Privacy policy
Mulberry Square Tuition
Last updated: October 2026
1. Introduction
Elena Eaton-Anagnostou and Mulberry Square Tuition ("Mulberry Square Tuition", "we", "us" or "our") provide private tuition services in the United Arab Emirates ("UAE"). This Privacy Policy (this "Policy") explains how we collect, use, disclose, store and protect personal data when you visit our website www.mulberrysquaretuition.com, make an enquiry, or enrol a child for tuition services. This Policy also applies to potential tutors who may provide personal data in view of working with us.
This Policy is intended to reflect the requirements of UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and, to the extent our services or website are used by or directed at children, Federal Decree-Law No. 26 of 2025 on Child Digital Safety.
By using our website or engaging our tuition services, you acknowledge that you have read and understood this Policy. If you are a parent or guardian providing personal data on behalf of a child, you confirm that you are authorised to do so and to give the consents described below.
2. Who We Are and How to Contact Us
Mulberry Square Tuition is the controller of personal data processed in connection with our website and tuition services, as that term is used under the PDPL. For any questions, requests or complaints about this Policy or our handling of your personal data, please contact us at enquiries@mulberrysquaretuition.com.
3. Personal Data We Collect
We collect the following categories of personal data:
3.1 Enquiry and contact data: when you submit a contact or enquiry form on our website, we collect the first name, last name and email address of the person making the enquiry.
3.2 Student and parent/guardian records: when a child is registered for tuition, we collect information provided by a parent or guardian, including the child's name, age, school, year group and academic information (such as subjects, levels and progress notes) reasonably required to provide the tuition services.
3.3 Website usage, cookies and marketing data: when you browse our website, we and our service providers may collect data through cookies and similar technologies, including browsing behaviour, device and browser information, and information used for analytics and marketing purposes, as described further in the Cookies section below.
We do not knowingly collect personal data directly from children through our website. All information relating to a student is provided to us by, and collected through, the student's parent or guardian.
4. How We Use Personal Data
In accordance with the processing controls under the PDPL, we only process personal data for specific, clear purposes and limit the data collected to what is necessary for those purposes. We use personal data to:
4.1 respond to enquiries and communicate with parents, guardians and prospective tutors;
4.2 register students, arrange and deliver tuition sessions, and track academic progress;
4.3 manage our relationship with parents and guardians, including administrative and billing matters and manage our relationship with tutors;
4.4 operate, maintain, secure and improve our website;
4.5 send marketing communications about our tuition services, where we have an appropriate legal basis or consent to do so, and in accordance with any applicable UAE rules on electronic marketing communications; and
4.6 comply with legal and regulatory obligations in the UAE.
5. Legal Basis for Processing
Personal data may not be processed without the consent of the data subject (or, for a child, their parent or guardian), except in limited cases recognised under the PDPL. We process personal data on one or more of the following bases: (i) the consent of the parent, guardian or data subject; (ii) where processing is necessary to perform a contract/ engagement for tuition services or to take steps requested before entering into one; (iii) where processing is necessary to engage a tutor, (iv) where processing is necessary to comply with a legal obligation to which we are subject; or (v) where processing is necessary for our legitimate interests in operating and promoting our tuition business, provided this does not override the rights of the data subject. Where we rely on consent, that consent is sought in a clear, specific and easily accessible manner, and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
6. Children's Personal Data
Our students are children. All personal data relating to a student is collected from, and with the consent of, the student's parent or guardian, rather than directly from the child. Where our website or services are directed at or used by children (if so), we take account of the requirements of the Federal Decree-Law on Child Digital Safety, including obtaining documented and verifiable parental consent before collecting a child's personal data, providing a straightforward way to withdraw that consent, limiting access to the child's data to authorised staff on a need-to-know basis, and not using a child's data for targeted advertising or for purposes beyond those for which it was collected.
A parent or guardian may withdraw consent to the processing of their child's personal data, or request access to, correction of, or deletion of that data, at any time by contacting us using the details above.
7. Cookies and Similar Technologies
Our website uses cookies and similar technologies to operate the site, remember preferences, and understand how visitors use our website, including for analytics and marketing purposes. You can control or disable cookies through your browser settings; please note that disabling certain cookies may affect the functionality of our website.
8. Disclosure of Personal Data
We do not sell personal data. We may share personal data with:
8.1 tutors and staff providing tuition services, on a need-to-know basis;
8.2 service providers who support our website, IT systems, payment processing, or marketing activities, acting on our instructions and at our request;
8.3 professional advisers, where necessary for the operation of our business; and
8.4 government, regulatory or judicial authorities in the UAE, where required or permitted by law.
Any third party that processes personal data on our behalf does so under a written agreement requiring it to apply appropriate technical and organisational measures consistent with the PDPL.
9. Cross-Border Transfers
We primarily store and process personal data within the UAE. If personal data is transferred outside the UAE, including to a cloud or website service provider located abroad, we will only do so where the destination country or territory is recognised as maintaining an adequate level of data protection, where appropriate contractual safeguards are in place obligating the recipient to apply the protections required under the PDPL, where the data subject (or, for a child, their parent or guardian) has given explicit consent to the transfer, or where another basis for transfer recognised under the PDPL applies.
10. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to provide tuition services, maintain academic records, meet legal, accounting or regulatory requirements, and resolve any disputes. Where data is no longer required, we will delete it or anonymise it so that it can no longer be linked to an identifiable individual.
11. Data Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or destruction, taking into account the nature and sensitivity of the data we hold. In the event of a personal data breach that is likely to prejudice the privacy, confidentiality or security of personal data, we will take appropriate steps to investigate, contain and remedy the breach, and will notify affected individuals and, where required, the relevant UAE authority, in accordance with the PDPL.
12. Your Rights
Subject to the conditions and exceptions set out in the PDPL, you (or, in relation to a child's data, their parent or guardian) have the right to:
12.1 request information about the personal data we hold and how it is processed;
12.2 request a copy of personal data provided to us, in a structured and commonly used format, where technically feasible;
12.3 request correction of inaccurate or incomplete personal data;
12.4 request erasure of personal data in certain circumstances;
12.5 request that we restrict or stop processing personal data in certain circumstances, including for direct marketing purposes;
12.6 withdraw consent to processing at any time, without affecting the lawfulness of processing carried out before withdrawal; and
12.7 lodge a complaint with us, and, if unresolved, with the UAE Data Office.
To exercise any of these rights, please contact us at enquiries@mulberrysquaretuition.com. We may need to verify your identity, or your authority to act on behalf of a child, before responding to a request.
13. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or in applicable UAE law. The updated Policy will be posted on our website with a revised "Last updated" date. We encourage you to review this Policy periodically.
14. Contact Us
If you have any questions, concerns or requests regarding this Policy or our handling of personal data, please contact us at enquiries@mulberrysquaretuition.com.