Privacy Policy
Last updated July 2026
Who we are
Pareto Path LLP ("we", "us") is registered in England and Wales (OC460781). Our registered address is 71-75 Shelton Street, Covent Garden, London WC2H 9JQ. We are the data controller for the information described in this policy and are registered with the Information Commissioner’s Office (ICO). This policy explains what personal information we collect, why we collect it, and how we look after it. Contact us about this policy, or to exercise any right under it, at pareto@paretopath.com.
Information we collect
When you contact us or book a Diagnostic Call we may collect your name, email address, telephone number and details about your course, level and learning goals. If you become a client we may also hold lesson notes, materials you share with us and scheduling information.
How we use your information
We use your information to respond to enquiries, arrange and deliver tuition, send session summaries and action steps, process bookings, and improve our service. We do not sell your personal data, and we do not share it with third parties except where necessary to deliver our service or where required by law.
Lawful basis
We process your data on the basis of your consent, our legitimate interest in providing the tuition you request, and where applicable the performance of a contract between us. You may withdraw consent at any time.
Data retention and security
We keep your information only for as long as necessary to provide our service and to meet our legal obligations, after which it is securely deleted. We take reasonable technical and organisational measures to protect your data against loss, misuse and unauthorised access.
Your rights
Under UK data protection law you have the right to access, correct, or request deletion of your personal data, to object to or restrict its processing, and to data portability. To exercise any of these rights, contact us at pareto@paretopath.com.
Recorded sessions: what we record
Online tutoring sessions are delivered over Google Meet. Where a session is recorded, we collect the audio and video of the session, an automated transcript, and notes generated by Gemini, the AI assistant within Google Workspace, together with participant names, email addresses and session details. Sessions may touch on matters such as a learning difficulty, health condition or special educational need. This is special category data and we handle it as described below.
Recorded sessions: why we record and our legal grounds
We only record with permission. Under Article 6 UK GDPR we rely on: consent (Article 6(1)(a)) for recording, transcribing and summarising the session; legitimate interests (Article 6(1)(f)) for keeping teaching records, tracking progress and improving tuition; contract (Article 6(1)(b)) for delivering the tuition you have engaged us for; and legal obligation (Article 6(1)(c)), together with legitimate interests, for meeting safeguarding and legal duties and handling claims or complaints. Where a recording captures special category data we rely on your explicit consent (Article 9(2)(a) UK GDPR) and, where necessary to protect a child or individual at risk, the safeguarding condition in Schedule 1, paragraph 18 of the Data Protection Act 2018. If consent is not given, the session simply proceeds unrecorded.
Recorded sessions: consent, and students under 18
Consent may be given in writing (including by email or WhatsApp), by accepting our Terms, or verbally at the start of a session after the recording notice has been given. We keep a record of each consent. Where the student is under 18, consent must be given by a parent or guardian; students aged 13 to 17 are also told, in an age-appropriate way, that the session is recorded and why, in line with the ICO’s Children’s Code. Consent can be withdrawn at any time, as easily as it was given, without affecting the tuition provided.
Recorded sessions: AI-generated notes
Transcripts and notes are produced by AI and may contain errors. We review them before relying on them, and you may ask us to correct any inaccuracy. We do not use recordings, transcripts or notes to make solely automated decisions with legal or similarly significant effects about any person.
Recorded sessions: storage, access and sharing
Recordings, transcripts and notes are held in our access-controlled Google Workspace environment and are accessible only to the members of Pareto Path and the tutor who delivered the session. Google processes this information as our data processor under the Google Cloud Data Processing Addendum. Where a subcontracted tutor delivers your tuition, they are bound by a written agreement imposing the same protections. We disclose recordings otherwise only where required by law or by a safeguarding duty. We do not sell recordings or use them for advertising. Where Google processes data outside the UK, the transfer is protected by the UK-US Data Bridge or the UK International Data Transfer Agreement or Addendum, as applicable.
Recorded sessions: retention
We keep transcripts and AI-generated notes for 6 years from the end of the tutoring relationship (Limitation Act 1980). Audio and video recordings are kept for up to 6 years from the end of the tutoring relationship and may be deleted earlier once notes are verified. Records connected to a safeguarding concern are kept in line with our safeguarding policy, which may extend to the individual’s 25th birthday. Consent records are kept for as long as the related recording is held, plus the limitation period. At the end of the applicable period the information is securely deleted or anonymised.
Recorded sessions: your rights
You may request access to, correction of, or deletion of recordings, transcripts and notes about you, object to or restrict their use, and withdraw consent to recording, by contacting us or telling your tutor. We respond within one month and delete on request unless a legal ground requires retention, such as a safeguarding duty or a live or anticipated claim. If you are dissatisfied, we will acknowledge your complaint within 30 days under our data protection complaints procedure (section 164A, Data Protection Act 2018), and you may complain to the ICO at ico.org.uk at any time.
Cookies and analytics
With your consent, we use Google Analytics to understand how the site is used and to improve it. We do not use advertising cookies and we never sell your data. You can accept or decline when you first visit, and change your mind at any time via Cookie choices in the footer or through your browser settings.
Questions about this policy? Email pareto@paretopath.com.