Privacy Policy

1. The Parent-Centric Model

At Emerald Tutoring Services, all accounts, transactions, and service agreements are strictly established between the company and the Student's Parent or Legal Guardian ("Parent").

• We do not knowingly allow individuals under the age of 18 to create accounts or purchase services.
• All personal information regarding a student is provided voluntarily by the Parent.
• By registering a student for services, the Parent provides verifiable parental consent for the collection and processing of the student's educational data.

2. Information We Collect

We collect information provided directly by the Parent:

• Parent Data: Full name, billing address, email address, phone number, and payment information.
• Student Data (Provided by Parent): Full name, age/grade level, school affiliation, and specific academic information (test scores, learning goals, or IEPs) necessary to facilitate tutoring.
• Communications Data: Records of inquiries submitted via our contact form, including name, email, and message content.
• Technical Data: IP addresses and approximate geolocation data collected to ensure compliance with US OFAC sanctions regulations, preventing unauthorized access from prohibited jurisdictions.

3. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to operate and improve the site experience.

• Essential Cookies: Required for the website to function. They cannot be disabled.
• Analytics Cookies: We may use third-party analytics tools (such as Google Analytics) to understand how visitors interact with our website. These tools may collect anonymized usage data.
• No Behavioral Advertising: We do not use cookies to serve targeted advertising or sell your data to advertisers.

You may control cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

4. Third-Party Service Providers

We use trusted third-party services to operate our platform. These providers only access your information as necessary to perform their services and are contractually obligated to protect it:

• Zoom Video Communications: All tutoring sessions are conducted via Zoom. Zoom's Privacy Policy governs data collected during sessions.
• Payment Processors: Payment information is handled by our secure payment gateway. We do not store full card details on our servers.
• Web3Forms: Our contact form uses Web3Forms to transmit inquiry data securely.

We do not sell, rent, or trade your personal information to any third party for marketing purposes.

5. Compliance with US Federal Law

• COPPA (Children's Online Privacy Protection Act): We comply with COPPA by requiring Parents to create all accounts and provide explicit consent before any data regarding a child under 13 is collected or processed. We do not knowingly collect personal information directly from children under 13.
• FTC Act (Section 5): We maintain fair and transparent data practices in accordance with FTC guidelines against unfair or deceptive acts.
• OFAC Sanctions: We operate in strict accordance with US Department of the Treasury Office of Foreign Assets Control (OFAC) regulations.

As a private tutoring company, we are not a covered educational institution under FERPA (Family Educational Rights and Privacy Act). However, we voluntarily handle all student education records with the same standard of care and confidentiality that FERPA requires of schools.

6. Texas State Privacy Rights

If you are a Texas resident, you may have additional rights under the Texas Data Privacy and Security Act (TDPSA) and the Texas Business & Commerce Code, including the right to:

• Know what personal data we collect and how it is used.
• Access, correct, or delete your personal data.
• Opt out of the sale of your personal data (we do not sell personal data).

To exercise these rights, contact us using the details in Section 10 below.

7. How We Use Information

We use collected information solely to:

• Process payments and manage enrollments.
• Match students with appropriate tutors.
• Deliver tutoring sessions via Zoom.
• Provide progress reports and academic feedback to Parents.
• Respond to inquiries submitted through our contact form.
• Ensure the security and integrity of our platform and OFAC compliance.

8. Data Sharing and Security

• No Sale of Data: We never sell or rent parent or student data to third-party marketers.
• Limited Disclosure: Student academic data is shared only with the specific tutor assigned to that student.
• Legal Disclosure: We may disclose information if required by law, court order, or to protect the rights and safety of our users.
• Security: We utilize industry-standard encryption (SSL/TLS) and secure data practices to prevent unauthorized access.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy:

• Account and billing data is retained for a minimum of 7 years to comply with US tax and financial record-keeping requirements.
• Student academic records are retained for the duration of active enrollment and for up to 2 years thereafter.
• Contact form inquiries are retained for up to 1 year.
• Upon a verified deletion request, we will delete or anonymize data within 30 days, subject to legal retention obligations.

10. Data Breach Notification

In the event of a data breach affecting your personal information, we will notify affected individuals in accordance with the Texas Business & Commerce Code § 521.053. Notification will be provided within 60 days of discovery of the breach, or within the timeframe required by applicable law, via email or written notice.

11. Parental Rights and Access

Parents have the following rights regarding the data we maintain:

• Review: You may request to see all information we have collected about you or your student.
• Correction: You may request that we correct any inaccuracies in your records.
• Deletion: You may request the deletion of your account and your student's data, subject to our legal and tax retention requirements.
• Consent Withdrawal: You may withdraw your consent for future data collection at any time, which may result in the termination of services.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Policy on this page and updating the "Last Updated" date above. For significant changes, we will provide additional notice via email. Your continued use of our services after such changes constitutes acceptance of the updated Policy.

13. Contact Us

For any questions regarding this Privacy Policy or to exercise your rights, please contact us at:
Emerald Tutoring Services
Email: info@emeraldtutoringservices.com
Phone: 832-660-8506