Super Tutors International Education Ltd (“Super Tutors UK”) and Shenzhen Chaoxue Intelligent Tech Ltd (“Chaoxue China”) jointly operate the SmarTLearn International App (“the App”, “we”, “us”). This Privacy Policy explains how we collect, use, share, and protect personal data when you use our services.
We are committed to processing your personal data lawfully, fairly, transparently, and in accordance with UK GDPR and applicable international data protection laws.
1. Who We Are (Joint Controllers)
Super Tutors International Education Ltd (UK)
Registered Address: C/O Xeinadin First Floor Secure House, Lulworth Close, Chandler's Ford, United Kingdom, SO53 3TL
Shenzhen Chaoxue Intelligent Tech Ltd (China)
Registered Address: Room 801-A85A, Zhenxing Building, No. 65 Jinli Road, Longgang District, Shenzhen, China
Email: admin@supertutors.org.uk
Both companies jointly determine the purposes and means of data processing for this App.
2. What Personal Data We Collect
We only collect data that is necessary for learning, parent communication, and school administration. Depending on your role
(student, parent, teacher, school), we may collect:
2.1 Account Data
- Name / username
- Email / phone number
- School name and class (if applicable)
- Parent-child relationship (for student accounts)
2.2 Learning Data
- Course progress
- Assignments and uploaded work
- Scores, feedback, and learning analytics
- Reading time, practice history, activity logs
2.3 Device & Technical Data
- IP address
- Device model, OS version
- App usage logs, crash logs
- Security logs to prevent fraud or misuse
2.4 Media Uploads (Homework Only)
- Photos and videos selected manually by the user The App does not scan or access your photo library without action from you.
2.5 School-Provided Data
When schools use our services, they may provide:
- Student lists
- Class allocation
- Parent contact details (if authorised by the school)
Schools remain responsible for obtaining valid consent from parents where required.
3. Legal Basis for Processing
We process data under the following lawful bases:
Creating & managing accounts：Contract
Providing learning services：Contract
School learning reporting：Contract + Legitimate Interests
Parental access to student progress：Contract + Legitimate Interests
Analytics & service improvement：Legitimate Interests
Direct communication with parents (educational resources)：Legitimate Interests (with opt-out)
Compliance with legal obligations：Legal Obligation
Processing children’s data：Consent from parent or guardian / school authority
For children under 13 in the UK, parental consent is required.
4. How We Use Personal Data
We use personal data for the following purposes only:
✔ To provide learning services
- Displaying courses
- Updating learning progress
- Providing feedback and analytics
✔ To support parents
- Showing student performance
- Sending learning updates
✔ To support schools
- Enabling class management
- Viewing student learning indicators
- Teacher feedback and reporting
✔ To maintain security & prevent misuse
- Fraud detection
- Ensuring account integrity
- Monitoring system stability
✔ To improve services
- Error diagnosis
- App optimisation
- Usage pattern analysis (non-identifiable)
✔ Appropriate Direct Communication (GDPR-compliant)
We may send parents:
- New learning resources
- Service updates
- Curriculum announcements
You may opt out at any time (see Section 10).
We do NOT:
- Sell data
- Perform advertising profiling
- Use data for non-educational marketing
- Track users across other websites
- Show personalised ads
5. Cookies and Similar Technologies
We use necessary cookies for:
- Login and authentication
- Keeping sessions active
- Security protection
- Faster loading
No tracking or advertising cookies are used.
6. Sharing Personal Data
We do not sell, trade, or rent personal data.
We may share limited data with:
6.1 Schools
Only for learning management purposes.
6.2 Service Providers
Including:
- Cloud storage providers
- Analytics and security service vendors
- AI-based homework grading engines (fully anonymised where possible)
All service providers are bound by data processing agreements.
6.3 Legal or Regulatory Authorities
Only when required by law.
7. International Data Transfers
Some data may be processed in the UK, EU, or China.
We ensure appropriate safeguards, including:
- Standard Contractual Clauses (SCCs)
- Technical and organisational security measures
- Data minimisation and pseudonymisation
Schools will be informed if cross-border transfer applies.
8. How We Protect Data
We use industry-standard security measures:
- Encryption in transit (HTTPS/SSL)
- Encrypted storage for sensitive fields
- Role-based access control
- Secure data isolation
- Regular penetration testing
- Employee confidentiality agreements
We maintain an incident response plan and will notify affected parties within required legal timelines.
9. Children’s Data
We take special care when processing children’s personal data.
9.1 Registration
Children cannot register independently.
Accounts must be created by:
- A parent/guardian, or
- A school (acting as data controller)
9.2 Use of Data
Children’s data is only used for educational purposes.
We do not:
- Use children’s data for advertising
- Profile children for commercial purposes
- Share data with third parties for marketing
9.3 Parent / Guardian Rights
Parents can:
- Access data
- Correct data
- Delete data
- Withdraw consent
- Request account deletion
10. Your Rights (UK GDPR)
You have the right to:
- Access your data
- Rectify inaccurate data
- Request deletion (“right to be forgotten”)
- Restrict processing
- Object to certain uses
- Withdraw consent
- Data portability
For parents:
You may also exercise these rights on behalf of your child.
Requests may be submitted via:
admin@supertutors.org.uk
We will respond within 30 days, as required by UK GDPR.
11. Data Retention
We retain personal data only as long as necessary:
- Active account holders: data kept until account deletion
- School contracts: data retained per contract terms
- Legal requirements: retention per statutory needs
- Backups: automatically purged on rolling schedules
After retention ends, data is anonymised or securely deleted.
12. Changes to This Privacy Policy
We may update this policy for legal or operational reasons.
We will notify users by:
- In-app notice
- Email (if appropriate)
- Version update notes
Significant changes will require renewed consent.
13. Contact Us
For privacy inquiries or rights requests:
Data Protection Officer (DPO)
Email: admin@supertutors.org.uk
Super Tutors International Education Ltd
C/O Xeinadin First Floor Secure House, Lulworth Close, Chandler’s Ford, United Kingdom, SO53 3TL
We are supervised by:
Information Commissioner’s Office (ICO), UK
You may lodge a complaint directly with the ICO if needed.
Update (December 2025):
Our app has been updated to comply with Google Play’s Photos and Videos Permissions Policy.
The app no longer automatically accesses or scans photos or videos stored on a user’s device.
Homework photo or video uploads are now handled through Android’s official Photo Picker and File Picker interfaces, where users manually select specific files to submit.
Screen protection for lesson videos is implemented using Android’s FLAG_SECURE system feature, which prevents screen capture and recording without accessing or storing any personal data.
These updates ensure full compliance with Google Play’s privacy requirements and protect user data in a secure, transparent, and education-focused manner.
Update (January 2026):
last update we moved vertical interface down to comply with iPhone 16 headline space.
Update (April 2026):
Auto-Start and Background Activity Disclosure
Legal Basis and Purpose
We process certain technical data and enable background activity strictly to ensure the proper functioning, security, and reliability of the application. These activities are carried out on the basis of our legitimate interests in providing a stable and secure service, and, where applicable, based on your consent.
Push Notifications and Background Activation
To ensure that you can receive push notifications while the application is closed or running in the background, the application may rely on system-level capabilities that allow it to be woken (auto-started) in response to system broadcasts.
* This functionality is strictly limited to delivering notifications and maintaining service continuity.
* Where a notification involves opening specific content, the application will only redirect you after obtaining your explicit interaction or consent.
* Without your interaction, the application will not trigger associated content launches.
You may manage or disable push notifications at any time through your device settings.
Download and Update Functionality
When you initiate a download within the application (such as application updates), we process and monitor the download task to ensure completion.
This may include:
* Maintaining network (HTTP) connections during the download process
* Continuing downloads when the application is in the background
* Handling interruptions such as network changes or system restarts
These processes may involve limited background activity or automatic restart of download-related services where necessary. This ensures that downloads complete reliably without requiring constant user intervention.
Widget Functionality (if applicable)
If you choose to use home screen widgets, the application will process system broadcast events (e.g., android.appwidget.action.APPWIDGET_UPDATE) to keep widget content up to date.
* These broadcasts are initiated by the operating system.
* The application may respond by activating widget-related services in the background to update displayed information.
This functionality is optional and only active if you enable and use widgets.
User Control and Transparency
You remain in control of these features:
* You can disable notifications through your device settings
* You may choose not to use widgets
* Background activity is limited to what is strictly necessary for functionality and cannot be used for unrelated purposes
Data Minimisation and Security
We ensure that:
* Only the minimum data necessary is processed
* Background activity does not involve unnecessary data collection
* All processes comply with applicable data protection laws, including the UK General Data Protection Regulation and other relevant regulations.