1. Who is responsible for your data
BrainRamp is the data controller for the personal data described in this policy.
BrainRampEuropalaan 920
1363 BM Almere
Netherlands
Privacy contact: Raksha Sadashiva Reddy
Email: noreply@brainramp.org
Telephone: +31 6 2057 6931
Raksha Sadashiva Reddy handles privacy enquiries for BrainRamp.
2. Personal data we collect
We collect only the information reasonably needed to arrange and provide tutoring, manage accounts, communicate, and meet legal obligations.
Account and contact information
- Student and parent or guardian names and email addresses.
- Telephone number when provided, country, timezone, and account identifiers.
- Authentication information produced by our login provider. BrainRamp does not store account passwords.
Tutoring and learning information
- Subjects, curriculum, level or grade, learning goals, availability, and information included in signup messages.
- Lesson dates, attendance and status, Google Meet links, rescheduling requests, and related communications.
- Lesson reviews, ratings, comments, and limited internal notes used to provide and improve the service.
Billing information
- Agreed rate, currency, invoice details, lesson line items, payment status, and billing correspondence.
- BrainRamp currently accepts payment by bank transfer and does not collect payment-card details through this website.
Technical information
- Necessary authentication and portal-preference cookie values.
- Basic request, device, IP address, security, and error-log information processed by our hosting and infrastructure providers.
Information normally comes from the student, parent or guardian, account activity, or the systems used to deliver lessons. When a parent or guardian supplies a child's information, that person is the source of the child's data.
Please do not include health information or other sensitive personal data in free-text fields unless it is genuinely necessary for tutoring and you have first discussed it with BrainRamp.
3. How and why we use personal data
| Purpose | Typical data | GDPR legal basis |
|---|---|---|
| Responding to enquiries, registering accounts, and agreeing tutoring arrangements | Names, contact details, subjects, level, goals, availability | Steps requested before entering a contract and performance of a contract |
| Providing lessons, bookings, Google Meet invitations, rescheduling, and portal access | Account, contact, lesson, timezone, and scheduling data | Performance of a contract |
| Authentication, fraud prevention, service security, and troubleshooting | Account identifiers, cookies, IP and technical logs | Performance of a contract and BrainRamp's legitimate interest in operating a secure service |
| Invoices, payment administration, tax records, and accounting | Identity, lesson, rate, invoice, and payment-status data | Performance of a contract and compliance with legal obligations |
| Service administration, support, quality control, and handling disputes | Communications, lesson history, reviews, and relevant internal notes | Performance of a contract and legitimate interests in improving and protecting the service |
| Optional promotional updates | Name, email, and marketing preference | Consent, which can be withdrawn at any time |
| Establishing, exercising, or defending legal claims | Relevant account, communication, lesson, and payment records | Legitimate interests and, where applicable, legal obligations |
BrainRamp does not sell personal data. It does not use personal data for behavioural advertising, profiling, or automated decisions that produce legal or similarly significant effects.
Lesson feedback is used privately for service quality. BrainRamp will not publish a student's or parent's review as a testimonial without separate permission.
5. International data transfers
Some providers may process personal data outside the European Economic Area. Where a destination does not benefit from an EU adequacy decision, BrainRamp relies on an appropriate transfer mechanism such as the European Commission's Standard Contractual Clauses, together with supplementary safeguards where required. You may contact us for more information about the safeguard relevant to your data.
6. How long we keep personal data
- Enquiries and inactive leads: normally up to 12 months after the last meaningful contact.
- Account, tutoring, scheduling, reschedule, and review records: while the tutoring relationship is active and normally for up to 2 years afterwards, unless a longer period is needed for a dispute or a shorter period is appropriate.
- Invoices, payment records, and core business administration: 7 years, as generally required for Dutch business and tax records.
- Marketing preference: until consent is withdrawn or the information is no longer useful, with a minimal suppression record retained where needed to honour an opt-out.
- Authentication cookies: up to 7 days on an active session. The parent portal's selected-student preference lasts up to 30 days. A short-lived Google Calendar security cookie used by the administrator lasts up to 10 minutes.
- Technical logs and backups: retained for the shortest period reasonably needed for security, reliability, and recovery, then deleted or overwritten according to provider schedules.
When a retention period ends, data is deleted or anonymised unless continued retention is required or permitted by law.
7. Your GDPR rights
Depending on the circumstances, you may ask BrainRamp to:
- provide access to your personal data and a copy of it;
- correct inaccurate or incomplete data;
- delete data;
- restrict how data is used;
- provide data in a portable format;
- stop processing based on legitimate interests where your rights outweigh those interests; or
- withdraw consent at any time, without affecting earlier lawful processing.
Some rights are subject to legal conditions and exceptions. For example, BrainRamp may need to retain invoices even after an account is deleted. We may request information needed to verify identity before acting on a request and will normally respond within one month.
8. Children's and students' data
BrainRamp provides tutoring to students who may be under 18. A parent or legal guardian must create or authorise an account for a minor and must have authority to provide the student's information. Parents should explain this policy to the student in an age-appropriate way.
If a child's data was provided without appropriate authority, or any information is incorrect, contact Raksha Sadashiva Reddy so it can be investigated and corrected or removed where required.
9. How we protect data
BrainRamp uses measures appropriate to the service, including encrypted HTTPS connections, secure HTTP-only authentication cookies, access controls, role-based database policies, restricted private invoice storage, server-side secrets, and limited administrative access. No online service can promise absolute security. Please notify us promptly if you believe an account or personal data has been compromised.
11. Contact, complaints, and policy changes
For access, correction, deletion, consent withdrawal, or any concern about how data is handled, contact Raksha Sadashiva Reddy at noreply@brainramp.org or +31 6 2057 6931.
You also have the right to complain to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens, or another competent supervisory authority in the EU country where you live or work.
This policy may be updated when the service, providers, or legal requirements change. Material changes will be communicated through the website, account, or email where appropriate. The date at the top identifies the current version.