This supplement details how Hellobugs Entertainment (“the Company”) collects, uses, protects, and discloses the Personal Data of its Tutors/Instructors (“Tutor”) who contribute content to the Mcubes Online Platform. This policy is subject to the general Privacy Policy (Part C) and the financial terms of the Terms of Use (Part A).

1. Information We Collect from Tutors

We collect data necessary to manage the distribution agreement, ensure compliance, and facilitate payments:

Category of DataSpecific Data Points CollectedPurpose of Collection
Identification & ProfileFull Name, Email Address, Hashed Password, Profile Picture, Biographical Information, Resume/CV, Instructional Experience.Account creation, identity verification, displaying public profile on the Platform for marketing.
Financial & Payout DataBank Account Name, Account Number, IFSC/SWIFT Code, Tax Identification Number (TIN/PAN), and Payout History.Fulfilling contractual payment obligations (Section 5, Part A), managing the minimum payout threshold ($100 USD), and ensuring legal tax compliance.
Content & Performance DataCourse Titles, Video Files, Lecture Texts, Student Enrollments, Student Ratings/Reviews, Earnings Data, Refund Chargebacks.Calculating earnings, tracking Tutor financial liability for refunds, platform quality assurance, and providing performance analytics.
Technical & Security DataIP Addresses, Login Times, Device Information, Audit Logs of Content Uploads/Modifications.Securing the account, preventing unauthorized access to proprietary content, and maintaining legal records.

2. How Tutor Data is Used

Tutor Personal Data is used strictly for the following legitimate business purposes:

  • Contract Execution and Payment: To process and disburse earnings, manage the $100 USD minimum payout threshold, and ensure the Company covers associated bank transaction fees.
  • Performance and Quality Control: To analyze content performance, track student satisfaction metrics, and investigate any user reports of content quality issues or material discrepancies as per the Refund Policy.
  • Financial and Legal Compliance: To issue necessary tax documents (TDS certificates, 1099 forms, etc.), comply with tax authorities in India and relevant international jurisdictions, and track financial transactions, including refund chargebacks.
  • Platform Functionality and Marketing: To display the Tutor’s public profile, biography, and course listings to potential students on the Platform and through marketing channels.

3. Disclosure and Sharing of Tutor Data

We limit the sharing of Tutor data to essential parties under strict confidentiality:

  • Payment Processors & Banking: Financial details (bank account information) are securely transmitted to our authorized payment processors and banking partners solely for the purpose of initiating payouts to the Tutor.
  • Tax and Legal Authorities: Data, including financial records and TIN/PAN information, will be disclosed to governmental, regulatory, or tax authorities when legally required (e.g., fulfilling obligations under the IT Act 2000).
  • Public Profile Display: Biographical information, profile pictures, and course ratings/reviews are intentionally made publicly available on the Platform to market the Tutor’s courses to prospective students.
  • Audit and Security: Data may be shared with external auditors or legal counsel to protect the Company’s rights, verify financial reporting, or enforce the strict Anti-Fraud policies.

4. Tutor Financial Data Security

We commit to the following security standards for highly sensitive Tutor data:

  • Encryption: All financial payout details are stored securely using industry-standard encryption protocols.
  • Restricted Access: Access to the Tutor’s personal financial details is strictly limited to authorized personnel within the Finance department responsible for payment processing and compliance.
  • Payout Transparency: Tutors have the right to view their earnings statements and the calculation of any refund chargebacks deducted from their balance via their dashboard.

5. Tutor Data Rights and Termination

  • Content Deletion upon Termination: If the Tutor’s distribution agreement is terminated (either by the Tutor or the Company), all non-financial content (videos, files) will be removed from the Platform.
  • Data Retention: Notwithstanding a termination request, financial records, transaction data, and tax information will be retained for a minimum period mandated by Indian tax and accounting laws (typically 7 years) to ensure compliance with financial regulations and manage any outstanding refund liability or penalties.
  • Right of Access and Correction: Tutors maintain the right to access and update their profile and financial information via their dashboard or by contacting howdy@darkgrey-echidna-669001.hostingersite.com.