Tutorly Bird Privacy Policy
Tutorly Bird ("we," "us," or "our") provides live online tutoring services designed for children ages 4–13. We prioritize the privacy and safety of families using our service.
This Privacy Policy explains how we collect, use, disclose, and safeguard personal information from parents, legal guardians, and children under the age of 13, in strict compliance with the U.S. Children's Online Privacy Protection Act (COPPA) and applicable state privacy laws.
1. Who This Policy Applies To & The Parental Model
Tutorly Bird operates strictly through a parent-managed model:
- Accounts must be created, authorized, and managed solely by a parent or legal guardian.
- Children do not create accounts, log in independently, or submit personal information directly to our servers.
- References to "your child's information" mean information provided by you (the parent or legal guardian) to facilitate tutoring.
2. Information We Collect
We adhere strictly to data minimization principles, collecting only what is necessary to deliver quality tutoring.
A. Information Collected from Parents & Legal Guardians
- Account Credentials: Parent/guardian full name, email address, and account password.
- Payment Data: Payment information (credit/debit card, billing address) processed directly by our secure third-party payment provider, Base44 Payments / Wix. We do not store complete payment card details on our servers.
- Communication & Booking Records: Lesson booking history, messages sent to support or tutors, and lesson recap notes.
B. Information Collected About Children (Provided by Parent)
- First Name: Used solely to address the student during live tutoring sessions.
- Date of Birth: Used internally to calculate the child's age for grade-level and age-appropriate tutor matching. Tutors never see the exact birthdate—they see only the child's first name and calculated age.
- Grade Level & Academic Subjects: To match the student with a qualified tutor.
- Optional Tutor Notes: Learning preferences, interests, or accommodation requests voluntarily provided by the parent.
What We Do NOT Collect: We do not collect children's contact information, home addresses, phone numbers, photographs, social security numbers, or precise geolocation.
3. Verifiable Parental Consent & Verification Mechanisms
Under COPPA, we must obtain Verifiable Parental Consent (VPC) before collecting, using, or storing any personal information about a child under 13.
When you create an account and add a child profile, we verify your identity and confirm parental consent using one of the following FTC-approved mechanisms:
- Monetary Transaction Verification: A micro-charge or authorization transaction during payment account setup (processed via Base44 Payments/Wix).
- Knowledge-Based Authentication (KBA): Dynamic, multi-choice verification questions that cannot easily be answered by a child.
- Two-Factor / Text-Plus Verification: A confirmation code sent via SMS to the parent's verified phone number, coupled with a secondary email confirmation.
You may choose to withhold consent or stop further collection of your child's information at any time, which will prevent further tutoring sessions from being scheduled.
4. How We Use Information
We use family information strictly for legitimate operational purposes:
- Matching students with appropriate tutors and scheduling live video sessions.
- Processing payments and maintaining session credit balances.
- Delivering lesson recaps, progress notes, and administrative updates to parents.
- Ensuring platform safety, verifying identities, and detecting fraudulent or abusive behavior.
- Improving internal platform performance and pedagogical delivery (using aggregated or de-identified data only).
We do NOT sell, rent, or monetize personal information. We do NOT use child information for behavioral targeting, profiling, or direct advertising.
5. Who Can Access Information & Third-Party Service Providers
Access to information is strictly restricted on a need-to-know basis:
| Recipient / Access Level | Scope & Purpose |
|---|---|
| Parent / Guardian | Full access to edit, review, or delete all family and child data. |
| Assigned Tutor | Restricted solely to the child's first name, age, grade, subject, and parent-provided notes for active bookings. Tutors cannot view other families' data or full birthdates. |
| Tutorly Bird Administrators | Access reserved for customer support, safety monitoring, and technical oversight. |
| Vetted Service Providers | Third-party infrastructure providers operating under strict contractual data protection agreements. |
Categories of Third-Party Service Providers
We share necessary data with third parties solely to fulfill essential platform functions:
- Payment Processors: Base44 Payments / Wix (processes financial transactions securely under PCI-DSS compliance).
- Video Communications Infrastructure: Powers live 1-on-1 video sessions via secure, encrypted links.
- Cloud Hosting & Storage: Hosts encrypted database infrastructure.
All service providers are contractually bound to keep data confidential, use it solely for the specified service, and maintain standards consistent with COPPA and applicable security frameworks.
Parents have the right to consent to the collection and operational use of their child's data without consenting to optional third-party disclosures.
6. Live Sessions & Technical Safeguards
Tutoring takes place in real-time online classrooms:
- No Recording Without Express Consent: Live sessions are never recorded by default. If a session recording feature is introduced in the future, it will require separate, explicit opt-in consent from the parent.
- Encrypted Rooms: Video streams use end-to-end encryption (TLS/SRTP). Session links are unique, password-protected, and inaccessible to unauthorized third parties.
- Conduct Rules: Tutors undergo identity and background screening before being permitted to conduct sessions with students.
7. Mandatory Data Retention Schedule
In compliance with FTC COPPA Rule § 312.10, we retain child data only as long as reasonably necessary to fulfill the operational purpose for which it was collected. We do not retain child data indefinitely.
| Data Type | Retention / Deletion Period |
|---|---|
| Active Child Profiles | Retained while parent account remains active. |
| Deleted Child Profiles | Permanently erased from active databases within 30 days. |
| Inactive Accounts (No login > 24 mo) | Automatically flagged and deleted following email notice. |
| Lesson Notes & Session Logs | Retained for 12 months, then automatically purged. |
| Financial / Billing Records | Retained up to 7 years solely to satisfy legal/tax law. |
8. Parental Rights & Controls
As a parent or legal guardian, you retain full ownership and control over your family's personal information. You have the right to:
- Review & Correct Data: View or edit your child's profile details at any time via the "My Children" tab in your account.
- Refuse Further Collection: Revoke consent at any time to stop further data collection or tutor interactions.
- Direct Deletion: Delete individual child profiles directly from your account, or request complete family data erasure by submitting a written request.
- Third-Party Restriction: Restrict data sharing to third parties where such disclosure is not integral to providing the tutoring service.
9. Information Security Program
We maintain a comprehensive Information Security Program designed to protect the confidentiality, integrity, and security of child and parent data:
- Technical Protections: Data encrypted in transit (TLS 1.3) and at rest (AES-256).
- Administrative Controls: Dedicated security oversight, role-based database access, regular risk assessments, and background screening for staff and tutors.
- Vendor Monitoring: Annual reviews of third-party vendors handling personal data.
10. Contact Us & Privacy Concerns
If you have questions, wish to exercise parental rights, or need to report a privacy or safety concern, contact our dedicated privacy administration team:
- Primary Channel: Use the Report a Safety Concern page in your parent dashboard.
- Email Support: Reply to any account confirmation email or email us directly at privacy@tutorlybird.com.