Privacy policy

01Who We Are

Data Controller:
WAGMI SOLUTIONS LTD (trading as LernaSync)
128 City Road, London, United Kingdom, EC1V 2NX
Email: privacy@lernasync.com

Data Protection Officer:
Email: dpo@lernasync.com

We are registered with the Information Commissioner's Office (ICO).
ICO Registration Number: [Pending Registration]

02Legal Basis for Processing

We process your personal data under the following legal bases:

03Personal Data We Collect

3.1All Users

• Identity Data: Full name, username
• Contact Data: Email address, phone number (optional)
• Account Data: Password (encrypted), account preferences
• Technical Data: IP address, browser type, device information
• Usage Data: How you interact with our platform

3.2Students

• Educational Data: Grade level, subjects, academic progress
• Assignment Data: Homework submissions, grades, feedback
• Attendance Data: Session attendance records
• Date of Birth: For age-appropriate services (optional)

3.3Parents

• Relationship Data: Linked student accounts
• Contact Preferences: Communication settings

3.4Tutors

• Professional Data: Qualifications, subjects taught, bio
• Performance Data: Session history, student feedback

3.5Administrators

• Organization Data: School/company details
• Management Data: User management activities

04How We Use Your Personal Data

We use your personal data to:

• ✅ Provide and manage tutoring services
• ✅ Facilitate communication between tutors, students, and parents
• ✅ Track academic progress and assignments
• ✅ Schedule and manage tutoring sessions
• ✅ Send important platform notifications
• ✅ Improve our services through analytics
• ✅ Ensure platform security and prevent fraud
• ✅ Comply with legal obligations
• ✅ Send marketing communications (with your consent)

05How We Share Your Personal Data

5.1Within Your Organization

Your data is shared with:

• Tutors: Can see assigned students' academic data
• Parents: Can see their children's progress and assignments
• Administrators: Have access to manage users and data within their organization

5.2Third-Party Service Providers

We share data with:

All third-party providers are contractually required to protect your data and only process it according to our instructions.

5.3Legal Requirements

We may disclose your data if:

• Required by UK law or court order
• Necessary to protect our rights or property
• To prevent fraud or security threats

5.4International Transfers

Some of our service providers are located outside the UK. When we transfer your data internationally, we ensure adequate protection through:

• ✅ Standard Contractual Clauses (SCCs) approved by the ICO
• ✅ Adequacy decisions (for transfers to approved countries)
• ✅ Data Processing Agreements requiring equivalent protection

06Your Data Protection Rights (UK GDPR)

Under UK data protection law, you have the following rights:

6.1Right of Access (Subject Access Request)

Request a copy of the personal data we hold about you.

6.2Right to Rectification

Request correction of inaccurate or incomplete personal data.

6.3Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data in certain circumstances.

6.4Right to Restrict Processing

Request that we limit how we use your personal data.

6.5Right to Data Portability

Receive your personal data in a structured, machine-readable format.

6.6Right to Object

Object to processing based on legitimate interests or for direct marketing.

6.7Rights Related to Automated Decision Making

You will not be subject to automated decisions that significantly affect you without human review.

How to Exercise Your Rights:

• Email: privacy@lernasync.com
• Use the in-app "Privacy Settings" page (coming soon)
• Written request to our address above

We will respond within one month of receiving your request.

07Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations.

After the retention period, we securely delete or anonymize your data.

08Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• ✅ Encryption: Data encrypted in transit (HTTPS/TLS) and at rest
• ✅ Access Controls: Role-based access and row-level security
• ✅ Authentication: Secure password requirements and session management
• ✅ Audit Logs: Comprehensive logging of data access
• ✅ Regular Testing: Security assessments and vulnerability testing
• ✅ Staff Training: Regular data protection training
• ✅ Incident Response: Data breach procedures in place

09Cookies and Similar Technologies

We use cookies to improve your experience. See our separate Cookie Policy for details.

Essential Cookies: Required for platform functionality (no consent needed)
Analytics Cookies: Help us understand usage (requires consent)
Marketing Cookies: Currently not used

You can manage cookie preferences in your browser settings or our cookie banner.

10Children's Privacy (Under 13)

While UK GDPR does not set age 13 as a specific threshold for online services, we take extra care with younger children's data:

• ✅ We collect minimal data from children
• ✅ Parents can access and control their children's data
• ✅ Children's data is never used for marketing
• ✅ We provide age-appropriate privacy notices

Parental Rights:
Parents can request access to, rectification of, or deletion of their child's data at any time.

Age-Appropriate Services:
Our services are designed to be educationally appropriate and safe for all ages.

11Educational Records

For users in educational settings:

• Educational records are protected with appropriate access controls
• Only authorized personnel (tutors, administrators) can access student records
• Parents have the right to access their children's educational records
• Records are retained in accordance with UK education guidelines

12Automated Decision Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

If we introduce such processing in the future, we will:

• Inform you in advance
• Obtain your consent where required
• Provide an opportunity for human review

13Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for high-risk processing activities to ensure your rights are protected.

14Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Email notification
• Prominent notice on our platform
• Requiring re-consent where legally required

Current Version: 1.0
Last Updated: 1 February 2026

15Complaints and Contact

Contact Our Data Protection Officer:

Email: dpo@lernasync.com
Address: WAGMI SOLUTIONS LTD, 128 City Road, London, EC1V 2NX

Lodge a Complaint with the ICO:

If you believe we have not handled your data properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/

16Legal Framework Summary

This Privacy Policy complies with:

• ✅ UK General Data Protection Regulation (UK GDPR)
• ✅ Data Protection Act 2018
• ✅ Privacy and Electronic Communications Regulations (PECR)
• ✅ Children's Code (Age Appropriate Design Code)
• ✅ Equality Act 2010 (for educational accessibility)

Questions? Contact us at privacy@lernasync.com

Your privacy matters to us. We are committed to protecting your personal data and respecting your rights under UK law.