Simones Tutoring FZE — Data Processing Agreement (DPA)

Last Updated: May 10, 2026

This Data Processing Agreement (“DPA”) forms part of the agreement between Simones Tutoring FZE (“Simones Tutoring,” “Processor,” “we,” “our,” or “us”) and the customer, school, institution, organization, business client, educational partner, or other entity (“Controller,” “Customer,” or “Partner”) using Simones Tutoring Services (“Services”).

This DPA governs the processing of personal data by Simones Tutoring on behalf of the Controller in connection with educational, tutoring, institutional, or platform-related Services.

This DPA is intended to support compliance with applicable data protection and privacy laws, including where relevant:

• The EU General Data Protection Regulation (“GDPR”);

• UK GDPR;

• UAE data protection laws;

• Other applicable privacy or educational data regulations.

1. Definitions

For purposes of this DPA:

• Controller means the entity determining the purposes and means of processing personal data.

• Processor means Simones Tutoring processing personal data on behalf of the Controller.

• Personal Data means information relating to an identified or identifiable individual.

• Processing means any operation performed on personal data, including collection, storage, access, use, disclosure, deletion, or transfer.

• Data Subject means the individual to whom personal data relates.

• Subprocessor means a third party engaged by Simones Tutoring to process personal data.

Terms not otherwise defined shall have meanings consistent with applicable data protection laws where applicable.

2. Scope and Applicability

This DPA applies where Simones Tutoring processes personal data on behalf of:

• Schools;

• Educational institutions;

• Organizations;

• NGOs;

• Districts;

• Ministries;

• Enterprise or institutional customers;

• B2B clients.

This DPA applies only to the extent Simones Tutoring acts as a Processor for Customer-controlled personal data.

3. Nature and Purpose of Processing

Simones Tutoring may process personal data for purposes including:

• Delivering tutoring and educational Services;

• Managing student enrollments;

• Facilitating online learning;

• Supporting educational programs;

• Managing accounts and communications;

• Providing customer support;

• Maintaining platform security;

• Conducting operational analytics;

• Supporting institutional or educational functions.

Processing activities may involve:

• Collection;

• Storage;

• Organization;

• Access;

• Transmission;

• Deletion;

• Archiving.

4. Categories of Personal Data

Depending on the Services used, personal data processed may include:

• Student names;

• Parent or guardian information;

• Contact information;

• Educational records;

• Attendance records;

• Session participation;

• Communications;

• Technical identifiers;

• Payment-related information;

• User account data;

• Audio or video participation data;

• Session recordings where applicable.

5. Categories of Data Subjects

Data subjects may include:

• Students and learners;

• Parents or guardians;

• Educators and tutors;

• Institutional personnel;

• Customer representatives;

• Platform users.

6. Controller Responsibilities

The Controller is responsible for:

• Ensuring lawful collection and sharing of personal data;

• Obtaining required consents or permissions;

• Providing appropriate privacy notices;

• Determining lawful processing purposes;

• Ensuring compliance with applicable laws;

• Responding to data subject requests where required.

The Controller represents that it has all necessary rights and permissions to provide personal data to Simones Tutoring for processing.

7. Processor Obligations

Simones Tutoring shall:

• Process personal data only as reasonably necessary to provide Services;

• Implement reasonable security measures;

• Restrict unauthorized access to personal data;

• Maintain confidentiality obligations for personnel;

• Assist with applicable data protection obligations where reasonably appropriate;

• Notify the Controller of confirmed security incidents where legally required.

Simones Tutoring may process personal data:

• Pursuant to documented instructions;

• As required for Service delivery;

• As required by applicable law.

8. Confidentiality

Simones Tutoring personnel with access to personal data shall be subject to:

• Confidentiality obligations;

• Access limitations;

• Security procedures.

Access to personal data shall be limited to personnel with legitimate operational or business needs.

9. Security Measures

Simones Tutoring maintains reasonable administrative, technical, and organizational safeguards intended to protect personal data.

Security measures may include:

• Encryption technologies;

• Access controls;

• Monitoring systems;

• Network protections;

• Backup procedures;

• Authentication requirements;

• Incident response procedures.

No security system can guarantee complete protection.

10. Subprocessors

Simones Tutoring may engage subprocessors to support Services, including providers related to:

• Cloud hosting;

• Video conferencing;

• Payment processing;

• Analytics;

• Customer support;

• Infrastructure management;

• Communication services.

Simones Tutoring shall take reasonable steps intended to require subprocessors to maintain appropriate security and confidentiality obligations.

The Controller acknowledges and authorizes the use of subprocessors necessary for Service delivery.

11. International Data Transfers

Because Simones Tutoring may operate internationally, personal data may be processed or stored outside the European Economic Area (“EEA”), United Kingdom, or United Arab Emirates.

Where applicable, Simones Tutoring may implement reasonable measures intended to support lawful international transfers, which may include:

• Contractual protections;

• Vendor safeguards;

• Security measures;

• Transfer mechanisms where appropriate.

12. Data Subject Requests

Where reasonably appropriate and operationally feasible, Simones Tutoring may assist the Controller with requests relating to:

• Access;

• Correction;

• Deletion;

• Restriction;

• Objections;

• Data portability.

The Controller remains responsible for responding to data subject requests unless otherwise agreed.

13. Incident Notification

In the event of a confirmed security incident involving personal data processed under this DPA, Simones Tutoring may:

• Investigate the incident;

• Take remediation measures;

• Notify the Controller where legally required or operationally appropriate;

• Cooperate regarding incident response efforts where feasible.

Notifications may depend on:

• Available information;

• Legal obligations;

• Severity of the incident;

• Operational considerations.

14. Data Retention and Deletion

Simones Tutoring may retain personal data for as long as reasonably necessary to:

• Provide Services;

• Maintain operational continuity;

• Comply with legal obligations;

• Resolve disputes;

• Maintain security and backups.

Upon termination of Services and subject to operational, legal, or backup requirements, Simones Tutoring may:

• Delete personal data;

• Return certain data where feasible;

• Retain limited information where legally required.

Additional information is available in our Data Retention and Deletion Policy.

15. Audits and Information Requests

Where reasonably necessary and subject to confidentiality, security, operational, and legal limitations, Simones Tutoring may provide:

• Security documentation;

• Policy information;

• Responses to reasonable compliance inquiries.

Formal audits or extensive security reviews may require:

• Separate agreements;

• Advance notice;

• Scope limitations;

• Confidentiality protections.

16. Limitation of Liability

To the maximum extent permitted by law, Simones Tutoring’s liability under this DPA shall be subject to limitations contained in the applicable Service agreements or Terms of Service unless otherwise agreed in writing.

Nothing in this DPA limits liabilities that cannot legally be limited under applicable law.

17. Term and Termination

This DPA remains effective while Simones Tutoring processes personal data on behalf of the Controller in connection with the Services.

Termination of the underlying Services or agreement may result in termination of this DPA, subject to applicable retention obligations.

18. Governing Law

Unless otherwise agreed in writing, this DPA shall be governed by the laws of the United Arab Emirates.

Parties may agree separately to additional jurisdictional or contractual requirements where applicable.

19. Changes to This DPA

Simones Tutoring reserves the right to update or modify this DPA periodically.

Updated versions become effective upon posting unless otherwise stated.

Continued use of the Services after updates constitutes acceptance of the revised DPA.

20. Contact Information

If you have questions regarding this Data Processing Agreement or data protection matters, please contact:

Simones Tutoring FZE

Dubai, United Arab Emirates
Email: info@simonesutoring.com
Website: https://www.simonesutoring.com

Important Notice

This document is provided for informational and operational purposes only and does not constitute legal advice.

Simones Tutoring should consult qualified legal counsel regarding:

• GDPR compliance;

• UAE data protection laws;

• Educational privacy obligations;

• International data transfers;

• School and institutional contracting requirements;

• Enterprise security and compliance standards.