiling.
• Not to be subject to decisions without human involvement. The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you. We do not make any such decisions based on data collected by the Services.

13. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How to complain

Please contact us if you have any queries or concerns about our use of your information. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the Data Protection Commission in Ireland. You may also complain to the supervisory authority in the country where you live, where you work, or where you believe the issue arose. The Data Protection Commission can be contacted here.

15. The exali liability seal

This site displays the exali liability seal, which confirms that Sophyra Limited holds professional indemnity insurance. The seal graphic is loaded from servers operated by exali AG. Because of the technical design of the internet, your IP address is transmitted to exali AG so that the graphic can be delivered to your browser. If you click the seal you leave this site and are taken to exali AG’s servers.

The legal basis is Article 6(1)(f) of the General Data Protection Regulation, legitimate interest. Our legitimate interest is in allowing visitors to verify independently that we hold professional indemnity cover. exali AG is established in Germany, within the European Economic Area, so no transfer outside the European Economic Area arises. Further information is in exali AG’s privacy notice.

16. Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means such as email.

17. How to contact us

You can contact us using our enquiry form or by telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law, or to make a complaint.

Enquiry form: sophyratutors.com/enquiry

Telephone: +353 21 221 0007