Privacy Policy

Introduction

This Privacy Notice for Tutly ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Tutly, or any other application of ours that links to this Privacy Notice)
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns?

Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at tutly.contact@gmail.com.

Summary of the key points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process you information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Do we offer artificial intelligence-based products?
7. How do we handle your social logins?
8. How long do we keep your information?
9. How do we keep your information safe?
10. What are your privacy rights
11. Controls for DO-NOT-TRACK features
12. Do United States residents have specific privacy rights
13. Do we make updates to this notice?
14. How can you contact us about this notice?
15. How can you review, update, or delete the data we collect from you?

What information do we collect?

Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• email addresses
• passwords

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Google API Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

How do we process your information?

We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

What legal bases we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• AI Platforms
• Data Storage Service Providers
• User Account Registration & Authentication Services
• Cloud Computing Services
• Data Analytics Services

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include:

• Remarketing with Google Analytics
• Google Display Network Impressions Reporting
• Google Analytics Demographics and Interests Reporting

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page

Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies
We offer AI-powered features ("AI Products") that are supported by third-party providers, including OpenAI ("AI Service Providers"). As outlined in this Privacy Notice, any input you provide, outputs generated, and personal information may be shared with these providers to deliver the AI Products in accordance with the purposes described in What Legal Bases Do We Rely On To Process Your Personal Information?.

Important: You must not use our AI Products in ways that violate the terms or policies of any AI Service Provider.

Our AI Products Our AI Products are designed to support the following functions: AI applications (e.g., generative tools, chat assistants, data analysis aids)

How We Process Your Data Using AI We process all personal data used with our AI Products in accordance with this Privacy Notice and any agreements we have with our AI Service Providers. These measures are in place to ensure the security and privacy of your personal data throughout the process.

How do we handle your social logins?

In short: If you choose to log in using a social media account, we may receive some of your public profile information.

Our Services allow you to sign up or log in using third-party social media accounts (such as Facebook or X). When you use these options, we may access certain profile information including (but not limited to) your:

• Name
• Email address
• Profile picture
• Friends list
• Any other public data associated with that account

We only use this information for the purposes outlined in this Privacy Notice. Please note that we do not control how social media providers use your information. We recommend reviewing their privacy policies to understand how they manage your personal data.

How long do we keep your information?

In short: We retain your information as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by law.

We will retain your personal data only as long as:

• You maintain an active account with us
• It is needed to comply with legal, tax, or regulatory obligations

When we no longer have a legitimate reason to keep your information, we will delete or anonymize it. If deletion isn’t possible (e.g., due to backups), your data will be securely stored and isolated until deletion becomes feasible.

How do we keep you information safe?

In short: We apply both organizational and technical measures to protect your data.

We have implemented reasonable security measures to protect your personal data. However, no system is completely secure. While we strive to protect your information, we cannot guarantee it against all unauthorized access, especially during online transmission. You are encouraged to use our Services in a secure environment.

What are your privacy rights?

In short: Depending on where you live, you may have specific rights over your personal data.

If you're located in the European Economic Area (EEA), United Kingdom (UK), Switzerland, Canada, or certain U.S. states, you may have rights including:

• Accessing your personal data
• Restricting or objecting to data processing
• Data portability
• Withdrawing consent where processing is based on consent

You can also request to review, update, or delete your account information at any time. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at: tutly.contact@gmail.com

Controls for DO-NOT-TRACK features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities

I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO

J. Education Information Student records and directory information NO

K. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO
L. Sensitive personal Information
NO

Category H. Audio, electronic, visual, and similar information The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

Your Rights You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon your state, you may also have:

• Right to access the categories of personal data being processed
• Right to obtain a list of the categories or specific third parties to which we have disclosed personal data
• Right to review, understand, question, and correct how personal data has been profiled
• Right to limit use and disclosure of sensitive personal data
• Right to opt out of the collection of sensitive data and data collected through voice or facial recognition

How to Exercise Your Rights
To exercise these rights, you can email us at tutly.contact@gmail.com

You may designate an authorized agent to make a request on your behalf. We may require proof of authorization and verify your identity.

Request Verification
We may need to verify your identity before processing your request. This may involve asking for additional information. If the request is submitted by an authorized agent, we may require written and signed permission from you.

Appeals
If we decline your request, you may appeal by emailing tutly.contact@gmail.com. We will inform you of our decision. If denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law
California residents may request information once per year, free of charge, about personal data disclosed to third parties for direct marketing purposes. To make such a request, contact us using the information in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”