Last updated 8th May 2026
Application Labs Limited, a company registered in England and Wales (No. 12238172) with our registered office at Regency House, Mere Park, Dedmere Road, Marlow, SL7 1FJ ("Sherpa" or "we"), operates the Sherpa Online platform at www.sherpa-online.com (the "Site"). We are committed to protecting your privacy and handling your personal data transparently and securely.
This Privacy Policy explains how we collect, use, protect, and share your personal information when you use our tutoring platform, whether you are a student, parent, guardian, school administrator, or tutor. We act as the data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Information We Collect
1.1 Information You Provide
To provide our tutoring services, we need to collect certain personal information from you. This information varies depending on whether you register as a student, parent, school administrator, or tutor.
Account Information
When you create an account, we may collect:
- Your name
- Email address
- Telephone number
- Postal address
- Date of birth
Tutor Application Information
If you apply to become a tutor, we may also collect:
- Educational background and qualifications
- Curriculum vitae (CV)
- Profile picture
- Teaching subjects and pricing
- Availability and scheduling preferences
- Identity verification documents (ID, proof of address, DBS check results where applicable)
- Gender
- Right to work documentation (for UK-based tutors)
Platform Activity Information
As you use our platform, we collect:
- Communication history with other users and our support team
- Booking details, including requests, confirmations, and lesson recordings
- Reviews and ratings (for tutors)
- Promotional codes and referrals you use or share
Payment Information
We use Stripe, a secure third-party payment processor, to handle all payment transactions. To process payments, we collect:
- For tutors: Bank account details (processed and stored by Stripe), invoices, and payment history
- For students: Payment history
Important: We do not store your payment card details on our servers. All payment card information is securely collected and stored by Stripe in accordance with Payment Card Industry Data Security Standards (PCI DSS). When you make a payment, Stripe processes your card details directly, and we only receive confirmation of the transaction.
Telephone call recordings
We may record telephone calls with users, tutors, and other third parties for training, quality assurance, dispute resolution, and safeguarding purposes. Where reasonably practicable, you will be informed that recording is taking place. By engaging with us by telephone, you acknowledge and consent to the possibility of recording as set out in this Privacy Policy.
Recordings are processed by our third-party telephony provider and may be retained for 3 years from the date of the call, after which they are permanently deleted. Where a recording relates to an active dispute or complaint, it may be retained until that matter is resolved and any applicable limitation period has expired.
1.2 Information We Collect Automatically
When you visit or use our Site, we automatically collect technical information to improve your experience and maintain security:
- Device information (type, operating system, browser)
- IP address and approximate location
- Pages visited and actions taken on our Site
- Date and time of visits
- Referring website or source of your visit
- Cookie data (see Section 5 for details)
1.3 Information from Third Parties
We may receive information about you from:
- DBS check providers when you authorize background verification
- Other Sherpa users who leave reviews or ratings
- Third-party services where permitted by law and with appropriate safeguards
2. How We Use Your Information
2.1 To Provide and Improve Our Services
We use your information to deliver the tutoring services you request:
- Creating and managing your account
- Matching students with suitable tutors
- Facilitating bookings and scheduling lessons
- Enabling communication between users
- Processing payments securely
- Providing lesson recordings and session summaries
- Offering customer support
- Improving platform functionality and user experience
2.2 For Safety and Security
We process your data to maintain a safe learning environment:
- Verifying tutor qualifications and identity
- Monitoring communications to fulfil safeguarding obligations
- Preventing fraud, spam, and inappropriate behaviour
- Ensuring quality standards are maintained
- Recording telephone calls for training, quality assurance, safeguarding, and dispute resolution purposes
2.3 For Marketing and Communications
With your consent or where we have a legitimate interest, we may use your information to:
- Send service updates and important account notifications
- Share promotional offers, discounts, and referral opportunities
- Conduct surveys to understand your needs better
- Personalize your experience with relevant content and recommendations
You can opt out of marketing communications at any time by clicking the unsubscribe link in our emails or emailing us at info@sherpa-online.com with "UNSUBSCRIBE REQUEST" in the subject line.
2.4 Legal Basis for Processing
Under UK GDPR, we process your personal data based on:
- Contract performance: Processing necessary data to provide our services to you
- Legitimate interests: Improving our services, fraud prevention, security, and marketing (where balanced against your rights)
- Your consent: For marketing communications and certain data sharing (which you can withdraw at any time)
- Legal obligations: Where required by law, such as safeguarding duties or financial reporting
3. Sharing Your Information
3.1 With Other Users
To enable tutoring services, certain information is shared:
- Tutor profiles are visible to all Site visitors and may include: first name and surname initial, profile picture, qualifications, grades, teaching subjects, pricing, and reviews
- When you request a lesson, tutors see your first name, surname initial, message content, and requested subject and level
- Messages between users may be monitored for safeguarding purposes
3.2 With Service Providers
We share limited personal data with trusted third-party providers who help us operate our platform:
- Stripe (our payment processor for secure transactions)
- Email and messaging services
- Analytics providers
- Identity verification services
- Customer support platforms
- Marketing and advertising platforms
- Telephony and call recording services
These providers are contractually obligated to protect your data and use it only for the purposes we specify.
3.3 For Legal Reasons
We may disclose your information when required by law or to:
- Comply with legal obligations or court orders
- Assist law enforcement investigations
- Protect the rights, property, or safety of Sherpa, our users, or others
- Enforce our terms and conditions
3.4 International Transfers
Some of our service providers are located outside the UK and European Economic Area (EEA), including in the United States. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:
- Standard contractual clauses approved by the UK Information Commissioner's Office
- Transfers to countries with adequacy decisions
- Other legally approved transfer mechanisms
You have the right to request details about these safeguards by contacting us.
4. Data Security
We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it:
- 128-bit SSL encryption for all data transmitted to and from our Site
- Secure servers with restricted access
- Regular security assessments and updates
- Employee training on data protection
Important: While we use our best efforts to protect your data, no internet transmission is completely secure. Email communications are not encrypted and should not be used for highly sensitive information. You transmit information at your own risk.
5. Cookies and Tracking
Our Site uses cookies and similar technologies to enhance your experience and support our operations. Cookies are small text files stored on your device that help us:
- Maintain your login session and preferences
- Provide customer support via live chat
- Monitor Site performance and debug issues
- Improve Site functionality
5.1 Types of Cookies We Use
- Strictly necessary cookies: Essential for Site operation, including security, account access, customer support, and performance monitoring. These cannot be disabled.
5.2 Tools We Use
We use the following tools on our Site:
- Intercom: We use Intercom to provide live chat customer support. Intercom sets cookies to maintain your chat session and conversation history so that our support team can assist you effectively.
- PostHog: We use PostHog to monitor Site performance, identify and debug technical issues, and improve the user experience. PostHog sets cookies to track your session and help us understand how the Site is being used.
5.3 Managing Cookies
You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our Site.
6. Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this policy:
- Active accounts: We retain data for six years after your last activity on the Site, allowing you to return and use your account throughout the typical user lifecycle
- Deleted accounts: After deletion or the six-year period, we remove your personal data unless we have a legal obligation to retain it longer
- Public content: Reviews, messages shared with other users, and booking records may remain on the Site but will be anonymized and no longer linked to your identity
- Legal requirements: Some records must be retained longer to meet regulatory or statutory obligations
7. Your Rights
Under UK GDPR, you have the following rights regarding your personal data:
7.1 Right to Access
You can request a copy of the personal data we hold about you, normally free of charge. To make a subject access request, email us at info@sherpa-online.com with the subject line 'Subject Access Request.'
7.2 Right to Rectification
You can request that we correct any inaccurate or incomplete personal data we hold about you.
7.3 Right to Erasure
You can ask us to delete your personal data where there is no good reason for us to continue processing it. To request deletion, email us at info@sherpa-online.com with the subject line 'Personal Data Deletion.'
7.4 Right to Data Portability
Where we process your data by automated means with your consent or for contract performance, you can request an electronic copy in a structured, machine-readable format to transfer to another organization. Email us at info@sherpa-online.com to request this.
7.5 Right to Withdraw Consent
Where we process your data based on your consent (e.g., marketing), you can withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal. Update your preferences in your account settings or contact us at info@sherpa-online.com.
7.6 Right to Object or Restrict Processing
You can object to processing based on legitimate interests or request we suspend processing in certain situations. Email us at info@sherpa-online.com with your concerns. Please note that exercising this right may impact our ability to provide services to you.
7.7 Rights Related to Automated Decision-Making
We use automated processing for:
- Screening tutor applications against our qualification criteria
- Monitoring messages to protect privacy
- Matching tutors with relevant student requests
- Determining tutor profile visibility based on activity
You have the right to request human review of automated decisions. Contact us at info@sherpa-online.com to exercise this right.
8. Children's Privacy
Our platform is used by students of all ages. Where students under 18 register for services, we require parental or guardian consent and involvement. We take extra care to protect the privacy and safety of minors using our platform through our safeguarding policies and monitoring procedures.
9. Third-Party Websites
Our Site may contain links to external websites. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before providing any personal information.
10. Google API Disclosure
Our application's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We only use your Google user data for the specific purposes for which it was collected and will not transfer this data to others except as explicitly stated in this Privacy Policy or for limited exceptions as required by law.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. When we make significant changes, we will notify you by email using the address associated with your account and by posting the updated policy on our Site with a new "Last Updated" date. We encourage you to review this policy periodically to stay informed about how we protect your information.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:
Email: info@sherpa-online.com
Postal Address: Application Labs Limited, Suite 2, Regency House, Mere Park, Dedmere Road, Marlow, SL7 1FJ, United Kingdom
Making a Complaint
We strive to handle all personal data in accordance with the law. If you are not satisfied with our response or believe we are processing your data unlawfully, you have the right to lodge a complaint with the UK data protection regulator:
Information Commissioner's Office (ICO)
Website: www.ico.org.uk
Telephone: 0303 123 1113
We encourage you to contact us first so we can address your concerns directly.