Privacy Policy

SBT Reading Tutors LLC Website: https://sbtreadingtutors.com
Effective Date: July 4, 2025
Last Updated: March 30, 2026

Introduction
Scope and Application
Definitions
Information We Collect
How We Use Your Information
Third-Party Platforms and Service Providers
Information Sharing and Disclosure
Educational Privacy and FERPA Compliance
Children's Privacy and COPPA Compliance
Data Security and Protection
Data Retention and Deletion
Your Rights and Choices
Cookies and Tracking Technologies
International Data Transfers
Changes to This Privacy Policy
Contact Information

1. Introduction

SBT Reading Tutors LLC ("Company," "we," "us," or "our") is committed to protecting the privacy and security of personal information collected through our educational tutoring services. This Privacy Policy explains how we collect, use, share, and protect information when you use our website located at https://sbtreadingtutors.com (the "Website"), our online tutoring services, educational materials, and all related services, features, and content (collectively, the "Services").

We understand that privacy is especially important when it comes to educational services and the protection of student information. As an educational service provider, we are committed to complying with applicable privacy laws, including the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), and other relevant federal and state privacy regulations.

This Privacy Policy applies to all users of our Services, including students, parents, guardians, and any other individuals who interact with our platform. By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

We take a privacy-by-design approach to our services, implementing appropriate technical, administrative, and physical safeguards to protect personal information throughout its lifecycle. We are transparent about our data practices and provide individuals with meaningful choices about how their information is collected and used.

2. Scope and Application

This Privacy Policy applies to all information collected by SBT Reading Tutors LLC through our Website, mobile applications, online tutoring platform, and any other digital or offline interactions with our Services. This includes information collected directly from users, information received from third parties, and information automatically collected through our technology platforms.

2.1 Covered Services
This Privacy Policy covers the following services and platforms operated by SBT Reading Tutors LLC:
Our primary website at https://sbtreadingtutors.com and any associated subdomains or microsites. Our online tutoring platform, including video conferencing capabilities, interactive learning tools, and educational content delivery systems. Mobile applications developed and operated by SBT Reading Tutors LLC for accessing our tutoring services. Customer support systems, including help desk platforms, chat systems, and communication tools. Marketing and promotional platforms, including email marketing systems and social media presence. Payment processing systems and billing platforms used to facilitate transactions.

2.2 Geographic Scope
This Privacy Policy applies to our operations within the United States. As specified in our Terms of Service, SBT Reading Tutors LLC provides services exclusively to individuals located within the United States and does not conduct business with individuals or entities located outside the United States.

2.3 Excluded Information
This Privacy Policy does not apply to information collected about our employees, job applicants, independent contractors, or business partners in their capacity as such. These individuals are covered by separate privacy notices and employment-related privacy policies.
Additionally, this Privacy Policy does not apply to third-party websites, applications, or services that may be linked to or integrated with our Services. We encourage users to review the privacy policies of any third-party services they choose to use in connection with our platform.

3. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set forth below:
"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This includes both information that directly identifies an individual (such as name, email address, or phone number) and information that could be used to identify an individual when combined with other information.
"Educational Records" means records that are directly related to a student and maintained by an educational agency or institution or by a party acting for the agency or institution. This includes tutoring session recordings, progress reports, assessment results, and communications between tutors and students or parents.
"Student" means any individual who receives or has received educational services from SBT Reading Tutors LLC, regardless of age, and includes both current and former students.
"Parent" means a parent of a student and includes a natural parent, a guardian, or an individual acting as a parent in the absence of a parent or guardian.
"Third-Party Service Providers" means companies, organizations, or individuals that provide services to SBT Reading Tutors LLC to support our operations, including but not limited to technology platforms, payment processors, and analytics providers.
"Processing" means any operation or set of operations performed on personal information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
"De-identified Information" means information that has been processed to remove or obscure personal identifiers such that the information is no longer reasonably linked or linkable to an identified or identifiable individual.

4. Information We Collect

We collect various types of information to provide and improve our educational tutoring services. The information we collect falls into several categories, each serving specific purposes related to delivering high-quality educational experiences while maintaining appropriate privacy protections.

4.1 Information You Provide Directly
We collect information that you voluntarily provide to us when you create an account, use our Services, or communicate with us. This information is essential for providing personalized tutoring services and maintaining effective communication with students and families.

Account Registration Information: When you create an account with SBT Reading Tutors LLC, we collect basic identifying information including your full name, email address, phone number, and mailing address. For student accounts, we also collect the student's date of birth to verify age eligibility and ensure compliance with applicable privacy laws. We may request additional demographic information such as grade level, school district, and educational goals to help us tailor our services to individual needs.
Educational Background and Assessment Information: To provide effective tutoring services, we collect information about the student's current reading level, academic history, learning objectives, and any special educational needs or accommodations. This may include results from standardized tests, school report cards, previous tutoring experiences, and specific areas where the student needs improvement. We also collect information about learning preferences, such as preferred learning styles and optimal session times.
Communication and Correspondence: We maintain records of all communications between our staff, tutors, students, and parents or guardians. This includes emails, phone calls, chat messages, and any other forms of correspondence. These records help us provide consistent service, track progress, and address any concerns or questions that may arise during the tutoring relationship.
Payment and Billing Information: When you purchase our services, we collect payment information necessary to process transactions. This includes billing addresses, payment method details (though we do not store complete credit card numbers), and transaction history. We work with third-party payment processors to securely handle sensitive financial information in compliance with industry standards.
Feedback and Survey Responses: We regularly collect feedback from students and parents about their tutoring experience through surveys, evaluation forms, and informal feedback sessions. This information helps us improve our services and ensure that we are meeting the educational needs of our students.

4.2 Information Collected Automatically
Our technology platforms automatically collect certain information when you access and use our Services. This automatic collection helps us maintain platform security, improve user experience, and analyze usage patterns to enhance our educational offerings.

Device and Technical Information: We automatically collect information about the devices and software you use to access our Services, including device type, operating system, browser type and version, screen resolution, and device identifiers. This information helps us ensure compatibility and optimize the performance of our platform across different devices and configurations.
Usage and Activity Information: We track how you interact with our Services, including pages visited, features used, time spent on different sections of our platform, and navigation patterns. For tutoring sessions, we may collect information about session duration, participation levels, and engagement with educational materials. This data helps us understand how our Services are being used and identify areas for improvement.
Location Information: We may collect general location information based on your IP address to ensure compliance with our geographic restrictions and to provide location-appropriate services. We do not collect precise geolocation information unless specifically required for service delivery and with appropriate consent.
Log Files and Server Data: Our servers automatically record information when you access our Services, including IP addresses, browser requests, referring URLs, access times, and error logs. This information is used for system administration, security monitoring, and troubleshooting technical issues.

4.3 Information from Third Parties
We may receive information about you from various third-party sources, which helps us provide comprehensive services and maintain accurate records.

Educational Institutions: If you are referred to our services by a school, school district, or other educational institution, we may receive information about your educational background, current academic standing, and specific learning needs. This information is shared in accordance with applicable educational privacy laws and institutional policies.
Parent and Guardian Information: Parents or guardians may provide information about their children when enrolling them in our services. This includes educational history, learning challenges, family circumstances that may affect learning, and communication preferences.
Third-Party Platforms: When you use third-party platforms integrated with our Services (such as video conferencing tools or learning management systems), we may receive information from these platforms about your usage and interactions. This information is collected and used in accordance with the privacy policies of these third-party platforms and our agreements with them.
Referral Sources: If you are referred to our services by another individual or organization, we may receive basic contact information and background about your educational needs from the referring party.

4.4 Sensitive Information
We recognize that some of the information we collect may be considered sensitive, particularly information related to educational performance, learning disabilities, and family circumstances. We implement additional safeguards for sensitive information and limit its collection to what is necessary for providing effective educational services.

Learning Disabilities and Special Needs: When relevant to providing appropriate tutoring services, we may collect information about learning disabilities, special educational needs, accommodations required, and therapeutic interventions. This information is collected only with appropriate consent and is used solely to ensure that our tutoring approach is tailored to the student's individual needs.
Academic Performance Data: We collect and maintain detailed records of student progress, including assessment scores, improvement metrics, and academic achievements. This information is essential for tracking educational outcomes and adjusting tutoring strategies as needed.
Family and Household Information: In some cases, we may collect information about family circumstances that could affect a student's learning, such as household composition, primary language spoken at home, and socioeconomic factors. This information is collected only when relevant to providing effective educational support and with appropriate consent.

5. How We Use Your Information

We use the information we collect for various purposes related to providing, maintaining, and improving our educational tutoring services. Our use of personal information is guided by the principles of data minimization, purpose limitation, and educational necessity.

5.1 Primary Educational Purposes

Service Delivery and Instruction: The primary purpose for collecting and using personal information is to provide high-quality, personalized tutoring services. We use student information to assess learning needs, develop customized lesson plans, track academic progress, and adjust instructional strategies based on individual student performance. This includes analyzing assessment results, monitoring engagement during sessions, and identifying areas where additional support may be needed.
Tutor Matching and Assignment: We use information about student learning preferences, academic needs, and scheduling requirements to match students with appropriate tutors. This ensures that each student is paired with a tutor who has the relevant expertise and teaching style to support their specific learning objectives.
Progress Monitoring and Reporting: We use collected information to track student progress over time, generate progress reports for parents and guardians, and provide feedback on academic improvement. This includes analyzing session data, assessment results, and tutor observations to provide comprehensive insights into student development.
Educational Content Customization: We use information about student reading levels, learning preferences, and academic goals to customize educational materials and select appropriate content for tutoring sessions. This ensures that instructional materials are appropriately challenging and aligned with individual learning objectives.

5.2 Operational and Administrative Purposes

Account Management and Customer Service: We use personal information to manage user accounts, process registrations, handle billing and payments, and provide customer support. This includes responding to inquiries, resolving technical issues, and maintaining accurate account records.
Communication and Coordination: We use contact information to communicate with students, parents, and guardians about scheduling, session reminders, progress updates, and important announcements. This includes sending appointment confirmations, rescheduling notifications, and educational resources.
Quality Assurance and Improvement: We analyze usage data and feedback to evaluate the effectiveness of our services, identify areas for improvement, and develop new educational offerings. This includes reviewing session recordings for quality assurance purposes and analyzing student outcomes to refine our instructional approaches.
Legal and Regulatory Compliance: We use personal information as necessary to comply with applicable laws, regulations, and legal obligations, including educational privacy requirements, tax reporting, and record-keeping mandates.

5.3 Secondary Purposes

Research and Development: With appropriate consent and safeguards, we may use de-identified or aggregated information for research purposes to improve educational methodologies, develop new instructional tools, and contribute to the broader understanding of effective tutoring practices.
Marketing and Outreach: We may use contact information to send promotional materials, educational resources, and information about new services to existing customers. All marketing communications include opt-out mechanisms, and we respect user preferences regarding promotional communications.
Security and Fraud Prevention: We use information to protect the security and integrity of our Services, prevent unauthorized access, detect and prevent fraud, and ensure the safety of our platform for all users.

6. Third-Party Platforms and Service Providers

SBT Reading Tutors LLC relies on various third-party platforms and service providers to deliver our educational services effectively. We carefully select these partners based on their privacy and security practices, and we implement appropriate safeguards to protect personal information when it is shared with or processed by third parties.

6.1 Video Conferencing and Communication Platforms
Platform Integration: Our tutoring services are delivered through secure video conferencing platforms that enable real-time interaction between tutors and students. These platforms may include services such as Zoom, Microsoft Teams, Google Meet, or other professional video conferencing solutions. When you participate in tutoring sessions, your personal information and session data may be processed by these platforms in accordance with their privacy policies and our service agreements.
Data Sharing with Video Platforms: Information shared with video conferencing platforms typically includes participant names, email addresses, session scheduling information, and any content shared during sessions (such as screen sharing, chat messages, or file uploads). Some platforms may also collect technical information about your device and internet connection to optimize video quality and platform performance.
Session Recording and Storage: Tutoring sessions may be recorded for quality assurance, training purposes, and to allow students to review session content. These recordings are stored on secure third-party platforms with appropriate access controls and retention policies. We ensure that all recording practices comply with applicable privacy laws and obtain necessary consent before recording sessions.
Security and Privacy Protections: We select video conferencing platforms that implement enterprise-grade security measures, including end-to-end encryption, secure data transmission, and robust access controls. Our agreements with these platforms include specific privacy and security requirements, data processing limitations, and incident response procedures.

6.2 Learning Management and Educational Technology Platforms
Educational Content Delivery: We may use third-party learning management systems (LMS) or educational technology platforms to deliver instructional content, track student progress, and facilitate interactive learning experiences. These platforms help us provide structured, engaging educational experiences while maintaining detailed records of student engagement and progress.
Student Data Processing: Educational technology platforms may process various types of student information, including learning progress data, assessment results, time spent on activities, and interaction patterns with educational content. This information is used to personalize learning experiences and provide insights into student performance.
Integration and Interoperability: Our educational technology partners are selected based on their ability to integrate securely with our primary platform while maintaining appropriate privacy protections. We ensure that data sharing between platforms is limited to what is necessary for educational purposes and is governed by appropriate data processing agreements.

6.3 Payment Processing and Financial Services
Payment Gateway Integration: We partner with reputable payment processing companies to handle financial transactions securely. These processors handle sensitive payment information, including credit card details, billing addresses, and transaction records, in compliance with Payment Card Industry (PCI) Data Security Standards.
Financial Data Protection: Our payment processors implement industry-standard security measures to protect financial information, including encryption, tokenization, and secure data transmission. We do not store complete payment card information on our systems, instead relying on secure tokens provided by our payment processors.
Billing and Subscription Management: Third-party billing platforms may be used to manage subscription services, process recurring payments, and handle billing inquiries. These platforms process customer contact information, payment preferences, and billing history to facilitate smooth financial transactions.

6.4 Customer Relationship Management and Support Systems
CRM Platform Integration: We use customer relationship management (CRM) systems to maintain comprehensive records of customer interactions, track service delivery, and provide personalized support. These systems may be hosted by third-party providers who process customer contact information, service history, and communication records. Student Management and Scheduling Platform: SBT Reading Tutors LLC uses TutorBird (tutorbird.com) as its primary student management and scheduling platform. TutorBird processes student enrollment information, lesson scheduling, attendance records, invoicing, billing history, and parent and guardian communications. Information shared with TutorBird is used solely for the purpose of managing our tutoring operations and is governed by TutorBird's Privacy Policy, available at tutorbird.com/privacy-policy. We have reviewed TutorBird's data handling practices and determined them to be consistent with our commitment to protecting student and family information. Help Desk and Support Tools: Customer support is facilitated through third-party help desk platforms that enable efficient ticket management, live chat support, and knowledge base access. These platforms process customer inquiries, support requests, and resolution records. Communication and Marketing Platforms: We may use third-party email marketing platforms, SMS services, and communication tools to send service-related notifications, educational resources, and promotional materials. These platforms process contact information and communication preferences in accordance with applicable privacy laws and user consent. 6.5 Analytics and Performance Monitoring
Website and Platform Analytics: We use third-party analytics services to understand how users interact with our website and platform, identify areas for improvement, and optimize user experience. These services may collect information about user behavior, device characteristics, and usage patterns.
Educational Analytics: Specialized educational analytics platforms may be used to analyze student learning patterns, assess the effectiveness of instructional approaches, and generate insights for improving educational outcomes. These platforms process de-identified or aggregated student data to protect individual privacy while enabling meaningful analysis.
Performance and Security Monitoring: Third-party monitoring services help us maintain platform performance, detect security threats, and ensure system reliability. These services may process technical information about system performance, user access patterns, and potential security incidents.

6.6 Cloud Storage and Infrastructure Services
Data Storage and Hosting: Our platform and services are hosted on secure cloud infrastructure provided by reputable cloud service providers. These providers process and store various types of data, including user account information, educational content, and system logs, in secure data centers with appropriate physical and technical safeguards.
Backup and Disaster Recovery: We use third-party backup and disaster recovery services to ensure data availability and business continuity. These services process copies of our data in secure, geographically distributed locations with appropriate access controls and encryption.
Content Delivery Networks: To optimize platform performance and ensure reliable access to educational content, we may use content delivery networks (CDNs) that cache and distribute content from multiple geographic locations. These services may process user request information and content access patterns.

6.7 Third-Party Data Protection Measures
Contractual Safeguards: All third-party service providers are required to enter into comprehensive data processing agreements that specify privacy and security requirements, limit data use to specified purposes, and establish incident response procedures. These agreements ensure that third parties maintain appropriate protections for personal information.
Due Diligence and Vendor Management: We conduct thorough due diligence on all third-party providers, including assessment of their privacy practices, security measures, and compliance with applicable laws. We maintain ongoing oversight of vendor performance and regularly review their privacy and security practices.
Data Minimization and Purpose Limitation: We limit the personal information shared with third parties to what is necessary for the specific service being provided. Third parties are contractually prohibited from using personal information for purposes other than those specified in our agreements.
Incident Response and Breach Notification: Our agreements with third-party providers include specific requirements for incident response, breach notification, and remediation procedures. We maintain the ability to audit third-party security practices and require prompt notification of any security incidents that may affect personal information.

We are committed to protecting the privacy of personal information and limit sharing to circumstances that are necessary for providing our educational services, complying with legal obligations, or protecting the rights and safety of our users. All information sharing is conducted in accordance with applicable privacy laws and our contractual obligations.

7.1 Sharing with Educational Stakeholders

Parents and Guardians: We regularly share information about student progress, session attendance, and educational outcomes with parents and guardians. This includes progress reports, assessment results, tutor feedback, and recommendations for continued learning. Such sharing is essential for maintaining family involvement in the educational process and ensuring coordinated support for student learning.
Educational Institutions: When students are referred to our services by schools or school districts, we may share relevant information about student progress and outcomes with these institutions as permitted by law and with appropriate consent. This sharing helps ensure continuity of educational support and allows schools to make informed decisions about student placement and additional services.
Other Educational Service Providers: With appropriate consent, we may share information with other educational service providers working with the same student to ensure coordinated and comprehensive educational support. This may include sharing information with speech therapists, occupational therapists, or other specialists involved in the student's educational program.

7.2 Sharing for Operational Purposes

Service Providers and Contractors: We share personal information with third-party service providers and contractors who assist us in delivering our services, as described in Section 6 of this Privacy Policy. This includes technology platforms, payment processors, customer support systems, and other operational partners. All such sharing is governed by comprehensive data processing agreements that limit the use of personal information to specified purposes.
Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, personal information may be transferred to the acquiring entity as part of the transaction. We will provide notice of any such transfer and ensure that the acquiring entity agrees to protect personal information in accordance with this Privacy Policy or provide equivalent protections.
Professional Advisors: We may share personal information with professional advisors, including attorneys, accountants, and consultants, when necessary for business operations, legal compliance, or dispute resolution. Such sharing is limited to what is necessary for the specific professional service being provided.

7.3 Legal and Regulatory Disclosures

Legal Compliance: We may disclose personal information when required by law, regulation, legal process, or government request. This includes responding to subpoenas, court orders, law enforcement requests, and regulatory inquiries. We will provide notice of such disclosures when legally permitted and will challenge overly broad or inappropriate requests.
Protection of Rights and Safety: We may disclose personal information when we believe it is necessary to protect the rights, property, or safety of SBT Reading Tutors LLC, our users, or others. This includes investigating potential violations of our Terms of Service, preventing fraud or abuse, and responding to emergency situations.
Regulatory Reporting: We may be required to report certain information to educational authorities, licensing bodies, or other regulatory agencies as part of our compliance obligations. Such reporting is conducted in accordance with applicable laws and regulations.

7.4 Consent-Based Sharing

Marketing and Promotional Partners: With explicit consent, we may share contact information with carefully selected educational partners or service providers who offer complementary services that may be of interest to our users. Users can opt out of such sharing at any time through their account settings or by contacting us directly.
Research and Academic Studies: With appropriate consent and ethical review, we may share de-identified or aggregated information with researchers, academic institutions, or educational organizations for studies aimed at improving educational outcomes or advancing the understanding of effective tutoring practices.

7.5 Limitations on Information Sharing

No Sale of Personal Information: We do not sell personal information to third parties for monetary consideration. Any sharing of personal information is conducted for legitimate business purposes related to providing our educational services or complying with legal obligations.
Minimal Disclosure Principle: When sharing personal information is necessary, we limit such sharing to the minimum amount of information required for the specific purpose. We regularly review our information sharing practices to ensure they remain necessary and proportionate.
Ongoing Monitoring: We maintain oversight of all third parties with whom we share personal information and regularly review their privacy and security practices to ensure continued compliance with our standards and applicable laws.

8. Educational Privacy and FERPA Compliance

As an educational service provider, SBT Reading Tutors LLC is committed to complying with the Family Educational Rights and Privacy Act (FERPA) and other applicable educational privacy laws. We recognize the special sensitivity of educational records and implement appropriate safeguards to protect student privacy while enabling effective educational services.

8.1 FERPA Applicability and Compliance

Educational Records Protection: We treat all information directly related to students and maintained in connection with our tutoring services as educational records subject to FERPA protections. This includes tutoring session records, progress assessments, communication logs, and any other information that could be used to identify a student and is related to their educational experience with our services.
Written Consent Requirements: Except as permitted by FERPA exceptions, we obtain written consent from parents (for students under 18) or eligible students (18 and older) before disclosing personally identifiable information from educational records. This consent specifies the records to be disclosed, the purpose of the disclosure, and the parties to whom the disclosure may be made.
Directory Information Limitations: We do not designate any student information as "directory information" that could be disclosed without consent. All student information is treated as protected educational records requiring appropriate consent or falling within specific FERPA exceptions for disclosure.
Annual Notification: We provide annual notification to parents and eligible students about their rights under FERPA, including the right to inspect and review educational records, request amendments to records, and file complaints with the Department of Education regarding alleged violations.

8.2 FERPA Exceptions and Permitted Disclosures

School Officials Exception: We may disclose educational records to school officials with legitimate educational interests when students are referred to our services by educational institutions. Such disclosures are governed by written agreements that specify the purposes for which the information may be used and require protection of student privacy.
Studies Exception: We may disclose educational records to organizations conducting studies for or on behalf of educational agencies to develop, validate, or administer predictive tests, administer student aid programs, or improve instruction. Such disclosures are governed by written agreements that protect student privacy and require destruction of personally identifiable information when no longer needed.
Audit and Evaluation Exception: We may disclose educational records to authorized representatives of federal, state, or local educational authorities for audit or evaluation of federally or state-supported education programs. Such disclosures are conducted in accordance with written agreements that protect student privacy.
Health and Safety Emergency Exception: We may disclose educational records in connection with a health or safety emergency if knowledge of the information is necessary to protect the health or safety of students or other individuals. Such disclosures are limited to the period of the emergency and to parties who can assist in addressing the emergency.

8.3 Record Keeping and Audit Requirements

Disclosure Records: We maintain detailed records of all disclosures of educational records, including the date of disclosure, the parties to whom records were disclosed, and the legitimate interests or purposes for the disclosure. These records are available for inspection by parents and eligible students.
Access Logs: We maintain comprehensive logs of all access to educational records, including internal access by our staff and tutors. These logs help ensure accountability and enable us to respond to requests for information about record access.
Retention and Destruction: We maintain educational records in accordance with applicable retention requirements and securely destroy records when they are no longer needed for educational purposes or legal compliance. Our retention schedule balances the need to maintain records for educational continuity with privacy protection principles.

8.4 Student and Parent Rights

Right to Inspect and Review: Parents and eligible students have the right to inspect and review educational records maintained by SBT Reading Tutors LLC. We respond to such requests within 45 days and provide access in a form that is understandable to the requesting party.
Right to Request Amendment: Parents and eligible students may request amendment of educational records they believe are inaccurate, misleading, or in violation of privacy rights. We have established procedures for reviewing such requests and, when appropriate, amending records or providing the opportunity for a hearing.
Right to File Complaints: Parents and eligible students have the right to file complaints with the U.S. Department of Education regarding alleged violations of FERPA. We provide information about this right and assist individuals in understanding the complaint process.
Right to Consent: Parents and eligible students have the right to provide or withhold consent for disclosures of educational records, except in cases where FERPA permits disclosure without consent. We clearly explain when consent is required and obtain appropriate documentation of consent decisions.

9. Children's Privacy and COPPA Compliance

SBT Reading Tutors LLC is committed to protecting the privacy of children and complying with the Children's Online Privacy Protection Act (COPPA) and other applicable laws governing the collection and use of information from minors. While our Terms of Service require users to be at least 17 years old, we recognize that some users may be under 18 and implement appropriate protections for all minor users.

9.1 Age Verification and Parental Consent

Age Verification Procedures: We implement robust age verification procedures to ensure compliance with our minimum age requirements and applicable privacy laws. This includes requiring date of birth information during registration and implementing additional verification steps when there are questions about a user's age.
Parental Consent for Minors: For all users under 18 years of age, we require verifiable parental consent before collecting, using, or disclosing personal information. This consent is obtained through secure methods that verify the identity of the parent or guardian providing consent.
Consent Documentation: We maintain comprehensive records of all parental consent, including the method of consent verification, the scope of consent provided, and any limitations or restrictions specified by parents. This documentation enables us to honor parental choices and demonstrate compliance with applicable laws.
Ongoing Consent Management: We provide parents with ongoing control over their child's information, including the ability to review information collected, request changes or deletions, and modify consent preferences. Parents can withdraw consent at any time, though this may affect our ability to provide services.

9.2 Limited Collection and Use

Minimal Data Collection: For users under 18, we limit our collection of personal information to what is necessary for providing educational services and ensuring platform safety. We do not collect more information than is reasonably necessary for the educational purposes for which it is collected.
Educational Purpose Limitation: Information collected from minors is used solely for educational purposes, including providing tutoring services, tracking academic progress, and communicating with parents about educational matters. We do not use information from minors for marketing purposes or share it with third parties for non-educational purposes.
No Behavioral Advertising: We do not engage in behavioral advertising directed at users under 18 or use information collected from minors to create advertising profiles. Any advertising or promotional content shown to minor users is limited to educational resources and services directly related to our tutoring offerings.

9.3 Enhanced Security and Protection

Additional Security Measures: We implement enhanced security measures for accounts associated with users under 18, including additional access controls, monitoring for unusual activity, and heightened protection against unauthorized access.
Restricted Communication: Communication with users under 18 is limited to educational purposes and is conducted through secure, monitored channels. We maintain records of all communications with minor users and ensure that such communications are appropriate and professional.
Supervision and Oversight: All interactions with users under 18 are subject to additional supervision and oversight to ensure appropriate conduct and protection of minor users. This includes monitoring of tutoring sessions and review of communication records.

9.4 Parental Rights and Controls

Access to Child's Information: Parents have the right to review all personal information collected from their child, including educational records, communication logs, and usage data. We provide secure methods for parents to access this information and respond to requests promptly.
Correction and Deletion Rights: Parents can request correction of inaccurate information about their child or deletion of information that is no longer necessary for educational purposes. We honor such requests unless retention is required by law or necessary for legitimate educational purposes.
Communication Preferences: Parents can control how we communicate with their child and can request that all communications be directed to the parent rather than the child. We respect these preferences and ensure that our communication practices align with parental instructions.
Withdrawal of Consent: Parents can withdraw consent for the collection and use of their child's information at any time. While withdrawal of consent may affect our ability to provide services, we respect parental decisions and provide clear information about the consequences of consent withdrawal.

10. Data Security and Protection

SBT Reading Tutors LLC implements comprehensive security measures to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. Our security program is designed to address the unique risks associated with educational data and to maintain the confidentiality, integrity, and availability of personal information.

10.1 Technical Safeguards

Encryption and Data Protection: We use industry-standard encryption to protect personal information both in transit and at rest. All data transmissions between users and our platform are protected using Transport Layer Security (TLS) encryption, and sensitive data stored on our systems is encrypted using Advanced Encryption Standard (AES) encryption or equivalent protection.
Access Controls and Authentication: We implement robust access controls to ensure that personal information is accessible only to authorized personnel who have a legitimate need to access such information for business purposes. This includes multi-factor authentication for administrative accounts, role-based access controls, and regular review of access permissions.
Network Security: Our network infrastructure is protected by firewalls, intrusion detection systems, and other security technologies that monitor for and prevent unauthorized access attempts. We regularly update and patch our systems to address known security vulnerabilities.
Secure Development Practices: We follow secure software development practices, including regular security testing, code reviews, and vulnerability assessments. Our development team is trained in secure coding practices and privacy-by-design principles.

10.2 Administrative Safeguards

Staff Training and Awareness: All employees and contractors who have access to personal information receive comprehensive training on privacy and security requirements, including FERPA compliance, data handling procedures, and incident response protocols. This training is updated regularly to address emerging threats and regulatory changes.
Privacy and Security Policies: We maintain detailed privacy and security policies that govern the collection, use, storage, and disposal of personal information. These policies are regularly reviewed and updated to reflect changes in our operations, technology, and applicable laws.
Vendor Management: We conduct thorough due diligence on all third-party service providers and require them to implement appropriate security measures and comply with our privacy and security standards. Our vendor agreements include specific security requirements and audit rights.
Incident Response Procedures: We have established comprehensive incident response procedures to address potential security breaches or privacy incidents. These procedures include immediate containment measures, investigation protocols, notification requirements, and remediation steps.

10.3 Physical Safeguards

Secure Facilities: Our offices and data centers implement appropriate physical security measures, including controlled access, surveillance systems, and environmental controls. Access to areas where personal information is stored or processed is limited to authorized personnel.
Device Security: We implement security measures for all devices that access or store personal information, including encryption, remote wipe capabilities, and secure disposal procedures for end-of-life equipment.
Document Security: Physical documents containing personal information are stored in secure locations with appropriate access controls and are disposed of securely when no longer needed.

10.4 Monitoring and Auditing

Continuous Monitoring: We continuously monitor our systems for security threats, unauthorized access attempts, and unusual activity patterns. This monitoring helps us detect and respond to potential security incidents quickly.
Regular Security Assessments: We conduct regular security assessments, including penetration testing, vulnerability scans, and security audits, to identify and address potential weaknesses in our security posture.
Compliance Auditing: We regularly audit our privacy and security practices to ensure compliance with applicable laws, regulations, and industry standards. These audits help us identify areas for improvement and ensure ongoing compliance.

11. Data Retention and Deletion

We maintain personal information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and protect our legitimate business interests. Our data retention practices are designed to balance the need to maintain information for educational continuity with privacy protection principles.

11.1 Retention Periods

Educational Records: Student educational records, including tutoring session data, progress reports, and assessment results, are retained for a minimum of three years after the completion of services or until the student reaches age 21, whichever is longer. This retention period ensures continuity of educational services and compliance with educational record-keeping requirements.
Account Information: User account information, including contact details and billing information, is retained for the duration of the account relationship and for up to seven years after account closure to comply with business record-keeping requirements and to address any post-service inquiries or disputes.
Communication Records: Records of communications with users, including emails, phone calls, and chat logs, are retained for up to three years to ensure continuity of service and to address any questions or concerns that may arise.
Technical and Usage Data: Technical logs, usage analytics, and system monitoring data are typically retained for up to two years, unless longer retention is required for security purposes or legal compliance.

11.2 Secure Deletion Procedures

Data Destruction Standards: When personal information reaches the end of its retention period, we securely delete or destroy it using methods that ensure the information cannot be reconstructed or recovered. This includes overwriting digital storage media and physically destroying paper documents.
Third-Party Data Deletion: We require our third-party service providers to implement similar secure deletion procedures and to certify the destruction of personal information when it is no longer needed for the specified purposes.
Verification and Documentation: We maintain records of data deletion activities to demonstrate compliance with our retention policies and to provide assurance that personal information has been properly disposed of when no longer needed.

11.3 Legal and Regulatory Considerations

Legal Hold Procedures: In cases where personal information may be relevant to legal proceedings, regulatory investigations, or other legal matters, we implement legal hold procedures to preserve relevant information until the matter is resolved.
Regulatory Requirements: Our retention practices comply with applicable legal and regulatory requirements, including educational record-keeping laws, tax regulations, and other business record requirements.
User-Requested Deletion: We honor user requests for deletion of personal information, except where retention is required by law or necessary for legitimate business purposes. We provide clear information about any limitations on deletion requests.

12. Your Rights and Choices

We respect your privacy rights and provide various mechanisms for you to control how your personal information is collected, used, and shared. The specific rights available to you may vary depending on your location and the applicable privacy laws.

12.1 Access and Portability Rights

Right to Access: You have the right to request access to the personal information we maintain about you. We will provide you with a copy of your personal information in a commonly used, machine-readable format when technically feasible.
Educational Records Access: Parents and eligible students have specific rights under FERPA to inspect and review educational records. We provide access to these records within 45 days of receiving a request and in a format that is understandable to the requesting party.
Data Portability: Upon request, we will provide your personal information in a structured, commonly used format that allows you to transmit the information to another service provider, where technically feasible.

12.2 Correction and Amendment Rights

Right to Correction: You have the right to request correction of inaccurate or incomplete personal information. We will investigate such requests and make appropriate corrections when warranted.
Educational Records Amendment: Under FERPA, parents and eligible students have the right to request amendment of educational records they believe are inaccurate or misleading. We have established procedures for reviewing such requests and providing hearings when amendments are denied.

12.3 Deletion and Restriction Rights

Right to Deletion: You may request deletion of your personal information in certain circumstances, such as when the information is no longer necessary for the purposes for which it was collected or when you withdraw consent for processing.
Right to Restriction: You may request that we restrict the processing of your personal information in certain circumstances, such as when you contest the accuracy of the information or object to processing for legitimate interests.

12.4 Communication Preferences

Marketing Opt-Out: You can opt out of receiving promotional communications from us at any time by using the unsubscribe link in our emails, adjusting your account settings, or contacting us directly.
Communication Channels: You can specify your preferred methods of communication and request that we communicate with you through specific channels or at specific times.

12.5 Exercising Your Rights

Request Procedures: To exercise any of your privacy rights, you can contact us using the information provided in Section 16 of this Privacy Policy. We may require verification of your identity before processing requests to protect against unauthorized access to personal information.
Response Timeframes: We will respond to your requests within the timeframes required by applicable law, typically within 30 days for most requests. We will notify you if we need additional time to process your request.
No Discrimination: We will not discriminate against you for exercising your privacy rights, including by denying services, charging different prices, or providing different levels of service quality.

13. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance user experience, analyze platform usage, and improve our services. This section explains what tracking technologies we use, how they work, and how you can control them.

13.1 Types of Tracking Technologies

Essential Cookies: We use essential cookies that are necessary for the operation of our platform, including session management, security features, and basic functionality. These cookies cannot be disabled without affecting the core functionality of our services.
Analytics Cookies: We use analytics cookies to understand how users interact with our platform, identify popular content, and analyze usage patterns. This information helps us improve our services and optimize user experience.
Preference Cookies: We use preference cookies to remember your settings and preferences, such as language preferences, accessibility settings, and customization options.

13.2 Third-Party Tracking

Third-Party Analytics: We may use third-party analytics services, such as Google Analytics, to analyze website usage and user behavior. These services may use cookies and other tracking technologies to collect information about your use of our platform.
Social Media Integration: Our platform may include social media features and widgets that may collect information about your visits to our site. These features are governed by the privacy policies of the respective social media companies.

13.3 Cookie Management

Browser Controls: You can control cookies through your browser settings, including blocking or deleting cookies. However, disabling certain cookies may affect the functionality of our platform.
Opt-Out Options: We provide opt-out options for non-essential tracking technologies and respect your choices regarding the use of such technologies.

14. International Data Transfers

SBT Reading Tutors LLC operates exclusively within the United States and does not transfer personal information outside the United States. However, some of our third-party service providers may have international operations, and this section addresses how we protect personal information in such circumstances.

14.1 Data Localization

US-Based Operations: All of our primary operations, including data processing and storage, are conducted within the United States. We select service providers that can provide services from US-based infrastructure when possible.
Third-Party International Operations: Some of our third-party service providers may have international operations or may store data in multiple geographic locations. We require these providers to implement appropriate safeguards for international data transfers.

14.2 Transfer Safeguards

Contractual Protections: When personal information is transferred to third parties with international operations, we implement contractual safeguards that require appropriate protection of personal information regardless of the location where it is processed.
Adequacy Determinations: We consider adequacy determinations and other legal frameworks for international data transfers when selecting third-party service providers with international operations.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We are committed to providing clear notice of any material changes and obtaining appropriate consent when required.

15.1 Notification of Changes

Advance Notice: We will provide at least 30 days' advance notice of any material changes to this Privacy Policy by posting the updated policy on our website and sending notification to registered users.
Effective Date: All changes to this Privacy Policy will include a new effective date, and the updated policy will apply to information collected after the effective date.
Continued Use: Your continued use of our services after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

15.2 Material Changes

Definition of Material Changes: Material changes include changes to the purposes for which we collect information, new categories of information collected, new types of third-party sharing, or changes that materially reduce privacy protections.
Additional Consent: For material changes that affect how we use previously collected information, we may seek additional consent from users before implementing the changes.

16. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us using the information below. We are committed to addressing your privacy concerns promptly and thoroughly.

16.1 Privacy Contact Information
SBT Reading Tutors LLC
Privacy Officer
8735 Dunwoody Place, Suite 6
Atlanta, GA 30350
United States
Email: support@sbtreadingtutors.com
Phone: +1 (678) 370-7473
Website: https://sbtreadingtutors.com

16.2 Response Procedures
Inquiry Response: We will acknowledge receipt of your privacy inquiry within 5 business days and provide a substantive response within 30 days, or sooner when required by applicable law.
Escalation Process: If you are not satisfied with our response to your privacy inquiry, you may request escalation to our senior management team or file a complaint with applicable regulatory authorities.

16.3 Regulatory Contacts
FERPA Complaints: Complaints regarding alleged violations of FERPA may be filed with the U.S. Department of Education at:
Family Policy Compliance Office
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202-8520

State Privacy Authorities: Depending on your location, you may also have the right to file complaints with state privacy authorities or attorneys general regarding our privacy practices.

Acknowledgment

By using our services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Privacy Policy. This Privacy Policy is incorporated into and forms part of our Terms of Service.

Last Updated: July 4, 2025
Effective Date: July 4, 2025