1

Process your application as a student

Some of this processing is necessary for takings steps at your request to enter into a contract with you.

Additional processing is necessary for the purpose of the legitimate interests pursued by us.

We have a legitimate interest in fully assessing students to ensure the selection of suitable and appropriate tutors.

We aim to arrange the best suitable consultants to students and this contributes towards meeting our business objectives, maintain our reputation and attracting students interested in learning.

To the extent that there is any processing of special personal information for purposes of the application processing, we will rely on your consent in circumstances where required by applicable laws.

2

Providing contracts of online learning and preparing to learn with us.

Some of this processing is necessary for the compliance with legal obligations to which TutorABC is subject including the requirement to issue written particulars or terms of online learning.

Additional processing is necessary to take steps to enter into the contract between you and TutorABC and to perform that contract.

To the extent that there is any processing of special personal information for purposes of the contract and online learning process, and such processing is not necessary for the establishment, exercise or defence by TutorABC of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

3

Managing and administering your contract, including without limitation arranging class scheduling, feedback and payment for your services;

Display your profile, learning experience and language proficiency to consultants you may learn from via our services and platforms;

Facilitate classes with consultants you may learn from or users of our services and platforms;

Update your profile when requested by you or otherwise required by applicable law; and

We will use and otherwise process your special categories of personal data for the following purpose:

• Verify your identity;
• Detect potential imposters or fraudsters who may be using our services and platforms fraudulently or illegally;
• Where applicable display your photograph and facial images on your profile.

Some of the processing is necessary to perform the contract between you and TutorABC to ensure that you carry out your obligations or execute your rights under your contract.

Further processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in contributing to appropriate business protection by ensuring that students can be identified and to prevent imposters posing as approved students.

It also includes facilitating, controlling and restricting access to the TutorABC Platform and other TutorABC systems. To be effective these must be monitored and kept up to date.

To the extent that there is any processing of special personal information for purposes of the managing your contract including the display of photographic and facial images, we will rely on your consent in circumstances where required by applicable laws.

In addition to our legitimate interests where reliance on such lawful basis is permitted by applicable laws, any processing of special categories of personal data for identification and detecting imposters or fraudsters will be carried out based on your explicit consent. Alternative verification mechanisms may be provided where these would achieve similar standards of verification and authentication.

4

Communicate with you in respect of the services we provide via the TutorABC Platform or when you otherwise learn with us via the TutorABC Platform;

Send you marketing communications or advertisements from or about us or our Affiliates in relation to our products and services (including but not limited to newsletters, events and promotions); and

Enable selected third parties to send marketing communications which are related to their products or services which we think may be of interest to you.

Using your data to communicate with you is necessary for the compliance with legal obligations to which TutorABC is subject including the need to communicate with you regarding processes governed by laws.

Additional processing is necessary to perform the contract between you and TutorABC. There needs to be communication between you and TutorABC to operate your contract.

Further processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in managing and operating its business. This includes effective communication and maintaining a dialogue with students operationally and in relation to their terms and conditions of contract.

Communication is important to support the effective organisation and delivery of service and support successful delivery of commitments to members and enable effective business performance.

Marketing communications will be sent in our legitimate interests or to the extent that students have consented to receiving such communications, where required by applicable laws.

5

Enable us to operate the TutorABC Platform;

Carry out support and maintenance functions; provide you with necessary assistance in case of any technical issues;

Conduct data analysis and research, further develop and enhance the functionality and features of the TutorABC Platform; and

Deploy security measures for the TutorABC Platform.

Some of this processing is necessary for the purpose of meeting TutorABC's contractual obligations to provide you with tools and support in the provision of the services.

Further processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in ensuring that the TutorABC Platform meets and operates to market standards for the provision of its services to members.

6

Carry out our internal business functions such as sessions quality control, consultants headcount planning, reporting management;

Protect our intellectual property and other rights;

Enforce our internal policies and/or contractual rights; and

Conduct necessary investigations and suspend or terminate actions.

Some of this processing is necessary for the compliance with legal obligations to which TutorABC is subject including statutory reporting obligations and corporate governance requirements.

Additional processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in managing and operating its business, ensuring appropriate governance and controls are in place and to measure and report on financial management and business performance.

This includes appropriate preparation of management information reports; financial accounts; reporting for internal and external governance; and liaising with third parties such as investors or finance providers.

TutorABC also has a legitimate interest in ensuring that its business, members, students and systems are protected.

While we engage in management procedures with a view to addressing and resolving concerns we also need to ensure that any ultimate decision to bring your contract to an end is fair and lawful. This processing is necessary to perform the contract between you and TutorABC where we have committed to comply with certain procedures as part of your terms and conditions of contract .

TutorABC has a legitimate interest in managing its student pool and operating its business. This includes putting in place appropriate policies and procedures for students and taking action if they are not complied with. It also includes addressing student concerns and issues, resolving the same and complying with our policies and procedures.

These activities support business continuity and are important to support the TutorABC's long-term business goals and outcomes.

To the extent that there is any processing of special personal information for business operational purposes, and such processing is not necessary for the establishment, exercise or defence by TutorABC of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

7

Comply with applicable laws, regulations, legal process (such as a court order or subpoena), governmental request, our internal policies and procedures, and other ethics, anti-corruption and compliance reporting tools;

Protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, health and safety compliance, regulatory, investigative, grievance and remedy purposes;

Detect, prevent or address fraud, security or technical issues; and

Protect us and you, and our, your or others' rights, property or safety, or the public against harm, as required or permitted by law.

This processing is necessary for the compliance with legal obligations to which TutorABC is subject where there is a legal obligation to disclose information or a court or other legal order to provide information is place.

Where not legally required, processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in co-operating with relevant authorities, government bodies or regulators for the provision of information where appropriate.

TutorABC wishes to maintain its reputation as a good corporate citizen and to act ethically and appropriately in all the jurisdictions in which it does business.

TutorABC has a legitimate interest in protecting its organisation from breaches of legal obligations owed to it and defending itself against litigation. This is necessary to ensure that our legal rights and interests are protected appropriately, to protect our reputation and to protect us from other damage or loss.

To the extent that there is any processing of special personal information for general compliance purposes, and such processing is not necessary for the establishment, exercise or defence by TutorABC of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

This encourages compliance and high standard of business practice and protects our reputation. This supports our immediate and long-term business goals and outcomes.

8

Safety and security; satisfying the Company's regulatory or other obligations to supervise users; and preventing, detecting and investigating a wide range of activities and behaviours and liaising with regulatory authorities.

Some of this processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in ensuring that its business, members, employees and systems are protected and that action is taken to mitigate risk and to prevent and detect matters which may put TutorABC or its business or stakeholders at risk.

This includes carrying out risk assessments; detecting and preventing crimes or criminal activity or other unlawful or unethical activity; ensuring that only appropriate users are engaged in our platform; and ensuring compliance with other legal or regulatory requirements placed upon us or related official guidance.

To the extent that there is any processing of identifiable special personal information for safety and security purposes and for the prevention and detection of inappropriate or unlawful activities, and such processing is not necessary for the establishment, exercise or defence by TutorABC of a right or obligation in law, we will rely on your consent in circumstances where required by applicable laws.

9

We may share your personal data with the following:

• our affiliates within the TutorABC group of companies,
• students you may learn with via, and users of, our services and platforms;
• our (and/or our Affiliates') service providers who support our provision of the TutorABC Platform, our services and our business;
• Government, enforcement or regulatory authorities in any applicable jurisdiction;
• outside parties involved in a merger, acquisition or due diligence exercise; and
• anyone you authorise.

TutorABC has a legitimate interest in ensuring that it can engage with suppliers effectively and that suppliers can access the information they need to provide the service for which they have been engaged.

Effective communication with and engagement of suppliers is important for business continuity and improvement.

TutorABC has a legitimate interest in providing tutoring packages, which may include recording of tutoring sessions to students. Note that our members also have legitimate interest in retaining such packages.

Some of this processing is necessary for the compliance with legal obligations to which TutorABC is subject.

Additional processing is necessary for the purpose of the legitimate interests pursued by TutorABC.

TutorABC has a legitimate interest in managing its business operations in the most effective way. TutorABC needs to make decisions relating to the future of its business in order to preserve its business operations, grow its business or maximise efficiency and effectiveness.

In the event that TutorABC makes a decision to outsource a function or acquire or transfer a business or part of a business TutorABC and the third party with whom TutorABC is seeking to transact each have a legitimate interest in ensuring that the workforce, employee costs and liabilities are sufficiently understood prior to committing to the transaction and to ensure a smooth transition of employees if a transaction goes ahead.

To the extent that there is any disclosure or sharing of special personal information with third parties, we will rely on your consent to such disclosure and sharing of personal data in circumstances where required by applicable laws.