Privacy Policy

WATT E-School is committed to protecting your personal data. This Privacy Policy outlines our privacy commitments in a transparent and easily accessible way. We will ensure that all details will be safely kept.
We kindly ask you to read this Privacy Policy carefully before you submit your details, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services of WATT E-School, as defined in our Terms of Service. This Privacy Policy explains when, where, and why we process the personal data of people who use the WATT E-School Platform, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

GENERAL
Access to the WATT E-School Platform (including Website, related software and) is available with or without the necessity to register an account. You may access our Website without registration. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how WATT E-School works, look through the list of tutors, etc.). However, whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt out of cookies except those without which the Website cannot work.

When you are a registered user, WATT E-School may collect from you and process cookie identifiers and the data you specifically provide us with upon registration, including first name, last name, email, phone number, time zone, interface language, IP address, and device type.
Specifically, if you are a tutor, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip code, gender, year of birth, city of residence, and education experience.
Registered users may additionally provide profile pictures as well as chosen currency to perform actions pursuant to our Refund and Payments Policy.
You can find out more about the specific cases of data collection and the purposes of the processing of such data in a separate section of this Privacy Policy.

We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top of this page. Additional notifications on any amendments will be sent to your email.
We may also occasionally experiment with different features of the WATT E-School Platform which can affect the scope, purposes, or other details of the processing of personal data. In such cases we will provide prior notification and, if necessary, obtain your consent.
Any questions regarding this Policy and our services should be sent to support@watteschool.com.

1.   What Is Personal Data and the Processing of Personal Data?
 
Personal data is any information relating to you that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.
Processing of the personal data means any operation with your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; means you as a user of WATT E-School.

Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2.   WATT E-School’s Lawful Bases for Processing
WATT E-School processes your personal data only when we have lawful bases. Specifically, WATT E-School     processes your personal data if:
•       processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, analysis of video lessons, your participation in our events and webinars, and placement of different types of cookies, and posting of the sweepstakes winners is based on your consent;

•       processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of WATT E-School; in particular, this concerns enhancing the learning experience for tutors and students by providing personalized recommendations, improved lesson planning, and interactive learning tools;

•       processing is based on the explicit consent you have given to us and our online verification provider to process your biometric information for the purposes of tutor identity verification and fraud identification;

•       processing is necessary for the purposes of our legitimate interests. Those legitimate interests may include but are not limited to:

-       the assessment of WATT E-School’ business efficiency by analyzing the WATT E-School Platform traffic and financial performance indicators;

-       promotion of WATT E-School through social media networks, media outlets, referees; this in particular concerns the right of WATT E-School to use the tutor’s name, profile picture and other details for marketing, advertising or promotional purposes pursuant to the Terms of Service;

-       performance of the contracts with WATT E-School Business customers and provision of reports on their employees’ and contractors’ language learning progress and results of language assessment tests;

-       user session control and fraud prevention, ensuring the appropriate protection of personal data;

-       tutor verification and development of high-quality learning programs with tutors;

•       where necessary, compliance with applicable legislation (e.g., data subject request processing);

•       in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

In all cases, we will notify you about the applied legal basis for processing and other relevant details before we start the processing of your personal data on a specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.

 
3.   Data We Collect: Scope
 
WATT E-School collects from you only the following information and only for the stated below purposes;

(1)  Account for Students
WATT E-School collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For registration purposes, you submit your login credentials (username and password), first name, last name, and email. You may also edit your Account anytime with additional information and WATT E-School Calendars. Such additional information may help you to find a suitable time slot with a tutor or to have more visibility of your schedule. At the same time, you are not required to provide additional information not specifically necessary for the registration; it is your choice.

(2)  Account for Tutors
WATT E-School collects and processes personal data submitted by you upon registration and further editing of your profile. For registration purposes, you submit your login credentials (username and password), first name, last name, and email. You may also edit your profile anytime with additional information as well as sync your Google and WATT E-School Calendars. Such additional information may help you to find a suitable time slot with a student or to have more visibility of your schedule. At the same time, you are not strictly required to provide additional information not specifically necessary for the registration. Therefore, it is your choice whether to include additional data in your profile, or not, such as zip code, country, language skills, education, and work experience.

Some personal data, such as users’ names and location, that is listed in your user profiles or derived from IP addresses may be publicly visible to other users on the Services or to the web. We may implement a feature that permits you to choose what information is made public by changing your privacy setting in “Edit My Profile” within the Service.

 (3)  Subscription to the WATT E-School Blog
You may decide to subscribe to the WATT E-School Blog to receive newsletters and updates from the WATT E-School Blog. For this, we require you to give us your email.

(4)  Posting of Information
We process personal data freely submitted to you on WATT E-School. This may be a survey and online form you fill in on WATT E-School, a question or comment left in the Q&A section of our Website, or feedback you provide us with.
WATT E-School may also process information provided by you (including content and messages) that you post on/through the WATT E-School Platform, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to WATT E-School and to other users of the Services (students/tutors). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the Lessons created by you and used by other users (students/tutors).

From our turn and unless you opt out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service.

(5)  Service Use, Cookies and Other Similar Technologies
When you use our Services, we monitor and analyze web traffic and keep track of your behavior.

Please refer to our Cookie Policy for further details as to our use of cookies and similar technologies.

(6)  Billing Information
We process the details of transactions you carry out through the WATT E-School Platform (such as ID, date and time of transaction).

(7)  Sensitive Data
Unless you expressly agree, WATT E-School does not process your sensitive data.

(8)  Pages on Social Networks
We maintain WATT E-School’ official pages on social networks, such as Facebook, TikTok, Instagram and LinkedIn. When you interact with WATT E-School’ official pages in social networks, such as subscribing to the pages or leaving comments or reactions (e.g., ‘like’ our posts), we can analyze this data to measure our efficiency and conduct an analysis of our social media marketing campaigns in our legitimate interests.

(9)     Tutors Community (for Tutors Only)
We maintain a Tutors Community which can be accessed via oltag.watteschool.com. To fulfill purposes specified under subsection (10) of section (4) of this Privacy Policy, we will also collect and process your interaction data and usage data within the Tutors Community.

(10) Tutors Learning Portal (for Tutors Only)
By registering as a tutor, you will be able to access our Tutors Learning Portal i.e. wattelive.watteschool.com and take various courses to gain new skills, improve your methodology, boost your ranking and get the most out of the WATT E-School Platform. Information Required for Submitting Tax Documentation

To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For example, a Ghana Revenue Authorities tax form or such other required tax form(s) necessary to receive a tax clearance certificate from the GRA. For submitting tax documentation, we may process your personal data, including, but not limited to, your full name, country of citizenship, permanent residence address, mailing address, date of birth, taxpayer identification number, or foreign tax identifying number.

To comply with our reporting obligations, we may process your first name, last name, primary address, date of birth, tax identification number (TIN), VAT number, and financial account identifier (e.g., bank account).

(11)  Information Required for Marketing and Promotion
We may collect the tutor’s postal address to promote the Tutoring Services that you provide via the WATT E-School Platform and help you reach more prospective students looking for Tutoring Services within a certain geographical area.

(12)  Analysis of Speech Activity
When you give/take lessons on the WATT E-School Platform, we may analyze your microphone activity and measure the volume of the sound. We do it to provide you with an overview of your speaking activity and to let you know how active you were during the lesson.

(13)  Language Assessment
We process your personal data to assess your level of language proficiency. For this, we may additionally process your name, email address, and the results of your language assessment. Such an assessment may take place before or after you register on the WATT E-School Platform.

(14)  Tutor Verification (for Tutors Only)
We process your education credentials (we have engaged a third-party online verification provider for this purpose) and your school certificates to verify your credentials and identify fraud.

 4.   Data We Collect: Purposes
 
We may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of WATT E-School to the fullest extent possible and to provide you with high-quality Services under the Terms of Service.

 (1)  Provision of Services
Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a tutor or a student) find your account or profile, schedule, give and/or take lessons, and track your learning progress.

In order for you to use the Services, you will need to provide payment (e.g. credit card details) and billing information through our partners – third-party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information.

We may also ask you to take a language assessment test in order to establish your level of language proficiency.
For companies using the WATT E-School Business Services, we process the personal data of their Authorized Users to create their accounts, enable access to the Services, provide language assessment, language learning progress reports and results of language assessment tests.

Please note that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of WATT E-School Platform, connect you with other users, allow you to communicate with them and take/give lessons.

(2)  Payment Services
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more lessons is safe in your account as we use an integrated iframe for checkouts from our partners-payment provider (PayStack) and tutors get the payment for each confirmed lesson securely through third-party payment providers (PayStack). Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. All payment information is stored encrypted and securely by PayStack service. We do not store your payment information on our servers.

(3)  Referral Programs
For our “Tell-A-Friend” referral program, we generate a personalized referral link for you to share with your friends to sign them up. We will not collect your friend’s personal data until they follow the link and access the WATT E-School Platform.

For our B2B referral program, you will be able to share the name, job position and email of your colleagues who may be interested in WATT E-School Business Services. We will inform your colleagues that we’ve received their personal data in the course of our referral program at the time of initial contact.

(4)  Communications
We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, WATT E-School updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through WATT E-School, including exchanging messages, conducting video calls, and/or leaving feedback about other users.

Having received the communications from us, you are always able to opt out of such communications in each message, excluding legal notices, essential reminders/notifications or changes of user settings on WATT E-School.

(5)  User Research
Your contact data (including email, phone number, Skype name, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:

- Feature development and product updates;

- Marketing activities, including publishing them on WATT E-School on other information resources;

- Customer Support updates;

- Other service updates for improving your experience.

Your feedback will not be video recorded, audio recorded, or webcast by the interviewer without obtaining consent from you first. The same applies to your voice and/or image recording.

(6)  Marketing and Promotion of WATT E-School
We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. But don’t worry. We will request your consent first, and you may always opt out of our marketing messages using the mechanisms described under the respective link in each message and through the user settings available on WATT E-School.

If you provide us with your phone number, we may also contact you with some commercial or promotional information about our Services.

To promote the WATT E-School Platform through the blog and influencer channels, we allow individuals to participate in the affiliate program on our Website. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of the WATT E-School Platform.

Also, please pay attention that we may use the information provided by you as feedback. The latter, under Section 12 of the Terms of Service, may be used by WATT E-School without any additional compensation to you.

(7)     Tutor Verification and Program Preparation
To ensure a high quality of lessons given by tutors on WATT E-School, we collect and process tutor credentials to verify their eligibility to teach subjects claimed by them. Besides that, we cooperate with the tutors and use their information to help them develop learning programs.

(8)  Licensure Verification (For Ghanaian)

We process your teaching documents (we liaise with the National Teaching Council) to verify the authenticity of your Licensure Certificate to ensure that you have been authorized by the NTC to teach.

In order to verify tutor identity and identify fraud, we process tutors’ biometric information and ID.

(9)     Support and Platform Supervision
In case of any disputes on WATT E-School and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the WATT E-School Platform, and respond to any complaints or requests.

(10)  Events and Webinars Conducted by WATT E-School
We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events or webinars, as well as to send you registration confirmation, reminders, associated useful materials or the information you have requested about our Services.

(11)  Compliance with Legal Requirements
We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the WATT E-School Platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

(12)  Fraud Prevention
Certain information, such as your log information, payment information and your behavior on the WATT E-School Platform are subject to our supervision to prevent fraudulent activities and assist you in managing your user sessions.

(13)  Changes
We may change the WATT E-School Privacy Policy from time to time. Upon any changes to this Policy, your rights may not be reduced unless you provide explicit consent. The latest version is posted on this page. If we make substantial changes, we will notify you by sending an email.

5.   How Is Personal Data Shared?
 
In order to provide high-quality services, WATT E-School hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under data processing agreements (DPA). For those reasons, some of your personal data can be passed to the persons mentioned. WATT E-School uses only secure places of storage.

(1)  Categories of Third-Party Service Providers
●    Analytics services

Personal data shared with this category of third-party service providers may include the information described in subsections 5 and 14 of section 3 of this Privacy Policy.

 ●   Social network platforms and search engines

Personal data shared with this category of third-party service providers may include the information described in subsection 7 of section 4 and subsection 2 of section 5 of this Privacy Policy.

●     Customer communication solutions

Personal data shared with this category of third-party service providers may include the information described in subsection 4 of section 3 of this Privacy Policy.

●    User research tools

Personal data shared with this category of third-party service providers may include the information described in subsection 5 of section 4 of this Privacy Policy.

●    Services to manage emails and send out push notifications

Personal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.

 ●   SMS providers for mobile marketing and notifications

Personal data shared with this category of third-party service providers may include your contact details and the personal identifiers you provide to us.

 ●   Payment services providers

Personal data shared with this category of third-party service providers may include the information described in subsection 6 of section 3 of this Privacy Policy.

●   Providers of video conferencing, speech-to-text, and conversation analytics tools Personal data shared with these categories of third-party service providers may include the information described in subsection 16 of section 3 of this Privacy Policy.

●   Influencer marketing solution providers to identify and engage influencers

Personal data shared with this category of third-party service providers may include your name and other identifiers described in subsections 1 and 2 of section 3 of this Privacy Policy.

●   Language assessment tools

Personal data shared with this category of third-party service providers may include the information described in subsection 15 of section 3 of this Privacy Policy.

●  Services to manage Tutors Academy

Personal data shared with this category of third-party service providers may include the information described in subsection 11 of section 3 of this Privacy Policy.

●  Services to manage Tutors Community

Personal data shared with this category of third-party service providers may include the information described in subsection 10 of section 3 and subsection 10 of section 4 of this Privacy Policy.

●  Online verification providers

Personal data shared with this category of third-party service providers may include the information described in subsection 18 of section 3 of this Privacy Policy.

●   Tax and accounting compliance software providers

Personal data shared with this category of third-party service providers may include the information described in subsection 12 of section 3 of this Privacy Policy.

(2)  Use of Social Network Platforms
We use social network platforms like Facebook, Instagram, LinkedIn, and TikTok to maintain WATT E-School’ social media pages.

You may contact us with any questions related to your activity on WATT E-School’ social media pages on the above-mentioned social network platforms or our processing of your personal data.

The service providers mentioned under subsections 1 and 2 will help us to ensure that your data is secure within WATT E-School.

 (3)  Data Transfer in Case of Change of Control or Asset Disposition
In the event of any merger, acquisition, sale or change of control, we’ll continue to ensure the confidentiality of your personal data and give affected users notice before personal data is transferred or becomes subject to a different privacy policy.

(4)  Companies Using WATT E-School Business Services
We may share the Authorized Users’ language learning progress and results of language assessment tests with their respective employers.

(5)  WATT E-School Independent Contractors
We work with independent contractors who help us provide you with our Services. Specifically, we may engage such contractors to assist us with data analytics and software development, customer support, promotion, marketing, user research, as well as financial and legal matters. These contractors will only have access to your personal data on the need-to-know basis and under strict privacy and security obligations.

 (6)  Other Users of the WATT E-School Platform
Your personal data may also be made visible to visitors and users of the WATT E-School Platform. This can happen via personal contacts (between student and tutor), or in connection with the social features of the WATT E-School Platform. For example, your profile picture and name may be visible if you have signed up for a group class or if you left a tutor review.

6.   How Long Will the Personal Data Be Processed and Stored by WATT E-School?
 Your personal data will be stored by WATT E-School for no longer than necessary for the purposes for which the personal data is processed.

Generally, WATT E-School retains your personal data as long as your account is active. If your last activity on WATT E-School was more than 2 years ago, your account will be considered expired. In this case or when you decide to delete your WATT E-School account, we undertake to remove your personal data from our active systems and servers within 90 days or earlier.

However, in case of conflict situations in progress, WATT E-School may retain your personal data for longer in order to be able to establish, exercise or defend legal claims. Upon the settlement of the conflict situation, all personal data gets deleted if the standard retention period has expired.

We may also retain some of your personal data for longer if we need it to comply with the applicable legal, regulatory, tax, accounting or other requirements.

7.   Your Rights as Data Subject Regarding Your Personal Data WATT E-School Processes
 
(1)  Right of Confirmation

You can obtain confirmation from WATT E-School as to whether personal data concerning you is being processed.

(2)  Right of Access
You can access your personal data processed by WATT E-School.

 (3)  Right to Rectification
You can ask WATT E-School to have incomplete personal data requiring corrections completed.

(4)  Right to Erasure (Right to Be Forgotten)
You can request WATT E-School to erase personal data. In most cases, WATT E-School will erase it unless otherwise required by legislation.

 To delete your personal data, you can:
 
•       Contact us by email at support@watteschool.com. We will respond to your request to delete your information within 30 days and notify you of the outcome.

(5)  Right of Restriction of Processing
You can contest the accuracy of your personal data or in case WATT E-School is not interested in processing your personal data any longer, but you want WATT E-School to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.

(6)  Right to Data Portability
You can have your personal data transmitted directly from one controller to another where technically feasible, and when doing so does not adversely affect the rights and freedoms of others.

 (7)  Right to Withdraw Consent at any Time by Contacting Us
After we at WATT E-School receive a withdrawal request from you, we will process it in a timely manner, and we will no longer process your personal data unless otherwise set by law.

If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

These requests are free of charge.

 If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.

 8.   Other Privacy Commitments
 
(1)  Cross-border Transfers

We process your personal data both within Ghana and outside Ghana. Although countries where we process data may have different laws, we take measures to ensure high standards of data privacy and compliance (namely, as provided in Section 5 of this Privacy Policy).

(2)  Security
WATT E-School takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage. For example, WATT E-School uses verified contractors that might have access to the data with which the relevant data processing agreements are signed.

 (3)  Accessing Account to Provide Support
In exceptional circumstances, such as required customer support, our support specialists may need to access your account. When such an occasion occurs, they will be able to see the personal data submitted to your account, including your scheduled personal events, if your Google Calendar and WATT E-School Calendar are connected.

 Please note that if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.

(4)  Children’s Privacy
The privacy of children is one of our concerns. WATT E-School Services are not intended for use by children under the age of 18 without the supervision of their parent or legal guardian. If you are under the age of 18 but not less than the age of 13, you will need to ask your parent/legal guardian to set up an account on the WATT E-School Platform that you may use under their supervision.

We do not knowingly collect information from children under the age of 13 and discourage the use of WATT E-School Services by children under this age. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide information on the WATT E-School Platform without their permission.

(5)  Breach Notifications
If there is a personal data breach that is likely to result in a high risk of adversely affecting your rights as the data subject, we would inform you and the respective data protection agencies as to the accidents without undue delay. We would also do our best to minimize any such risks.

(6)  “Do Not Track” Requests
WATT E-School does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.

(7)  Automated Decision-Making and Profiling
As a part of the WATT E-School Platform functionality, we process the personal data of our tutors and students in a way that might be considered profiling.

(8)     Sale of Personal Data
We do not sell your personal data and the personal data of any minors under 16 years of age.

 (1)  Disclosure of Personal Information to Law Enforcement Officials
 
WATT E-School, may disclose your personal information to the extent required by law or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by government or law enforcement officials or private parties, including to meet national security or law enforcement requirements).

9.      Legal Matters
 
WATT E-School considers your use of the Services to be private. However, we may disclose your personal data stored in our databases in order to:
(1)  comply with the law or legal process served on us;

(2)  enforce and investigate potential violations of this Privacy Policy; including the use of the Services to participate in or facilitate activities that violate the law;

(3)  investigate potential fraudulent activities; or

(4)  protect the rights, property, or safety of WATT E-School, its employees, customers or the public.

We hope this Privacy Policy helps you to understand how your personal data will be dealt with here at WATT E-School. We will take care of your personal data, so you can use our Services and not be concerned about your privacy. Should you have any questions, e-mail us at support@watteschool.com.

Your WATT E-School Team