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Privacy Policy

Last updated June 2025
 
Welcome to TurtlEd

TurtlEd LLC ("TurtlEd," "we," "us," or "our") provides affordable, high‑quality online tutoring to K–12 students across public, charter, and private schools. Protecting the privacy of every student and guardian who trusts us is core to our mission.

This Privacy Notice explains how we collect, use, share, and protect personal information when you:

  • visit or use our websites, mobile or web apps, or any service that links to this Notice (the "Services");
  • participate in a tutoring session streamed through our proprietary platform; or
  • interact with us in person, by phone, or through marketing, sales, or events.

If you have questions, email privacy@withturtled.com.


Summary of Key Points

  • What do we collect? Student and guardian contact details, academic information (e.g., grade level, test scores), and limited usage data.
  • Do we sell or share data for advertising? No. We do not sell personal information or use it for cross‑context behavioral advertising.
  • Sensitive information? We process student educational records—classified as Sensitive Personal Information under the California Privacy Rights Act (CPRA)—only for core educational purposes permitted by law.
  • Children’s privacy: We comply with COPPA, FERPA, and California’s SOPIPA. Verifiable parental consent—or a school contract acting in loco parentis—is obtained before collecting data from children under 13.
  • Your rights: California residents (and other jurisdictions, where applicable) can access, correct, delete, or limit use of their data.
  • Security: We employ industry‑standard technical and organizational safeguards, including encryption in transit and at rest, strict access controls, and annual third‑party penetration testing.


1. Information We Collect

The type of personal information we collect depends on who you are and how you interact with our Services.


Category

Examples

Why We Collect

Student & Guardian Identifiers

Student name, guardian name, email, phone, mailing address, unique student ID

Scheduling, session reminders, support

Academic Information (Sensitive)

Grade level, coursework details, test scores, progress notes

Designing personalized tutoring plans, measuring academic growth

Payment & Billing

Cardholder name, billing address, last 4 digits of card (guardian or school payors)

Processing payments, invoicing

Audio / Video

Live session video and audio; we record sessions only if a school or guardian opts‑in (notice provided at start of session)

Safety, quality assurance, training, and to share playback with authorized users


No biometric, geolocation, or advertising identifiers are collected.

All information must be accurate and current; please notify us of changes via your account settings or at privacy@withturtled.com.


2. How We Use Your Information

We use personal information to:

  1. Provide & operate the Services – create accounts, match students with tutors, stream sessions, maintain learning records.
  2. Personalize tutoring – adapt lesson plans based on grade level, test results, and progress.
  3. Communicate – send scheduling reminders, program updates, and respond to inquiries.
  4. Ensure safety & integrity – monitor for fraud, abuse, or policy violations; comply with child‑safety mandates.
  5. Improve & develop – analyze aggregate usage to enhance curriculum, content, and platform performance.
  6. Comply with laws – FERPA, COPPA, CPRA, SOPIPA, and other applicable regulations. We only process data when we have a lawful basis, such as consent, contract performance, legitimate educational interest, or legal obligation.


3. When & Why We Share Information

We limit disclosure of personal information to:

  • School Districts & Educators – to fulfill our contractual role as a School Official under FERPA.
  • Service Providers (e.g., secure hosting, video infrastructure, payment processors) – bound by written agreements and no‑sell/no‑share clauses.
  • Legal Obligations & Safety – to comply with subpoenas or protect the rights and safety of students.
  • Business Transitions – if we merge or are acquired, information will transfer subject to the same privacy commitments. We do not share data with advertisers or data brokers, and we prohibit downstream recipients from using data for marketing.

4. Cookies & Tracking Technologies

We use first‑party cookies and similar technologies only for service functionality, security, and performance analytics. Most browsers let you refuse cookies; disabling them may affect certain features.


5. Student Data & Children’s Privacy

  • COPPA Compliance (Under 13): We collect personal information from children under 13 solely with verifiable guardian consent or a school district contract.
  • FERPA & SOPIPA: When partnered with a school, we act as a School Official with a legitimate educational interest, use data only for the school’s purposes, and comply with all student‑data privacy statutes.
  • No Targeted Ads: Student data is never used to build profiles for commercial advertising.


6. Data Retention

We retain personal information only as long as necessary to deliver Services and meet legal or contractual obligations. Unless a longer period is required by law, we delete or anonymize:

  • Student records – within 300 days after program completion or school instruction to delete.
  • Account data – within 30 days of account deletion.
  • Session recordings – max 12 months (or shorter if contract specifies) then securely deleted.


7. Security Measures

  • TLS 1.3 encryption in transit; AES‑256 at rest
  • Role‑based access; background‑checked personnel
  • Continuous monitoring and incident‑response plan


8. Your Privacy Rights

A. Accounts Created Directly With TurtlEd

If you (or your guardian) signed up directly on our website, you may:

  • Access personal information we hold about you.
  • Correct inaccurate information.
  • Delete your information (subject to legal exceptions).
  • Limit our use of sensitive personal information.

Send your request to privacy@withturtled.com. We will verify your identity and respond within 45 days as required by applicable law.


B. Data We Receive From a School

When a school or district provides student information under a contract, that school is the data controller (and, under FERPA, the "educational agency").

  • Students and guardians must direct any request to access, review, or amend student records to the school.
  • Upon the school’s written instruction, TurtlEd will assist the school in fulfilling the request—typically within 30 days or any shorter period required by law or contract.


C. Opt‑Out of Sale or Sharing

TurtlEd does not sell or share personal information for cross‑context behavioral advertising, so no opt‑out is necessary.

We will not discriminate against you for exercising any privacy right available under applicable law.


9. Do‑Not‑Track & Global Privacy Control

We honor Global Privacy Control (GPC) signals as an opt‑out request. Industry standards for Do‑Not‑Track are still evolving; we do not currently respond to browser DNT signals.


10. California Privacy Disclosures (CPRA)

  • Sensitive Personal Information: Student academic data is processed strictly for "service provider" purposes. We do not use or disclose it outside those purposes.
  • Data minimization: We collect only information reasonably necessary for tutoring.
  • No Sell/Share: We did not sell or share personal information in the past 12 months and have no plans to do so.
  • Right to correct & limit: California residents may correct inaccurate info and limit our use of sensitive personal information.

Full CPRA notice is available in Appendix A.


11. Virginia Privacy Disclosures (VCDPA)

Virginia residents have similar rights to access, correct, delete, and obtain their personal data, and may appeal any decision we make regarding a request. Contact privacy@withturtled.com.


12. International Transfers

Our servers are located in the United States. If you access the Services from outside the U.S., you consent to transferring your information to the U.S. where data protection laws may differ from those in your jurisdiction.


13. Changes to This Notice

We will post any updates here with a new "Effective Date" and, if the changes are material, notify account holders by email.


14. Contact Us

Questions or concerns? Email privacy@withturtled.com.


Appendix A – California Privacy Rights Act (CPRA) Notice

The California Privacy Rights Act (CPRA) grants California residents specific rights regarding their personal information. This appendix supplements the information in Section 10 and applies only to individuals who reside in California.


A. Categories of Personal Information Collected (Past 12 Months)


Letter

Category

Examples

Collected

A

Identifiers

Real name, alias, postal address, email, phone, IP address, account ID

Yes

B

California Customer Records

Name, contact details, payment information

Yes

C

Protected Classification

Age (student grade level may indicate age); gender (optional)

Yes

F

Internet / Network Activity

Session logs

Yes

H

Audio/Visual

Session recordings (with opt‑in)

Yes

J

Education Information

Grades, test scores, progress reports

Yes

All other CPRA categories

–

–

No


B. Sources of Personal Information

  • Directly from you (students, guardians, or school administrators)
  • Automatically via your device when you use our platform
  • From schools that contract with us as a School Official


C. Business Purposes for Collection & Use

We use personal information only for the purposes described in Sections 2–3 of this Notice—primarily to deliver and improve our tutoring Services and to comply with applicable law. We do not sell or share personal information for advertising.


D. Disclosure to Service Providers

In the preceding 12 months we disclosed the categories above solely to service providers (e.g., secure hosting, payment processors) under contracts that prohibit them from retaining, using, or disclosing the data for any purpose other than providing services to TurtlEd.


E. Your CPRA Rights & How to Exercise Them

California residents may:

  1. Know & Access the personal information we hold about you.
  2. Correct inaccurate personal information.
  3. Delete personal information (with certain legal exceptions).
  4. Limit the use of Sensitive Personal Information to what is necessary for our educational services.
  5. Opt‑out of Sale or Sharing (not applicable—we do not sell/share).

Submit a verified request by emailing privacy@withturtled.com. We will respond within 45 days. You will not be discriminated against for exercising your CPRA rights.


F. Retention

See Section 6 – Data Retention. We retain each CPRA category only as long as reasonably necessary to fulfill the purposes stated above unless a longer period is required by law.