RTL Clubs | review-2026-09-19-v0.7 PROVISIONAL REVIEW DOCUMENTS: not a binding contract Company: RTL Clubs Ltd Published: 2026-09-19T22:59:08.530365+00:00 L02: Club Operator Terms Version: review-2026-09-19-v0.7 # L02: Club Operator Terms Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Parties and licence RTL Clubs Ltd, at 20-22 Wenlock Road, N1 7GU, contracts with the legal operator identified in the organisation account and accepted order (Operator). The person accepting confirms authority to act for that Operator. A sole trader uses their own legal name and any trading name. Schools use the same terms through their correct legal organisation. RTL Clubs Ltd supplies software, content and books. RTL Education Ltd owns the RTL books and licenses them to RTL Clubs Ltd. RTL grants the Operator a non-exclusive, non-transferable licence to use its subscribed software, content and books for its own teaching business while the relevant fees are paid and the licence has not been suspended or terminated under these terms. No learner-number allowance is specified in this agreement. Separate learner identities and authorised access remain required. This is a software and content licence. RTL does not grant a franchise, operate the Operator's tuition business or appoint it to bind RTL. The Operator sets its own tuition services, fees and business arrangements. RTL does not recruit or vet tutors, carry out criminal-record checks, supervise sessions or manage local safeguarding. ## 2. Subscription and locations The accepted order identifies the Operator, subscribed programmes and services, fee including applicable taxes, payment route, start date and selected billing period. Billing may be monthly, quarterly or annually. The subscription renews for the same selected period unless renewal is cancelled before the next payment under the relevant purchase route or the licence ends under these terms. Cancelling renewal normally leaves the licence available until the paid period ends. Paying fees does not override a conduct restriction or termination. The price and payment period are shown before purchase; they need not be repeated in a separate signed commercial schedule. No undisclosed charge is payable. A proposed price change applies prospectively after notice, with consent where required and an opportunity to cancel renewal before it takes effect. One licence may cover multiple locations. Register every location in the app before use and keep its details current. Registration is not a safety inspection or premises certification. No additional-location charge is imposed by these terms. Schools do not require a separate agreement or mandatory school schedule. ## 3. Your tuition business Identify the actual tuition supplier to parents before enrolment, including its legal name and contact details. Explain any separate venue host or payment collector acting on that supplier's behalf. Contract for tuition in the supplier's own name. Maintain appropriate session, complaint, emergency and staffing arrangements under the law where you operate. You select, engage and supervise tutors and complete legally required checks through lawful routes. Prevent ineligible or barred people from undertaking relevant work. Keep proportionate local records and notify RTL of material concerns affecting the licence. RTL may request relevant, proportionate evidence of licence compliance, but does not routinely collect criminal-record certificates or certify suitability. Club-funded access is the normal club route: the club buys RTL access and the parent pays the club for tuition. Parents may instead choose to buy their child's programme access directly from RTL while using a club, or buy Home Learning access for use at home. Tuition remains a separate purchase from the named teaching provider. We identify the payer and access being purchased before any charge and do not require duplicate payment for the same coverage. An optional direct purchase does not remove the club's own professional licence requirement. ## 4. Professional access and materials Each tutor must accept L04 and use their own credentials. Only authorised staff may access assigned learners' records for their work. An Operator who teaches also accepts L04 personally. Remove assignment access when it is no longer needed and report matters requiring network-wide action. Use and print entitled content and books for your authorised teaching. Do not sell copies as standalone products, sublicense them, upload them publicly, bypass access controls or share credentials. Do not upload protected materials to external AI services without permission, subject to statutory rights. Use permitted RTL branding only to identify your independent use of RTL programmes. Do not register RTL-branded domains or social accounts without permission, or claim RTL runs, vets or accredits your business. RTL and its licensors retain their rights. This agreement does not assign children's work, independent tutor work or personal data to RTL. Completed learner work and reports may be retained lawfully after exit. Future commercial use of licensed materials ends with the licence. ## 5. Incorporated documents and information G01-G08, L10 for subscription mechanics and the completed applicable L09 data schedules form part of this agreement at the versions supplied on acceptance. Mandatory law prevails. An applicable data schedule prevails for data-processing obligations. Otherwise the accepted order's specific commercial particulars take priority, followed by L02, L10 and governance. The order cannot silently remove the core licence restrictions or change household sibling rules into club pricing. Keep confidential information secure and use it only for authorised purposes. No confidentiality or branding condition prevents good-faith complaints, lawful criticism, protected disclosures or reporting to authorities. ## 6. Ending the licence You may cancel renewal through your payment provider's cancellation route or ask RTL Help for assistance. The licence ends when the paid period expires without renewal, or earlier under G07. A failure to pay is handled as a payment issue and is not described as misconduct. RTL may suspend or terminate for material misuse, copyright or other IP infringement, unauthorised access or disclosure, misleading use of the RTL name, serious misconduct or conduct creating a material and reasonably evidenced risk to RTL's reputation. G07 governs evidence, proportionality, notice, remedy where appropriate and review. A remediable breach normally receives a reasonable opportunity to be corrected; serious infringement or an urgent continuing risk may justify immediate action. Paying again does not restore a terminated or restricted licence. RTL controls its own software, content and branding permissions. It does not purport to close your independent tuition business. On exit stop new licensed use and branding, remove professional access and follow G08 for lawful handover. L10 addresses affected RTL prepayments; the tuition supplier addresses its own tuition payments. Unaffected parent subscriptions do not automatically end. ## 7. Continuing terms and disputes Ending or not renewing the subscription does not end accrued payment obligations, confidentiality, IP protection, restrictions on future use, lawful records duties, review rights or provisions needed to give termination effect. Those provisions survive for as long as their purpose requires, subject to law. Nothing in these terms excludes or limits any right, remedy or responsibility that cannot lawfully be excluded or limited. RTL offers no discretionary compensation or goodwill payments. These terms specify no insurance requirement, negotiated liability cap or indemnity. Raise concerns through G06. English and Welsh law governs this agreement, with the courts of England and Wales for business disputes, subject to mandatory applicable local law. A change of legal contracting party needs a legally effective transfer; it is not achieved by editing a name. Notices use the account contact or RTL Help and the postal address above. An unenforceable provision does not invalidate the rest. --- L10: Programme Subscription, Cancellation and Refund Schedule Version: review-2026-09-19-v0.7 # L10: Programme Subscription, Cancellation and Refund Schedule Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Your purchase information RTL service supplier: RTL Clubs Ltd, 20-22 Wenlock Road, N1 7GU. Before payment show programme, covered children for a household purchase, actual payer, learner beneficiaries, base price, total price including taxes, currency, billing period, start/renewal date, any trial and its conversion price, minimum term if any, seller/merchant and collecting provider, cancellation route, technical requirements and applicable terms versions. Complete those particulars in the order; this schedule sets no cash prices. A payment button must clearly identify an obligation to pay. Free account acceptance alone is not a paid order. ## 2. Direct household purchases and programme-specific siblings The household tariff applies to direct parent purchases for Home Learning or parent-funded club access. Each programme is charged separately at its own base price P. Within that programme one child costs P, two cost 1.5P, three cost 2P, and n children cost P * (1 + 0.5 * (n - 1)). Here n is the positive whole number of covered siblings. No discount transfers across programmes. Two children in English cost 1.5 times the English base price. Maths for one of them adds the full Maths base price; adding the second to Maths changes only Maths to 1.5 times its own base price. This agreement sets no household cap or storefront rounding rule; the offered total must match approved pricing before sale. The club business licence does not use this household sibling formula or specify a learner-number allowance. Each learner retains their own identity and progress and may have different books. Normal progression does not require a new book purchase. Household printing of entitled materials is allowed under L01 and is separate from personalised profile entitlement. ## 3. Renewal and changes Club licences may be billed monthly, quarterly or annually and renew on the selected cycle. The licence continues while the relevant fees are paid unless ended under L02/G07; accrued and surviving terms continue after expiry. Only programmes identified in the order renew, at the dates and prices disclosed. Programmes can have separate renewal dates. Adding a sibling changes the relevant programme plan; show the resulting charge, any supported adjustment and effective date before confirmation. Do not silently add another programme. A downgrade must explain which learners retain paid access and when, without deleting their records. Any future price change must meet notice, consent and cancellation requirements applicable to the purchase route. No trial, pause or promotion exists unless expressly offered. ## 4. Cancelling future renewal Cancel Apple subscriptions using your Apple subscription settings; cancel Google Play subscriptions in Google Play's subscriptions area. Only if a direct purchase route is actually offered, its order must give [VERIFIED DIRECT CANCELLATION ROUTE]; a clear cancellation request may also be sent to Help > Contact Us. This does not assert that direct billing is available. Purchase-specific links must be supplied with the order and Help. Cancellation of future renewal normally leaves access until the paid period ends, unless a refund, lawful restriction or other disclosed change affects it. Deleting the app, leaving tuition or removing a tutor is not cancellation. You may cancel one programme without cancelling another. We must not create unnecessary obstacles to cancellation. ## 5. Cooling-off and early supply For a UK distance contract where the statutory right applies, you may cancel within 14 days after the contract is made, without giving a reason, by a clear statement to the identified trader. We provide cancellation information and a durable contract confirmation. Missing statutory information can extend rights. Applicable consumer rights are preserved for all payment routes. For paid digital content supplied during that period, loss of the cancellation right requires your prior express consent to immediate supply and acknowledgement that the right will be lost, with the required confirmation. Merely opening an account does not do this. For services starting early at your express request, a lawful proportionate amount may be payable for service supplied before cancellation if the statutory conditions are met; loss of the right on full performance requires the required acknowledgement. Starting a continuing subscription is not full performance of it. Classify content and services before selecting the separate wording in the acceptance specification. If early-supply permission is declined, offer commencement after the applicable cooling-off period rather than assuming consent. Where statutory cancellation requires a refund, we make it without undue delay and within the applicable legal deadline, ordinarily 14 days after notice for these contracts, through the original means unless you expressly agree otherwise and incur no fee. Store processing does not remove mandatory remedies owed by the relevant trader. ## 6. Faults and withdrawal of RTL access Statutory remedies for faulty or misdescribed content or services remain available. When RTL finally withdraws a paid RTL service, we will identify the payer, affected service and unused prepaid period, and seek return of the corresponding unused payment through the collecting provider's supported process. Where that route cannot deliver a remedy we owe, we will address an alternative lawful payment solution with the payer; a store refusal does not itself settle our obligations. We do not label a refund confirmed until payment-provider evidence supports that status. Account credit is not automatically a money refund. Apple's ordinary route is a refund request for Apple's decision. RTL cannot guarantee Apple's approval or a specific prorated amount. Google Play provides supported refund and revocation mechanisms, but the applicable transaction and integration must support the requested action. Contact Help > Contact Us if the available route does not resolve a remedy. We do not promise an automatic administrator-initiated store refund. RTL gives no discretionary compensation or goodwill payment for temporary restriction, interruption or termination. This does not remove a refund or other remedy required by law. The unused-prepayment treatment for final withdrawal above is separate from compensation. A refund is distinct from cancelling renewal and ending access. We will identify each action separately. Conduct restrictions do not become non-payment records and are not removed by paying again or restoring a purchase. ## 7. Independent tuition and history Tuition refunds are handled by the tuition supplier for fees it collected or was paid on its behalf. RTL does not undertake to refund those fees, without limiting liability for its own acts. A tutor's removal does not automatically cancel unaffected parent subscriptions. After entitlement ends, Passports and available history continue while RTL provides that service unless deletion is requested and carried out, or another lawful retention/withdrawal ground applies under G08. This does not include future paid content or lifetime access. ## 8. Optional cancellation form To: RTL Clubs Ltd, 20-22 Wenlock Road, N1 7GU, Help > Contact Us. "I give notice that I cancel my contract for [programme/service], ordered on [date]. Account/order reference: [reference]. Name and address: [details]. Date: [date]." Add a signature only if sending on paper. You can use any other clear statement; use the relevant store route as well to stop store renewal, with RTL assistance where needed. --- G01: Network Standards and Responsibility Charter Version: review-2026-09-19-v0.7 # G01: Network Standards and Responsibility Charter Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Responsibilities RTL Clubs Ltd supplies its agreed programme licences and software. Independent teaching providers supply tuition and run their own sessions, staff and premises. Permission to use RTL programmes is not certification of a provider, tutor or venue. RTL remains responsible for its own products, representations and data duties. ## 2. Provider identity and lawful operation Operators must show parents their actual legal supplier, contacts and any separate venue host or collection agent before enrolment. Keep organisation and all location records current. Schools follow the same operator terms. Providers must satisfy applicable local laws. These network terms impose no contractual insurance type, amount or evidence requirement. Overseas providers must assess local rules; UK registration and DBS terminology must not be presented as universal requirements. ## 3. Honest representation and licensed use Operators, tutors and partners must state their actual role and authority, use licensed materials and approved branding within their permissions, and make truthful claims. Do not promise guaranteed outcomes, unsupported verification or authority to bind RTL. Parents must use household materials within L01. Users retain ownership and rights in their independent work and personal information as applicable; programme rights remain with RTL or its licensors. ## 4. Cooperation and standards Provide necessary, proportionate information about compliance with your licence and report material changes affecting lawful access. Providers retain local checks and operational evidence. Do not routinely send criminal-record documents to RTL. RTL may decide access and licensing consequences under G07; that does not transfer management of tuition to RTL. ## 5. Fair treatment and hierarchy Everyone must respect others' dignity, privacy and lawful rights. Good-faith complaints, lawful criticism and whistleblowing are protected. The accepted role terms and applicable commercial/data schedules determine obligations and take precedence as stated there; governance does not create undisclosed prices. Local rules may add practical arrangements but cannot remove statutory rights or weaken incorporated standards. G06 covers reporting, G07 restrictions and G08 exit. Only the modules listed with a person's role acceptance bind that person contractually. --- G02: Local Provider Safeguarding Responsibilities Version: review-2026-09-19-v0.7 # G02: Local Provider Safeguarding Responsibilities Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Local accountability The teaching provider must establish safeguarding arrangements appropriate to its learners, activities, premises and local law before teaching. It must identify a responsible safeguarding contact and an alternative route if that person is unavailable or implicated. A sole provider must give families a credible alternative reporting route. RTL sets licence conditions; it does not recruit or check tutors, supervise sessions or act as the local safeguarding service. ## 2. Recruitment and eligibility The provider must assess each role, complete legally required checks and suitability steps lawfully before relevant activity, and prevent ineligible or barred individuals undertaking it. Assess identity, references, required qualifications, relevant overseas history and right to work as applicable. Keep evidence securely with justified access and retention. Assess rechecking on relevant changes and local requirements, rather than relying indefinitely on an old certificate. For England and Wales use the current regulated-activity rules, including the removal of the relevant supervision exemption from 1 September 2026. Assess the specific role; do not infer that all volunteers are automatically eligible for every check. Scotland and Northern Ireland require their own current assessment and routes. Overseas providers use local requirements. Do not request a higher-level check without eligibility or routine upload of certificates to RTL. ## 3. Preventing harm Provide staff with induction, proportionate training, reporting routes and supervision appropriate to their responsibilities. Apply G03 boundaries and G05 session arrangements. Consider abuse, neglect, bullying, discrimination, online contact, exploitation and risks arising from lone working. Agree reasonable adjustments without excusing unsafe or discriminatory treatment. Make arrangements known to parents and explain safe reporting to children in an age-appropriate way. ## 4. Responding to concerns Take immediate steps within your role to protect a child, contact emergency or local protection services when appropriate, and make required referrals without waiting for RTL. Listen without leading questions, record facts and the child's words accurately, and do not promise secrecy or undertake your own criminal investigation. Share only necessary information through secure routes. Allegations involving the safeguarding contact must use the alternative route. ## 5. Network notification Notify RTL through the restricted concern route of matters materially affecting professional access, programme use or brand permission. Protect the child and any official investigation when deciding what may be shared. RTL may preserve evidence and consider G07 restrictions without finding criminal guilt. Providers and tutors must cooperate with lawful authority requests and must not retaliate against reporters. Retain sensitive concern files separately from routine progress records under a lawful local schedule. --- G03: Tutor and Adult Conduct Code Version: review-2026-09-19-v0.7 # G03: Tutor and Adult Conduct Code Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Respect and professional boundaries Tutors and other adults acting professionally must treat children, families, colleagues and RTL staff respectfully. No threats, humiliation, discriminatory abuse, bullying, corporal punishment, sexual conduct with children, grooming or exploitation is permitted. Do not use gifts, secrets, favouritism or private contact to create an inappropriate relationship. Respectful conduct also applies to RTL's dealings with providers and families. ## 2. Contact and communication Use authorised professional communication routes. Do not arrange secret or inappropriate private contact with children, use personal social-media contact to bypass safeguards, or disclose private learner information. One-to-one teaching, transport, physical assistance and personal care must follow the provider's risk assessment, applicable law and agreed family arrangements. Physical contact must be necessary, appropriate and consistent with safeguarding and law, never punishment or intimidation. ## 3. Images, records and teaching Do not photograph, record or publish a child without the required lawful basis, permissions and clear purpose. Optional publicity is separate from learning. Do not pressure children or parents to agree. Keep observations accurate and relevant; distinguish observed fact from interpretation. Do not falsify records, misrepresent qualifications or claim RTL has vetted you. Use accessible, age-appropriate teaching and reasonable adjustments. ## 4. Reporting and cooperation Raise concerns under G06 and local safeguarding procedures. Do not retaliate, coach accounts, destroy evidence or obstruct a lawful report. An unproven allegation is not automatically malicious. Deliberately fabricated reports may be considered only on evidence, not because a complaint is inconvenient. Confidentiality protects privacy but does not prevent protected disclosures or lawful criticism. G07 determines RTL access consequences; providers separately address employment or tuition decisions lawfully. --- G04: Parent and Learner Conduct Code Version: review-2026-09-19-v0.7 # G04: Parent and Learner Conduct Code Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Working together Parents, tutors and RTL staff should speak respectfully and listen to concerns. Parents must not threaten, harass or abuse other families, tutors or staff. Tutors and providers owe the same respect to parents and children. You may complain, disagree, leave a lawful review or report a concern in good faith. ## 2. Helping your child participate Give your provider necessary attendance, collection and emergency information and tell it about relevant changes. Agree reasonable adjustments and any support your child needs. Follow the provider's lawful collection and session arrangements, supplied with its tuition terms. These local duties do not make RTL responsible for running sessions. Do not share another child's image or private information without lawful permission. ## 3. For learners Be kind. Give others a chance to learn. Use materials and devices carefully. Tell a trusted adult if you feel worried, hurt or left out. You can ask for help and take a break as agreed with the adult looking after the session. Adults should explain expectations in a way you understand and help you follow them. ## 4. When something goes wrong Providers must consider age, disability, additional needs and the circumstances before responding to behaviour. No humiliating punishment or automatic exclusion because of a disability is allowed. Immediate protective action may be needed for a safety concern, followed by a fair assessment and reasonable adjustments. G06 explains concerns and G07 covers RTL access decisions. Children do not personally accept adult contractual liability through this code. --- G05: Local Provider Session and Premises Responsibilities Version: review-2026-09-19-v0.7 # G05: Local Provider Session and Premises Responsibilities Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Before opening a session The provider must assess whether its actual activities, ages and hours require registration, permission or other local compliance as tuition, childcare or a school. Check the rules of the relevant UK nation or overseas jurisdiction. A programme licence is not regulatory permission. Register each location in the app and maintain the L07 location information, including for home and shared venues. ## 2. People and supervision Provide staffing, competence and supervision suitable for the learners and activity under local law and risk assessment. Record attendance and handover, authorised collectors and emergency contacts. Establish action for an uncollected or missing child. Staff must know who is responsible throughout arrivals, sessions, breaks and departure. Do not leave children with unauthorised adults or assume a venue host provides supervision. ## 3. Premises and health Assess safe entry, exits, fire, evacuation, first aid, accessibility, toilets, visitors, equipment and foreseeable hazards. Allocate premises duties with the host without displacing either party's legal duties. For homes assess household members, private areas, pets and visitors. Obtain necessary landlord and other permissions required for lawful use. Handle allergies, medicines, illness and personal care under appropriate local arrangements and privacy safeguards. Do not put sensitive details into unrestricted learner notes. ## 4. Online and individual teaching Assess platform access, appropriate visibility, recording, communication routes, one-to-one boundaries and action if a child reports harm remotely. Explain any parent supervision expected before sessions. Do not record by default or move children to unapproved private communication channels. Consider lone-working and transport risks where relevant. ## 5. Incidents and review Stop unsafe activity, seek emergency help where needed, record material facts and make required local reports. Follow G02/G06 for protection concerns and notify RTL of matters affecting licence or network access. Review arrangements after a significant incident, venue change or material activity change and at locally appropriate intervals. The provider performs and owns these operational tasks; RTL's location record is not an inspection or safety certificate. --- G06: Complaints, Reporting and Whistleblowing Policy Version: review-2026-09-19-v0.7 # G06: Complaints, Reporting and Whistleblowing Policy Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Where to raise a concern For RTL programme, account or billing concerns use Contact Us in website or in-app Help. Select "Programme or app", "Billing", "Privacy complaint", "Tuition provider" or "Concern about a child or tutor". If the form is unavailable or unsuitable, write to 20-22 Wenlock Road, N1 7GU. Sensitive concerns use Help > Contact Us (concern about a child or tutor). These routes and their accessibility must be verified before publication. Help is not an emergency service and no round-the-clock monitoring is promised. For tuition, the named provider's contact is in your tuition agreement. You may report directly to RTL without first confronting a provider or tutor. In immediate danger in the UK call 999; overseas use the local emergency number. Contact appropriate local child-protection services or police where needed. Do not wait for an RTL reply or internal review before making a necessary external report. ## 2. What happens to a report Give enough information to identify the concern and affected service, including dates where known. Do not send unnecessary criminal-record or medical documents. RTL will route reports to people who need them, distinguish local tuition matters from its own service and network-access decisions, and consider conflicts of interest. Local providers and competent authorities handle local safeguarding duties. RTL remains responsible for duties applicable to its own actions and data. RTL will assess available information, preserve relevant evidence, request clarification where appropriate and explain the next step so far as safe and lawful. Anonymous reports may be considered, although missing information can limit action. Confidentiality will be respected but absolute secrecy cannot be promised where protection or legal duties require disclosure. For general complaints, publish realistic contact arrangements when resourcing is confirmed; this does not displace a statutory deadline. For data-protection complaints, use Help > Contact Us and identify it as a privacy complaint, or write to 20-22 Wenlock Road, N1 7GU. We will acknowledge receipt within 30 days, make appropriate enquiries without undue delay, keep you informed of progress and communicate the outcome without undue delay. This legal requirement is separate from any voluntary service target and from the deadlines for exercising data rights. You may approach the ICO or another competent authority; its own complaint-handling procedure applies. ## 3. Fairness and review RTL will distinguish allegations, established facts and network judgements. Where a concern may justify restriction, G07 applies. The person concerned should normally receive sufficient information to respond, with protective redactions or delayed disclosure where necessary. Complainants may ask for review of complaint handling through Help > Contact Us (review request), without entitlement to another person's confidential records. An available person uninvolved in the original decision should review conflicts and material issues. ## 4. Protection for reporting Good-faith complaints, whistleblowing, lawful criticism and reports to regulators or police are not prohibited by confidentiality or brand clauses. No retaliation is permitted. Failure to substantiate a report does not make it malicious. A finding of intentional fabrication requires evidence and fair consideration. Anyone may seek legal advice or use available external remedies without completing this procedure. Store sensitive reports separately with restricted access and lawful retention. --- G07: Network Access Restrictions, Removal and Review Policy Version: review-2026-09-19-v0.7 # G07: Network Access Restrictions, Removal and Review Policy Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Purpose and grounds RTL may restrict its software, programme licences and brand permissions to address an identified material breach, copyright or other IP infringement, material misuse, unlawful use, unauthorised data access, misleading use of RTL branding or a serious credible concern about continued professional access. It acts on its own services and permissions, not as an authority closing independent tuition businesses or deciding criminal guilt. A complaint count alone is not a removal rule. ## 2. Temporary protection An authorised decision maker may impose immediate temporary restrictions where a serious credible concern creates a risk that cannot reasonably wait. Record the information considered, credibility and severity, affected permissions, why a lesser measure is insufficient, decision maker, time and review trigger and next review date proportionate to the risk. Consider urgency, corroboration and possible mistaken identity; do not require final proof before a necessary temporary protective step. Revisit restrictions as relevant information arrives and avoid open-ended suspension without active review. ## 3. Response and permanent decisions Give reasons and sufficient relevant information for a response where safe and lawful. Explain withheld information in general terms when possible. Consider the response and material exculpatory information. RTL may permanently remove professional access for substantiated serious misconduct, material misuse, copyright or other IP infringement, material licence or data misuse, materially misleading representations, or conduct creating a material and reasonably evidenced risk to RTL's reputation. It may also remove access for a material remediable breach not corrected after reasonable warning, or a documented continuing serious risk that proportionate lesser restrictions cannot adequately address. Reputation grounds require identified conduct and a reasoned link to material harm; dislike, an unsupported allegation or embarrassment caused by lawful reporting is insufficient. Repeated substantiated breaches may be relevant; duplicate reports are not separate incidents. No one-complaint or three-complaint automatic threshold applies. Document the grounds, evidence assessment, alternatives, scope and reasons. Distinguish the contractual access judgement from allegations of criminal conduct. Do not publish allegations as proved facts. A lawful report or critical review is not itself a ground for removal. ## 4. Scope and accounts Removing a tutor means all professional access across the RTL network. Do not allow re-entry through another club or role while that restriction remains. Preserve independently justified parent access unless a separate decision explains why it too must be restricted. Organisation restrictions must identify the organisation and affected users rather than treating every parent as culpable. Keep Help, review contact and appropriate billing information available through a usable route. Conduct state is separate from paid/unpaid state. Record payments accurately. A renewal, repayment or purchase restoration cannot clear a conduct restriction. Restrict only permissions justified by the decision and protect evidence and lawful learner records. Do not implement unexplained blank screens as an enforcement notice. ## 5. Review The affected person may ask Help > Contact Us (review request) for review, explaining any error, new evidence or disproportionate effect. Provide the request route with the decision. An available reviewer uninvolved in the original decision should reassess relevant grounds and conflicts; arrange suitable independent input if no such internal person is available. Do not invent a staffed appeals panel or fixed turnaround. A late request with a reasonable explanation should still be considered. Give the outcome and reasons where safe. Restrictions may continue during review where justified, but must be reconsidered if the risk changes. External referrals do not wait for review. ## 6. Money and restoration Identify the actual payer and affected service. Ending access, cancelling renewal and requesting/refunding payment are separate actions under L10. No tuition refund is promised for money RTL did not collect. Do not automatically cancel unaffected parent subscriptions. RTL gives no discretionary compensation or goodwill payments for temporary restriction or removal. Mandatory refunds and other non-excludable remedies remain available, and L10 separately governs unused prepayments after final withdrawal. Restore professional access only after an authorised documented decision that the relevant grounds have been resolved; a payment event is insufficient. Follow G08 for continuity and evidence. --- G08: Passport, Learner History and Provider Exit Policy Version: review-2026-09-19-v0.7 # G08: Passport, Learner History and Provider Exit Policy Review version: review-2026-09-19-v0.7 | Not effective as a contract Status: DRAFT FOR MANAGEMENT AND SOLICITOR REVIEW. Proposed contractual wording; not evidence of live implementation. ## 1. Continuing records Cancelling a subscription or leaving a club does not by itself delete a learner's Passport or history. Families may request deletion. Subject to the learner's rights, lawful retention and this policy, a Passport and its available history continue after paid access ends for as long as RTL provides that service. This is not a lifetime commitment or entitlement to new paid content. ## 2. Availability and withdrawal RTL may change or discontinue the Passport or history service. Reasons may include a business decision to discontinue it, replacement of the service, proportionate operational or maintenance costs, security, legal requirements or the absence of a lawful basis to provide access. A decision must be genuine and applied fairly; it must not be used to suppress a complaint, defeat a data-rights request or evade an existing obligation. Before a planned discontinuation, RTL will give reasonable advance notice appropriate to the impact and an opportunity to request a copy of available records through Help. Urgent legal or security action may require shorter notice; RTL will explain when safe and lawful. No fixed duration of continued availability is promised. Existing accepted commitments must be assessed before applying changed terms to an existing Passport. ## 3. Deletion requests and rights A learner or an adult with appropriate authority may ask through website or in-app Help, or by post to RTL Clubs Ltd, 20-22 Wenlock Road, N1 7GU, for deletion of the Passport and associated personal information. RTL will assess identity, authority and the learner's own rights, act within the applicable legal deadlines and explain any information it must lawfully retain. Deletion may be limited by a legal obligation, a justified legal claim or another applicable exception. Such retained information is restricted to that purpose, not kept in ordinary use because a subscription once existed. RTL reviews retention against the continuing purpose. Information no longer needed must be deleted or anonymised even if nobody requests it. Continuing app availability, lawful retention and data-subject rights are separate. Ending the history service does not remove a person's rights to information that is still held. L09 explains the relevant processing and rights. ## 4. Provider and tutor exit When a tutor leaves, the provider removes assignment access and arranges authorised handover. When a provider exits, it stops new licensed activity and branded representation and tells affected families what changes. Do not promise replacement tuition or transfer learners without appropriate authority and lawful sharing. Keep safeguarding files separate from learning records. Do not falsify, erase or withhold original records to pressure a payer. Parents and learners may retain lawfully obtained completed work and reports. Staff return or securely deal with working copies under lawful instructions. Licence expiry ends future commercial use of RTL materials, not ownership of the child's work. ## 5. Separate access and payments Identify affected organisations, professional roles, legitimate parent access and the actual payer. A partner's departure does not terminate independent clubs. G07 governs restrictions, L10 governs RTL payment treatment, and the named provider's tuition terms govern tuition. Record lawful handover, access removal, notices and outstanding requests without unnecessary duplication of sensitive information.