Terms of Service

Introduction

These Terms of Service (the Terms) are the agreement between Instructor Buddy Limited, a company registered in England and Wales with company number 17478231, whose registered office is at 3 Weekley Wood Close, Kettering, Northamptonshire, United Kingdom, NN14 1UQ (we, us, our), and the driving school or self-employed driving instructor that subscribes to the Instructor Buddy service (you, your).

Please read these Terms carefully before using Instructor Buddy. By creating an account, accepting an invitation to join a school's account, or subscribing to Instructor Buddy, you agree to these Terms. If you do not agree to them, do not use the service.

These Terms apply to the driving school or instructor who subscribes to Instructor Buddy. Learner drivers, and members of the public who contact a driving school through the service, are not parties to these Terms. They have no agreement with us, and nothing in these Terms creates one.

These Terms are for business customers. You confirm that you are subscribing for the purposes of your trade or profession and not as a consumer.

Instructor Buddy is offered in the United Kingdom only. It is built for UK driving schools teaching UK learner drivers.

1. Who we are and what we provide

1.1 About Instructor Buddy

Instructor Buddy provides an AI-powered assistant for driving schools and driving instructors. The service helps you respond to enquiries from learner drivers through supported communication channels.

Depending on the features enabled on your account, Instructor Buddy may:

• Answer enquiries from learner drivers;
• Provide information about your prices, working hours, the areas you cover, your cars and the transmission types you teach in;
• Ask a learner the questions you would ask them yourself, and record the answers;
• Check your diary and identify lesson slots that are genuinely free;
• Propose a slot to a learner and, depending on the setting you choose, either pencil it in for your approval or book it;
• Tell a learner how to pay you, after a lesson has been confirmed;
• Email you when it hands a conversation back to a person; and
• Connect to supported third-party services such as Google Calendar.

The exact features available may change from time to time. We may add, alter or withdraw features, and some features may be released gradually or only to some customers.

1.2 How the service is delivered

Instructor Buddy is a web application, designed to be used on a phone. It is reached through a web browser. It is not distributed through the Apple App Store or Google Play, and no separate app needs to be installed.

You are responsible for the device, internet connection and browser you use, and for any charges your network operator makes.

1.3 Who approves a booking

Instructor Buddy offers more than one booking setting, and you choose which one applies to your school:

• Ask first. The assistant proposes a slot and pencils it in. It does not become a lesson until an instructor approves it. Nothing enters your diary without a person agreeing to it.
• Book it in. The assistant confirms the slot with the learner itself and writes the lesson straight into your diary. No person approves it at the time it is made.
• I qualify. You book. The assistant asks the learner every qualifying question and emails you their details. It does not offer a time and it does not write anything into your diary — you book them in yourself.

If you choose book it in, you are instructing the assistant to make bookings on your behalf without a person checking each one first. You remain responsible for those bookings, for the settings that produce them, and for keeping your working hours, availability and connected calendars accurate.

1.4 The assistant identifies itself

The assistant introduces itself to every learner, on its first message, as an AI assistant acting for your driving school. We will not present it as a human being, and you must not ask us to, or represent to learners that they are talking to a person when they are talking to the assistant.

1.5 What the assistant cannot be relied on to do

AI-generated responses may occasionally be inaccurate, incomplete, outdated or inappropriate. We do not guarantee that:

• The assistant will respond correctly to every enquiry;
• The assistant will understand every message;
• The assistant will always provide accurate information;
• Every enquiry will result in a booking;
• Every proposed lesson will be suitable;
• The service will identify every available lesson slot; or
• The assistant will always recognise when a conversation should be handed to a person.

You should monitor the service, read the conversations it is having, and correct information where necessary.

1.6 Limits on use

We apply reasonable limits on how many messages the assistant will send, per learner and per account, to protect the service and to stop a fault producing a flood of messages.

2. Accounts

2.1 Who can create an account

You may create an Instructor Buddy account if you are aged 18 or over and either authorised to enter into a contract on behalf of a driving school, or using the service as a self-employed driving instructor. You must provide accurate and up-to-date information when creating your account.

2.2 Your information must be accurate

You are responsible for ensuring that the information you give Instructor Buddy is accurate, including your name, email address, driving school name, prices, working hours, areas covered, vehicles, transmission types, cancellation notice period, availability, payment method and any bank details you enter.

The assistant answers from what you tell it. If a price, an area or a set of working hours is wrong in your settings, the assistant will state it to a learner as fact. We are not responsible for problems caused by information you provide incorrectly or fail to update, including a lesson quoted at the wrong price or offered in an area you do not cover.

2.3 Signing in, and keeping your account secure

Instructor Buddy does not use passwords. You sign in by entering your email address and following a single-use link that we email to you. This means the security of your Instructor Buddy account is the security of your email account. You must:

• Keep your email account secure, and use a strong password and two-factor authentication on it;
• Not forward a sign-in link to anyone else, and not let anyone else use your account;
• Keep your device locked; and
• Tell us as soon as reasonably possible if you believe someone has accessed your account without permission, by emailing info@instructorbuddy.co.uk.

2.4 Owner and instructor accounts

A driving school account has one owner and may have any number of instructors invited by that owner. The owner is responsible for:

• Who they invite, and confirming that each invited instructor is authorised to use the service;
• Everything done under the account, including by invited instructors;
• Removing an instructor's access when they are no longer authorised; and
• Ensuring each invited instructor is told, before they accept, what the school will be able to see about their work.

Invited instructors see only the learners they are assigned. They cannot see the school's other instructors, other instructors' learners, or the school's bank details. Only the owner can change the school's settings, see the whole diary, or ask us to export or erase the school's data.

2.5 Suspending a single user

We may suspend an individual instructor's access without suspending the whole account, where that is enough to deal with a problem.

3. Subscription, pricing and payment

3.1 The two subscriptions

Instructor Buddy is sold in two forms:

• Solo — for one instructor working alone.
• School — for a driving school with more than one instructor. You pay for each instructor who uses the service.

Your subscription follows your headcount. If you are on Solo and invite another instructor, you move to School pricing from your next bill. If a school falls back to one instructor, it returns to Solo pricing. We never prevent you adding an instructor; it changes what you pay, and we tell you what it will cost before you do it.

Schools with fifteen or more instructors are arranged with us directly rather than through the website.

3.2 The price

The prices for each subscription are shown on our pricing page at instructorbuddy.co.uk when you subscribe, and confirmed to you in writing when your subscription starts.

Each subscription has a one-off setup fee and a monthly fee. The setup fee and your first month are taken as a single payment when you sign up; every payment after that is the monthly fee alone.

All prices are exclusive of VAT. We are not currently registered for VAT. If we become registered, VAT will be added at the rate then in force, and we will tell you before that happens.

3.3 Adding and removing instructors

You may add an instructor at any time, and we will never block you from doing so.

• Nothing is charged at the moment you add someone. The setup fee for that instructor, and their monthly fee, appear on your next bill.
• We tell you the cost before you commit, on the screen where you add them, including the date your next bill falls.
• We do not charge for part months. An instructor added part-way through a month costs nothing until your next bill.

If an instructor is removed, your next bill reflects the smaller number.

3.4 Discounts and promotions

We may offer discounts, introductory rates and promotions from time to time. Where one applies to you, its terms will be stated when you take it up, and the standard published price applies afterwards unless we have agreed otherwise in writing.

A discount offered to one customer does not entitle any other customer to it, and we may withdraw or change a promotion at any time for people who have not yet taken it up.

3.5 Free trial

We do not offer a free trial. Any introductory offer is a discount under clause 3.4 rather than a free period.

3.6 Billing and renewal

Subscriptions are billed monthly in advance and renew automatically each month until cancelled or paused. Payments are processed by Stripe. We do not receive or store your full payment card details; card information is handled by Stripe.

3.7 If a payment fails

If a payment fails, Stripe will try your card again over the following week, and we will tell you in the app straight away so you can update it.

• Your assistant keeps answering learners for the first four days.
• From the fifth day, the assistant stops replying to new enquiries. Your data, your diary and your conversations are untouched, and you can still sign in, read everything and export it.
• After about a week of failed attempts, the subscription is marked unpaid.
• As soon as a payment succeeds, everything switches back on at once.

While your assistant is stopped, we will email you if a learner messages you, with their name and their number or handle, so that you can contact them yourself. The learner is not sent an automatic reply.

Your telephone number is held for 30 days after a subscription is marked unpaid or a cancellation takes effect, and we will warn you 7 days before it is released. After that it is released and may be reissued to somebody else.

We will keep your data for 12 months after a subscription ends, then tell you to download anything you want, and erase it 30 days after that notice.

3.8 Pausing your subscription

If you need to stop for a while, you can pause instead of cancelling. A pause is free, and everything you have set up stays exactly as it is.

• You may pause for 30, 60 or 90 days.
• You may take up to three pauses in any twelve months, and no more than 90 days in total. Whichever of those two limits you reach first, you cannot pause again until the twelve months are up.
• The twelve months runs from the day your first pause ends.
• A pause starts at the end of the period you have already paid for — you keep the month you bought.
• You can come back early at any time, and only the days you actually used count towards your 90. It still counts as one of your three pauses.
• Your subscription restarts automatically on the day the pause ends, and we will remind you seven days before.
• You cannot pause in the first 30 days of a subscription.

While you are paused: the assistant stops answering learners, and neither you nor the assistant can send messages through the numbers and channels we provide. You can still sign in, see your diary, read your conversations and export your data, and nothing is deleted. We keep your telephone number for the whole of the pause.

If a learner messages you while you are paused, we will email you with their name and their number or handle so that you can contact them yourself, from your own phone or your own social accounts. The learner is not sent an automatic reply.

3.9 Changing the price

We may change our prices. If a change affects the price you pay, we will give you reasonable notice by email before it takes effect. If you do not accept the new price you may cancel before it applies, and the change will not apply to any period you have already paid for.

3.10 Cancelling your subscription

You may cancel at any time through the billing portal in your account, which is operated by Stripe.

Cancellation takes effect at the end of the period you have paid for. Your assistant keeps working until then, and you are not charged again.

3.11 Refunds

Subscription fees, including setup fees, are non-refundable for the unused part of a billing period after cancellation, unless we are legally required to refund, or we agree otherwise.

4. What Instructor Buddy does — and does not do

4.1 The service runs on the information you give it

The assistant answers learners using the information and settings you provide: your prices, working hours, covered areas, vehicles, transmission types, cancellation policy, availability, payment method and bank details. You are responsible for keeping all of it accurate and up to date.

4.2 The assistant does not replace the instructor

Instructor Buddy is an assistant. It does not replace your responsibility to run your driving school, to communicate with learners, to check your diary, or to provide driving instruction. You remain solely responsible for the driving instruction you deliver and for your obligations as an Approved Driving Instructor, including your registration with the DVSA and your obligations to your learners.

4.3 No guarantee of bookings

We do not guarantee that using Instructor Buddy will result in any particular number of enquiries or bookings, increased revenue, more learners, or any other business outcome.

4.4 Accuracy of responses

You acknowledge that AI technology is not perfect. The assistant may misunderstand a learner's question or give an incorrect or incomplete answer. You are responsible for the information you provide and should monitor the service.

4.5 Money never passes through us

Instructor Buddy does not process payments between driving instructors and learner drivers. We do not:

• Hold or receive learner payments;
• Hold instructor funds;
• Provide payment services between instructors and learners; or
• Act as a payment intermediary of any kind between instructors and learners.

Learners pay you directly, by whatever method you have chosen. We are not a party to that payment and have no involvement in it.

4.6 Bank details you choose to store

If you choose to enter them, we do store your bank account name, sort code and account number, and the assistant gives them to a learner after a lesson has been confirmed. This is how a learner is told where to send payment when the assistant has handled the whole booking and you were not part of the conversation.

• Entering bank details is optional. If you do not enter them, the assistant tells learners your payment method — for example “bank transfer” — and nothing more.
• The details are encrypted before they are stored, with a key held outside the database. They are never sent to your browser and never appear in a conversation record.
• Screens show the last four digits only — never the full number and never the sort code.
• The assistant gives them out only after a lesson is actually confirmed. A learner who simply asks for your account number is told the payment method and nothing else.
• We email you whenever these details are changed, so that an unauthorised change is visible to you immediately.
• They are deleted straight away when you remove them or close your account.
• A sort code and account number are not card data, so card-industry rules do not apply. They are personal data under UK GDPR, and we treat them accordingly.

You are responsible for the accuracy of the details you enter. We are not responsible for a payment made to an account whose details you entered incorrectly.

4.7 We are not regulated to handle money

Nothing in the service constitutes a payment service, e-money, credit, insurance, or any other regulated financial activity, and we are not authorised by the Financial Conduct Authority. If you provide a payment link or payment instructions to a learner, those arrangements are entirely yours.

5. Acceptable use

5.1 What you must not do

You must use Instructor Buddy lawfully and responsibly. You must not use the service to:

• Break the law, or commit or facilitate fraud;
• Misrepresent your identity or your driving school, or impersonate another person or business;
• Represent the assistant's messages as having been written by a person, where that would mislead;
• Send unlawful, abusive, threatening, harassing or harmful communications;
• Attempt to gain unauthorised access to another person's account or to any part of the service;
• Interfere with, disrupt, overload or attempt to reverse-engineer the service;
• Copy, resell, sub-license or make the service available to any third party, or use it to provide a service to another driving school;
• Use automated means to extract data from the service; or
• Use the service in a way that breaches the terms of a connected third-party platform.

5.2 Contacting people who have not contacted you

You must not use Instructor Buddy to send marketing or unsolicited messages to people who have not contacted you or your driving school first. Direct marketing by text, WhatsApp or email is regulated in the UK by the Privacy and Electronic Communications Regulations, and compliance is yours, not ours — you are the sender, and it is your list.

Uploading or entering contact details of people who have not enquired, in order to message them, is a breach of these Terms and grounds for immediate suspension.

5.3 Learners under 17

A person cannot hold a provisional licence to drive a car before their seventeenth birthday. Where the assistant is told that a learner is under 17, it stops trying to arrange a lesson and passes the enquiry to you.

You must not use the service to market to children, and where a parent or guardian enquires on a young person's behalf, you are responsible for handling that appropriately.

5.4 If you breach these Terms

We may suspend or terminate your access if we reasonably believe you have breached these Terms, are using the service unlawfully, or are using it in a way that could harm us, our other customers, learners or third parties. Where the breach is capable of being put right and there is no urgent risk, we will normally tell you and give you a chance to fix it first.

6. Phone numbers and communication channels

6.1 Numbers we provide

Where Instructor Buddy provides or manages a telephone number for use with the service, that number remains ours. You have the right to use it through the service for as long as your subscription lasts.

6.2 Numbers cannot be transferred

Telephone numbers we provide cannot be transferred to you or to another provider. If you need a number that is yours to keep, use your own and connect it to the service rather than using one we issue.

On cancellation or termination, your right to use a number we provided ends. We hold it for 30 days, and warn you 7 days before it is released. After that it may be reissued to somebody else.

6.3 Message charges

We pay for the text messages the service sends. There is no separate charge to you for them. We apply reasonable limits to protect the service, and we may contact you if usage is far outside normal use for a driving school.

6.4 Third-party channels

Instructor Buddy may connect with third-party services including WhatsApp, Instagram, Facebook, Google Calendar and others we may support in future. When you connect one:

• You are agreeing to that provider's own terms and policies, as well as these Terms;
• You remain responsible for complying with them; and
• We are not responsible for changes, restrictions, outages, account suspensions or decisions made by those platforms.

A third-party platform may withdraw access at any time, for reasons outside our control. If that happens, that channel will stop working, and we are not liable for the consequences.

7. Data protection

7.1 Privacy Policy

How we handle personal information is explained in our Privacy Policy at instructorbuddy.co.uk/privacypolicy, which forms part of these Terms.

7.2 Your own account information

For information about you and your business — your name, email address, school name, settings, subscription and use of the service — we are the data controller. The Privacy Policy explains what we do with it.

7.3 Learner information

For personal information about learner drivers processed through your use of Instructor Buddy — their names, contact details, messages, postcodes and lesson details — you are the data controller and we are your data processor. You decide why and how that information is processed. We process it only to provide the service and on your instructions.

7.4 Your obligations as controller

Because you are the controller of learner data, you are responsible for:

• Having a lawful basis for the processing you ask us to carry out;
• Giving learners your own privacy notice, telling them what happens to their information and naming us as a processor acting for you;
• Responding to learners who exercise their data protection rights (we will help — see Schedule 1);
• Making sure your instructions to us, including your settings, do not require us to break data protection law; and
• Telling your own instructors what the school records about their work.

7.5 Data processing terms

Schedule 1 to these Terms sets out the data processing terms required by Article 28 of the UK GDPR. It applies whenever we process personal data on your behalf.

7.6 Aggregated and anonymised information

We may create and use aggregated and anonymised data derived from use of the service, for product improvement, benchmarking, service insight, understanding usage trends, and developing Instructor Buddy.

• The information used for these purposes is aggregated and anonymised only — it cannot identify you, your school, or any learner.
• We will not use identifiable learner information for these purposes.
• We do not claim ownership of, or the right to commercially exploit, identifiable learner records or your own business records.
• We will not publish benchmarking data in a form from which any individual school could be identified.

7.7 Reviewing and improving the service

We review conversations handled by the assistant, and use them to train, improve and validate our AI models and the service. By subscribing, you agree that we may do this, including with conversations between the assistant and your learners.

This is limited in four ways, and the limits are the point:

• We do not sell your data, and we do not use it to train anyone else's AI models.
• We never use your calendar for any of this. If you connect one, we read only when you are busy — never the title, contents or guests of an event — and we write only the lessons this service arranged. Calendar information is never used to train, improve or validate any model. Section 12 of our Privacy Policy sets out both directions in full.
• We reduce and remove identifying details wherever we reasonably can before conversations are used for testing and development.
• We do not use it to compete with you — not to contact your learners, and not to build a picture of your business for anyone else.

If you would prefer your conversations were not used this way, tell us and we will discuss it.

8. Intellectual property

8.1 Our intellectual property

We and our licensors own all rights in the software, application, technology, design, branding, documentation and other materials that make up Instructor Buddy, except for content owned by you or by third parties. Nothing in these Terms transfers any of our intellectual property to you.

8.2 Your licence to use the service

While your subscription is active and you comply with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sub-licensable right to use Instructor Buddy for your own driving school's internal business purposes. The licence ends when your subscription ends or your account is terminated.

8.3 Your content

You retain ownership of the content and business information you provide — your prices, working hours, areas covered, vehicle information, instructor information, lesson information and your pupil records. You grant us the rights necessary to host, process and use that information in order to provide the service to you, and for no other purpose except as set out in clauses 7.6 and 7.7.

8.4 Feedback

If you send us suggestions or feedback about the service, we may use them freely and without obligation to you. We will not identify you as the source without your permission.

9. Availability and support

9.1 Availability

We will use reasonable efforts to keep Instructor Buddy available, but we do not guarantee that it will be available at all times, uninterrupted or error-free. The service depends on third parties — hosting providers, messaging platforms, AI providers and calendar providers — whose outages we cannot prevent. We do not offer a service level commitment.

9.2 Maintenance

We may suspend access for maintenance, updates or urgent security work. Where the work is planned and likely to interrupt the service, we will give reasonable notice.

9.3 Support

Support is available by email at info@instructorbuddy.co.uk. We aim to respond promptly, but we do not guarantee a response time.

10. Liability

10.1 What we promise

We will provide the service with reasonable care and skill. Instructor Buddy is an AI-assisted service and we cannot guarantee that it will always be available, accurate, uninterrupted or error-free.

10.2 What we are not responsible for

To the maximum extent permitted by law, we are not responsible for:

• Lost bookings or missed enquiries;
• Lost revenue, loss of profits, loss of business or loss of anticipated savings;
• Loss of goodwill or reputation;
• Business interruption;
• Losses arising from the assistant's responses, failures or errors;
• Losses arising from information you provided that was wrong or out of date;
• Losses arising from the acts, omissions, outages or decisions of third-party platforms; or
• Indirect or consequential loss of any kind.

You remain responsible for monitoring your enquiries, availability and bookings.

10.3 Liability cap

Subject to clause 10.4, our total liability arising out of or in connection with the service or these Terms — in contract, tort (including negligence), breach of statutory duty or otherwise — is limited to the total subscription fees you paid us in the twelve months immediately before the event giving rise to the claim.

10.4 Liability that cannot be excluded

Nothing in these Terms excludes or limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for anything else that cannot lawfully be excluded or limited.

10.5 Your responsibility to us

You are responsible for, and will compensate us for, any losses, claims, fines or costs we suffer because:

• You used the service in breach of these Terms or unlawfully;
• Of the content or accuracy of the information you gave the service;
• Of your instructions to us as data controller, or your failure to meet your own obligations under data protection law; or
• A third party claims that your content or your use of the service infringed their rights.

11. Termination

11.1 Cancellation by you

You may cancel your subscription in accordance with clause 3.10.

11.2 Termination by us

We may suspend or terminate your account if you materially breach these Terms, fail to pay amounts due, use the service unlawfully or misuse it, if your use creates a security or legal risk, or if we are required to by law or by a third-party platform. Where reasonably possible we will give you notice before terminating.

We may also stop providing Instructor Buddy altogether, on reasonable notice, refunding any fees you have paid for a period after the service ends.

11.3 What happens to your data

When your subscription ends:

• Your right to use Instructor Buddy ends and access will be disabled;
• Any outstanding amounts remain payable;
• You may ask us for an export of your data at any time up to 30 days after termination; and
• We keep your data for 12 months, then tell you to download anything you want to keep, and erase it 30 days after that notice — except where we are required by law to keep it, or need it to establish or defend a legal claim.

Records we are legally required to keep — financial records in particular — are kept for the periods set out in the Privacy Policy.

11.4 Numbers after termination

Any telephone number we provided ends with your subscription, in accordance with clause 6.2.

11.5 What survives

Clauses 4.5 to 4.7, 7, 8, 10, 11.3, 13 and 14 survive termination, together with any other clause that by its nature is intended to.

12. Changes to these Terms

We may update these Terms to reflect changes to our services, new features, changes in law or regulation, security improvements, or to clarify existing provisions.

If we make a material change, we will give you reasonable notice by email or through the application. Your continued use of the service after the updated Terms take effect means you accept them. If you do not agree to a material change, you may cancel before it takes effect.

Price changes are governed by clause 3.9.

13. General

13.1 Entire agreement

These Terms, the Privacy Policy and Schedule 1 are the whole agreement between us about Instructor Buddy and replace anything said or written beforehand. Neither of us relies on any statement not set out in them, but this does not limit liability for fraudulent misrepresentation.

13.2 Assignment

You may not transfer your rights or obligations under these Terms without our written consent. We may transfer ours to a company that acquires our business, on notice to you.

13.3 Severability and waiver

If any part of these Terms is found to be unenforceable, the rest continues to apply. If we do not enforce a right, we do not lose it.

13.4 No partnership or agency

Nothing in these Terms creates a partnership, joint venture or employment relationship, and neither of us is the other's agent. We do not act as your agent in dealing with learners — the assistant communicates as your assistant, but the contract for driving lessons is between you and the learner alone.

13.5 Third-party rights

Nobody other than you and us has any right to enforce these Terms under the Contracts (Rights of Third Parties) Act 1999. In particular, learner drivers acquire no rights under them.

13.6 Events outside our control

Neither of us is liable for failing to perform because of something outside our reasonable control, including failures of third-party platforms, hosting providers, telecommunications networks or AI providers.

13.7 Notices

We will send notices to the email address on your account. You should send notices to info@instructorbuddy.co.uk. It is your responsibility to keep your email address current.

14. Governing law and disputes

These Terms, and any dispute or claim arising out of them, are governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.

If you have a complaint, please raise it with us first at info@instructorbuddy.co.uk. We will acknowledge it and try to resolve it with you before either of us starts proceedings.

15. Contact us

Instructor Buddy Limited

• Email: info@instructorbuddy.co.uk
• Registered office: 3 Weekley Wood Close, Kettering, Northamptonshire, United Kingdom, NN14 1UQ
• Company number: 17478231
• Website: instructorbuddy.co.uk

Schedule 1 — Data processing terms

This Schedule applies where we process personal data on your behalf as your processor. Terms used in it have the meanings given in the UK GDPR and the Data Protection Act 2018.

1. Subject matter, duration, nature and purpose

Subject matter: the provision of the Instructor Buddy service. Duration: for as long as your subscription lasts, plus the retention periods set out in the Privacy Policy. Nature and purpose: receiving, storing and responding to enquiries from learner drivers on your behalf; identifying available lesson slots; recording and arranging lessons; and notifying you.

2. Types of personal data

3. Categories of data subject

Learner drivers who contact your driving school, and the parents or guardians who contact it on their behalf. Where you have invited instructors to your account, this Schedule also covers our processing of those instructors' personal data on your behalf.

4. Our obligations

We will:

• Process personal data only on your documented instructions, including on transfers outside the UK, unless we are required to do otherwise by law — in which case we will tell you first, unless the law forbids it. Your use of the service, and the settings you choose in it, are your documented instructions.
• Ensure that people authorised to process the data are bound by confidentiality obligations;
• Take appropriate technical and organisational security measures as required by Article 32 (see clause 7 below);
• Respect the conditions in clause 5 for engaging another processor;
• Help you, so far as we reasonably can, to respond to requests from individuals exercising their rights;
• Help you with data protection impact assessments, prior consultation with the Information Commissioner, and your obligations to keep data secure and report breaches;
• Delete or return the personal data at the end of the service, as set out in clause 9; and
• Make available the information you need to demonstrate compliance with Article 28, and allow and contribute to audits, as set out in clause 10.

We will tell you if, in our opinion, an instruction you give us breaches data protection law.

5. Other processors we use

You give us general authorisation to engage the sub-processors listed in Schedule 2. We will:

• Impose data protection terms on each of them that are no less protective than these;
• Remain fully liable to you for their acts and omissions; and
• Give you reasonable notice before adding or replacing one, by email or through the application. If you reasonably object on data protection grounds, you may raise it with us, and if we cannot resolve it you may terminate without penalty for the remainder of the term.

6. Where the data is, and transfers outside the UK

Our database is hosted in London, on Amazon Web Services in the eu-west-2 region, so the data held in it stays in the United Kingdom and no transfer takes place.

Some of our other providers are in the United States. Where personal data goes to them, we rely on the International Data Transfer Agreement, or the UK Addendum to the European Commission's standard contractual clauses, together with a transfer risk assessment. Schedule 2 says which is which.

Where data is stored and who can reach it are two different questions. Several of our providers store data inside the UK or the EEA but are companies incorporated in the United States, whose staff may access it for support. Those arrangements are covered by the same transfer safeguards.

7. Security

Our security measures include:

• Encryption of all data in transit;
• Encryption of data at rest at the database level, and additional application-level encryption of bank details, with the key held outside the database;
• Row-level access rules enforced by the database itself, so that no account can read another school's data even if the application is wrong — tested rather than assumed;
• Passwordless sign-in by single-use email link, so that no password exists to be stolen or reused;
• Access controls and audit logging on our own staff's access to customer data (see clause 8);
• Segregation of production data from development and testing environments; and
• No storage of payment card numbers by us at any point.

8. Our staff's access to your data

Our support staff can see limited information about how your account is getting on. Reading the content of a learner's conversation requires a separate permission that is switched off by default, and every such read is recorded — who read it, whose conversation, and when. We can tell you exactly who accessed what and when, on request.

9. Deletion and return

At the end of the service, we will delete the personal data we process on your behalf, or return it to you if you ask, within the periods set out in clause 11.3 of the Terms and our Privacy Policy, except to the extent we are required by law to keep it.

10. Audit and information

On reasonable written request, and no more than once a year unless a regulator requires otherwise or there has been a security incident affecting your data, we will provide the information you reasonably need to verify our compliance with this Schedule. Where an on-site audit is genuinely necessary, we will cooperate with a mutually agreed auditor, at your cost, on reasonable notice and without disrupting our other customers.

11. Personal data breaches

We will notify you without undue delay after becoming aware of a personal data breach affecting personal data we process for you, and give you the information you need to meet your own reporting obligations. Reporting a breach to the Information Commissioner, and telling affected learners, is your responsibility as controller — we will help.

12. Individuals exercising their rights

If we receive a request directly from a learner, we will not respond to it ourselves except to acknowledge it and tell them to contact you, unless you instruct us otherwise or the law requires otherwise. We will acknowledge it promptly and pass it to you. If you have not acted within 14 days, we will remind you.

Schedule 2 — Sub-processors

The organisations below process personal data on our behalf in order to deliver Instructor Buddy. This list is current as at the date of these Terms. Not every channel is switched on for every customer; where one is not connected to your account, no information reaches that provider.