Draft — for internal review only. Placeholders in brackets (e.g. [COMPANY_NAME]) must be replaced and this document reviewed by a lawyer before the site goes live.
Privacy Policy
Last updated: [DATE]
This Privacy Policy explains how [COMPANY_NAME] ("we") collects, uses, and protects personal data when you use Velbens, in accordance with the EU General Data Protection Regulation (GDPR).
Who We Are
The data controller is [COMPANY_NAME], registered at [COMPANY_ADDRESS]. For data protection questions, contact [SUPPORT_EMAIL].
Information We Collect
Account details (name, email, password hash), profile information tutors choose to share (bio, qualifications, photo), booking and payment records, messages exchanged on the platform, and basic usage data (device, browser, pages visited). For students, also a mobile phone number if you verify it by SMS.
How We Use Your Information
To operate bookings and payments, to match students with tutors, to review tutor profiles, to send service notifications (email verification, password resets, top-up receipts), to respond to support requests, and to improve the platform. Your phone number is used only to send the verification code and to protect the free trial lesson from abuse (one bonus per number); we don't use it for marketing.
Legal Basis for Processing
We process data to perform our contract with you (bookings, payments), to comply with legal obligations (tax, accounting), and, where applicable, based on your consent or our legitimate interest in operating and improving the platform.
Sharing Your Information
We share data with our payment processor to complete transactions, our hosting and database providers to run the platform, and public authorities where required by law. We do not sell personal data. To send SMS verification codes, we share your phone number with our provider Twilio Inc. (USA), which processes it only to deliver and check the code.
Data Retention
We retain account and booking data for as long as your account is active and afterward as required for tax, accounting, and dispute-resolution purposes, then delete or anonymize it.
Your Rights
Under GDPR you may request access to, correction of, or deletion of your data, object to certain processing, or request a copy of your data in a portable format. You may also lodge a complaint with the Latvian Data State Inspectorate (DVI). Contact [SUPPORT_EMAIL] to exercise these rights.
Children and Minors
Velbens serves school-age students. A parent or legal guardian must create and control the student account for any user under the age of digital consent in their country; tutors interact with minors only through lessons arranged and paid for via a guardian's account.
Cookies
We use essential cookies to keep you signed in and remember your language preference. We do not currently use third-party advertising or tracking cookies.
Security
We use industry-standard measures (password hashing, encrypted connections) to protect your data, but no system is completely secure. Report suspected security issues to [SUPPORT_EMAIL].
International Transfers
Our hosting and payment providers may process data outside the EEA under appropriate safeguards (such as Standard Contractual Clauses). This includes our SMS provider Twilio: phone numbers are processed in the USA under the EU Standard Contractual Clauses.
Changes to This Policy
We may update this policy from time to time; material changes will be announced on the platform.
Contact Us
For any privacy question, write to [SUPPORT_EMAIL].