Legal Policies

Privacy Statement

In accordance with the GDPR and the Dutch UAVG · Last updated: July 1, 2026

This Privacy Statement explains how Turning Pages Education (we, us), based at Herengracht 320, Amsterdam 1016CE, The Netherlands, KVK number 97960381, collects, uses, and protects personal data in connection with our tutoring, academic testing, and related services.

1. Who We Are

We are the data controller for the personal data described in this statement. For any questions about this statement or our data practices, please contact us via email at dr.vlrivers@turningpagesedu.com or by phone at +31 6 28 14 11 40.

2. What Personal Data We Collect & How

• Contact details of parents/guardians: name, address, email, phone number.

• Student details: name, date of birth, school, grade/year level, and curriculum followed.

• Academic data: results and reports from academic testing (reading, fluency, writing, speaking, listening, maths, sciences), lesson attendance, progress notes, intake/mid-year/exit reports.

• Billing information: invoicing details and payment records (we do not store full bank card details; payments are made by bank transfer).

• Communications: emails, messages, or notes arising from consultations and lessons.

• For online lessons: technical data needed to conduct the session (e.g., video-call platform identifiers).

• Data is collected through website forms, email contact, service agreements, lesson delivery, and payments.

3. Why We Process This Data, and Our Legal Basis

• Performance of a contract — to register students, schedule and deliver lessons and testing, issue invoices, and produce academic reports.

• Legal obligation — to meet Dutch tax, invoicing, and VAT record-keeping requirements.

• Legitimate interest — to maintain lesson quality, communicate about scheduling, website improvement, and safeguard our business records, balanced against your rights and interests.

• Consent — where we ask separately, for example, to share testing results with a school for placement purposes, or for optional communications.

4. Personal Data of Children

Many of our clients are minors. Where processing is based on the contract with the parent/guardian who registers the student, no separate consent from the child is required. Where processing would instead rely on consent (for example, sharing a child's report with a third party at the family's request), we obtain consent from the parent or legal guardian, in line with the UAVG's rules on the digital age of consent for children under 16.

5. Who We Share Data With

• Tutors and staff directly involved in delivering lessons and testing to the student.

• Schools or education professionals, but only with the family's explicit request or consent (e.g., for placement or IEP purposes).

• Service providers acting on our instructions, such as accounting/invoicing software, video-conferencing tools for online lessons, and IT hosting providers. These providers process data only under our instructions and appropriate data-processing agreements.

• We do not sell personal data, and we do not share data with third parties for their own marketing purposes.

6. International Transfers

Where any service provider is located outside the European Economic Area, we ensure an appropriate safeguard is in place, such as the European Commission's Standard Contractual Clauses, before any data is transferred.

7. How Long We Keep Data

• Student academic records and reports: for the duration of enrolment and for a reasonable period afterward to support future placement requests, unless you ask us to delete them sooner and no legal obligation requires retention.

• Financial and invoicing records: for the period required by Dutch tax law (currently 7 years).

• Contact details of former clients: deleted or anonymised once no longer needed for the purposes above.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse, including access controls, secure storage, and limiting data access to staff who need it to perform their role.

9. Your Rights

Under the GDPR, you (or, for a minor student, their parent/guardian) have the right to:

• Access the personal data we hold about you or your child.

• Request correction of inaccurate or incomplete data.

• Request erasure of data, where applicable.

• Request restriction of, or object to, certain processing.

• Request a portable copy of data you provided to us.

• Withdraw consent at any time, where processing is based on consent, without affecting processing carried out before withdrawal.

To exercise any of these rights, contact us at dr.vlrivers@turningpagesedu.com. You also have the right to lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

10. Cookies and Website

If you visit our website, we may use functional and, where you consent, analytics cookies. Please review our separate Cookie policy.

11. Changes to This Statement

We may update this Privacy Statement from time to time to reflect changes in our practices or in the law. The version published on our website or provided to you at registration is the version in effect.

Child Protection & Safeguarding Policy

In line with the Dutch Reporting Code (Meldcode) for Domestic Violence & Child Abuse and the GDPR/UAVG.

Last updated: July 1, 2026

Child protection and safeguarding means protecting children and young people from abuse, and identifying and responding to abuse that may already be happening. This policy applies to all staff, tutors, and volunteers of Turning Pages Education working with students under the age of 18.

1. Our Safeguarding Commitment

Abuse of a child or young person under the age of 18 can take several forms:

• Physical abuse — deliberate physical harm or injury.

• Emotional abuse — persistent ill-treatment causing severe or lasting effects on a child's emotional development, including humiliation, threats, or isolation.

• Sexual abuse — involving a child in sexual activity, whether or not the child is aware of what is happening.

• Neglect — the persistent failure to meet a child's basic physical, emotional, educational, or medical needs, likely to result in serious harm to health or development.

Abuse does not always fall neatly into these categories, and a child may experience more than one form at once. If you are ever in doubt about whether something constitutes abuse, seek advice rather than deciding on your own —see Section 6 below.

2. How We Safeguard Children

As a tutoring provider, we are not a statutory child-protection body. In the Netherlands, statutory powers and responsibilities for child protection sit with the police, Veilig Thuis (the regional advice and reporting centre for domestic violence and child abuse), and the Raad voor de Kinderbescherming (Child Care and Protection Board).

All our staff, tutors, and volunteers nonetheless have a duty to protect, safeguard, and promote the welfare of the children and young people we work with. Strong safeguarding procedures and practice allow us to provide a safe environment in which students can learn and engage with our services, and help build the trust of the families we serve.

3. Recruitment

• All staff and tutors working with children must hold a valid Verklaring Omtrent het Gedrag (VOG, Certificate of Conduct) specific to working with minors, obtained before they begin working with students and renewed periodically thereafter.

• We follow safer-recruitment practices, including identity verification, employment history checks, and references specifically addressing suitability to work with children, before any offer of work is confirmed.

• Tutors engaged as self-employed contractors are held to the same VOG and reference requirements as employed staff.

4. Training

• All staff and volunteers complete mandatory safeguarding induction training, regardless of whether their role involves direct contact with children.

• All staff and tutors who work directly with children also receive training on the Meldcode Huiselijk Geweld en Kindermishandeling (the Dutch Reporting Code for Domestic Violence and Child Abuse) and receive regular refresher training thereafter.

• Training covers recognising signs of abuse or neglect, responding appropriately to disclosures, and following our internal reporting procedure.

5. Designated Safeguarding Lead and Procedures

• We have designated Dr Vivian L. Rivers as our Designated Safeguarding Lead, responsible for receiving concerns, coordinating our response, and liaising with external authorities where needed.

Where a member of staff or tutor has a concern about a child, we follow the five steps of the Meldcode:

1. Identify and record signals of possible abuse or neglect.

2. Consult a colleague and, where needed, Veilig Thuis or another expert, without yet disclosing identifying details.

3. Where safe and appropriate, discuss the concern with the child and/or their parents/guardians.

4. Weigh the risk of harm to the child, seeking further expert advice from Veilig Thuis if needed.

5. Decide whether to provide or arrange support ourselves, and/or make a report to Veilig Thuis.

We maintain a suite of safeguarding policies, procedures, and guidance for all managers, staff, and volunteers to ensure clear and robust action can be taken whenever required.

6. If You Are Worried About a Child

• If you think a child or young person is at risk, being abused, or neglected, contact Veilig Thuis on 0800-2000 (free, available 24/7) or via veiligthuis.nl.

• If there is immediate danger to a child or anyone else, call 112 (Dutch emergency number).

• If your concern relates to one of our services, please also email our safeguarding team at [safeguarding email], so that we can take internal action alongside any external report.

• If you are a child or young person and want to talk to someone yourself, the Kindertelefoon can help, in confidence: call 0800-0432 (daily, 09:00–20:00) or chat online at kindertelefoon.nl.

• For students who attend a school outside the Netherlands but are tutored by us, we will also take into account any reporting obligations of that school's home jurisdiction where relevant, in addition to Dutch requirements.

7. Data Protection (GDPR / UAVG)

Information related to a safeguarding concern is sensitive personal data. We handle it in line with the GDPR and the Dutch Implementation Act (UAVG), and separately from ordinary academic and administrative records:

• Legal basis — we process safeguarding information based on our legal obligations, the vital interests of the child, and our legitimate interest in protecting the children and young people we work with.

• Access — safeguarding records are accessible only to the Designated Safeguarding Lead and those directly involved in managing a concern, on a need-to-know basis.

• Sharing — we share safeguarding information with Veilig Thuis, the police, or other competent authorities only where necessary to protect a child, and we do not require separate parental consent to do so where the child's safety is at risk.

• Storage and retention — records are stored securely, separately from general student files, and retained only for as long as necessary for child protection and legal purposes, in line with our Privacy Statement.

8. Review

This policy is reviewed annually, or sooner if Dutch child-protection law changes, guidance from Veilig Thuis changes, or our practice changes.

9. Contact

Turning Pages Education

Attention: Dr Vivian L. Rivers

Herengracht 320, Amsterdam 1016CE, The Netherlands

+31 020 26 12 950

dr.vlrivers@turningpagesedu.com

KVK | 97960381

Terms & Conditions

Tutoring, Academic Testing, and Related Services — 2026-2027 Academic Year

These Terms & Conditions (Terms) govern the provision of tutoring, academic testing, exam-preparation, and related services by Turning Pages Education (we, us, or the Company) to parents, guardians, and students (you, the Client). By booking a consultation, registering a student, or purchasing any service listed in our Pricing Guide, you agree to these Terms.

1. Services

We offer the following services, as described in our current Pricing Guide, which forms part of these Terms:

• A free 30-minute initial consultation.

• Monthly Subscription lessons (Primary, Middle, Upper, and Final groups), scheduled weekly.

• Single/irregular lessons booked on an ad-hoc basis (fewer than 4 times per month).

• Mandatory academic testing for new students joining a Monthly Subscription plan, and optional standalone academic testing for families requiring data or reports for school placement or Individual Education Plans (IEPs).

• 30-minute Homework Help sessions (online only).

• Exam-preparation half-day workshops (SAT/ACT/IELTS) and individual exam-preparation hours.

• Back to School lesson bundles, available for purchase throughout September 2026.

Current fees for all services are set out in the Pricing Guide, which we may update from time to time. The version in force at the time you book a service applies to that booking.

2. Registration

A one-time Registration Fee of €15 per student, per academic year applies to all students. Registration is confirmed once the fee is paid and any requested student/parent information has been provided.

3. Academic Testing

• Academic testing is mandatory for every new student joining a Monthly Subscription plan. It is charged at €125 when combined with a Subscription Plan, or €275 as a standalone service.

• Academic testing is based on CEFR scales and is adapted to the curriculum followed at the student's school (e.g., IB, American, European, UK, French, Swiss, or Dutch curricula).

• Testing covers Reading, Fluency, Writing, Speaking, Listening, and, where relevant, Mathematics and Sciences.

• Subscription students receive a comprehensive intake report, a mid-year progress report, and an end-of-year/exit report, each referencing the relevant curriculum standards.

• Academic testing is not required, and is not conducted, for 30-minute Homework Help sessions or for students booking irregular/single lessons.

• Parents may also request academic testing as a standalone service, independent of any lesson plan, for the purpose of school placement or IEP development.

4. Fees and Payment

1. Monthly Subscription fees are invoiced by email in advance of each month and are payable by bank transfer on or before the 1st of that month.

2. If payment is not received within 14 days of the due date, all further lessons will be suspended until outstanding amounts are settled in full. A 15% late fee is applied to the overall balance.

3. Monthly Subscription fees are calculated on an annual basis and divided evenly across 52 weeks, regardless of the number of lessons actually delivered in a given month.

4. Lessons under a Monthly Subscription are scheduled weekly for 38 weeks of the year. There are no lessons during the school's summer holidays or half-term breaks, unless a family specifically requests continued lessons during these periods, in which case such lessons will be delivered online only.

5. Families are responsible for booking and scheduling in line with the specific holiday calendar of the school their child attends.

6. All prices are exempt from VAT for private individuals. Where services are billed to a business or company, 21% Dutch VAT (BTW) is added in accordance with Dutch tax law.

7. Fees for Back to School Bundles must be paid in advance at the time of purchase; lessons may then be used flexibly across the academic year at the family's discretion.

5. Cancellations and Contract Termination

Cancellation of individual lessons and termination of Monthly Subscription contracts are governed by our separate Cancellation Policy, which forms an integral part of these Terms and is provided to all clients at registration and available on request.

6. Exam Preparation Workshops

• Small-group half-day workshops (SAT/ACT/IELTS) are capped at 5 students per session, priced per student, and include lunch and refreshments (unless online).

• Individual exam-preparation sessions are billed hourly.

• Trinity, LAMDA, and Cambridge examination preparation cannot be booked as standalone workshops and must instead be booked as weekly lessons under a Monthly Subscription or irregular-lesson arrangement.

7. Conduct and Responsibilities

• Parents/guardians are responsible for ensuring the student is present, prepared, and (for online lessons) has a stable internet connection and appropriate device at the scheduled lesson time.

• We will make reasonable efforts to provide consistent teaching staff but reserve the right to assign a substitute tutor where necessary to ensure continuity of lessons.

• Any behaviour that is abusive, unsafe, or seriously disruptive towards staff or other students may result in suspension or termination of services, at our discretion.

8. Liability

We provide tutoring and testing services with reasonable skill and care. We do not guarantee specific academic outcomes, examination results, or grade improvements, as these depend on factors outside our control, including student effort and engagement outside of lessons. Nothing in these Terms limits or excludes liability that cannot lawfully be limited or excluded under Dutch law, including liability for intent or gross negligence.

9. Data Protection

We process personal data, including data relating to minors, in accordance with the General Data Protection Regulation (GDPR) and the Dutch Implementation Act (UAVG). Full details are set out in our separate Privacy Statement, which is available to all clients and forms part of these Terms.

10. Changes to These Terms

We may update these Terms and our Pricing Guide from time to time, for example to reflect changes in our services, costs, or applicable law. Where changes materially affect an active Monthly Subscription, we will provide at least one month's notice before the change takes effect.

11. Governing Law and Disputes

These Terms are governed by the laws of the Netherlands. Any dispute arising from these Terms or the services provided will first be addressed through good-faith direct discussion between the parties. If unresolved, the dispute will be submitted to the competent Dutch court, or, for consumer clients, may alternatively be brought before the Geschillencommissie (Disputes Committee) where applicable, without prejudice to a consumer's right to bring proceedings before a Dutch court.

12. Contact

Turning Pages Education

Attention: Dr Vivian L. Rivers

Herengracht 320, Amsterdam 1016CE, The Netherlands

+31 020 26 12 950

dr.vlrivers@turningpagesedu.com

KVK | 97960381

Cancellation Policy

Applicable to all lessons and Monthly Subscription plans. This Cancellation Policy forms part of, and should be read together with, our Terms & Conditions.

1. Cancelling an Individual Lesson

• At least 24 hours' notice: if a student cannot attend a scheduled lesson and the teacher is informed at least 24 hours in advance, a substitute lesson will be rescheduled within the same month.

• Less than 24 hours' notice: lessons cancelled with less than 24 hours' notice are forfeited and are not rescheduled or refunded.

• Notice should be given directly to the assigned teacher or to our office by email or the agreed communication channel.

2. Cancelling a Monthly Subscription Contract

• Notice period: a Monthly Subscription contract may be cancelled with one calendar month's written notice.

• May, June, and July: contract cancellations are not accepted during May, June, or July, to preserve continuity through the end of the academic year and examination periods. Notice to end a subscription for the following year should be given by 30 April at the latest, taking the one-month notice period into account.

• Fees remain payable for the full notice period, in line with our Fees and Payment terms.

3. Non-Payment

If Monthly Subscription fees are not received within 14 days of the bill/due date, lessons are suspended until outstanding amounts are paid in full. A 15% late fee is applied against the total amount. Suspension due to non-payment does not itself end the subscription contract or the notice-period obligation.

4. Back to School Bundles

Bundles are paid in advance, and lessons may be used flexibly across the academic year. As bundles are pre-paid promotional packages, unused lessons are non-refundable but remain valid for use until the end of the 2026-2027 academic year, unless otherwise agreed in writing.

5. Academic Testing

Fees for academic testing (whether bundled with a subscription or booked as a standalone service) are payable at the time of booking and are non-refundable once testing has been scheduled, except where we are unable to deliver the service.

6. Exceptional Circumstances

Where a student is unable to attend due to illness, family emergency, or other circumstances beyond reasonable control, we will consider rescheduling requests made outside the standard 24-hour window on a case-by-case, good-faith basis.