Privacy Policy

Last Updated: August 28, 2026

Welcome to FocalTutor. We respect your privacy and are committed to protecting your personal data. This Privacy Policy is governed by the laws of the United Arab Emirates (UAE), specifically the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), as our operations are based in Dubai, UAE.

1. Data Controller Identity

FocalTutor (the "Controller") determines the purposes and means of the processing of your personal data. If you have any privacy-related concerns, you can contact us via our Contact Us page.

2. Personal Data We Collect

• Identity Data: Name, username, profile picture.
• Contact Data: Email address, physical location (city/country).
• Educational Data: Subjects of interest, academic levels, language preferences.
• AI Interaction Data: Prompts, queries, and chats submitted to our AI tools (e.g., AI Study Buddy, AI Content Generator).

3. Lawful Basis and Purpose of Processing

We process your data based on the following legal grounds under the PDPL:

• Consent: Where you have provided explicit consent for us to process your data for specific purposes (e.g., AI matchmaking).
• Performance of a Contract: To deliver the tutoring services you request.
• Legitimate Interests: To improve our platform, security, and AI models, provided these interests do not override your fundamental rights.

4. Third-Party Sharing & Cross-Border Transfers

We do not sell your personal data. We may share data with trusted third-party service providers (such as hosting partners and AI processing APIs like OpenAI/Gemini) strictly to facilitate our services. If your data is transferred outside the UAE, we ensure appropriate safeguards are in place in compliance with the PDPL, such as standard contractual clauses.

5. Your Data Subject Rights

Under the UAE PDPL, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request erasure of your personal data ("Right to be Forgotten").
• Restriction: Request restriction of processing your data.
• Withdraw Consent: Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

6. Data Security and Breach Notification

We implement robust technical and organizational measures to secure your data against unauthorized access. In the unlikely event of a data breach compromising your privacy, we are committed to notifying the UAE Data Office and affected individuals as required by law.