Privacy Policy

Effective Date: April 1, 2026  |  Last Updated: April 6, 2026

1. Introduction

The Scholars' Room ("we," "us," or "our") is a private academic tutoring service operated out of Bridgeport, Connecticut. We provide one-on-one tutoring services for students in Grades 2 through 12, supported by a proprietary diagnostic assessment platform accessible at app.thescholarsroom.com, a collaborative workspace at workspace.thescholarsroom.com, and a live on-demand tutoring platform at live.thescholarsroom.com. Our public website is located at thescholarsroom.com.

This Privacy Policy describes how we collect, use, store, and protect the personal information of our clients, including parents, legal guardians, and students. Because many of our students are children under the age of 13, we take special care to comply with the Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. 6501-6506, and the Federal Trade Commission's implementing regulations at 16 C.F.R. Part 312.

We also design our practices to satisfy the requirements of the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Connecticut Data Privacy Act (CTDPA), and other applicable state privacy laws, so that families across the United States receive consistent, high-standard privacy protections regardless of where they reside.

2. Who This Policy Applies To

This Privacy Policy applies to:

• Parents and legal guardians who enroll students in our services
• Students (Grades 2–12) who use our diagnostic assessment platform, workspace, or live on-demand tutoring service
• Prospective families who submit inquiry or intake forms through our website
• Any individual who visits our websites or interacts with our online services

Because our services are designed for minors, the parent or legal guardian is the primary account holder and contracting party for all students under 18. Student accounts are created exclusively by the administrator (tutor) after parental consent has been obtained.

3. Information We Collect

3.1 Information Provided During Intake

When a parent or guardian expresses interest in our services, we collect information through our website intake form and during our initial consultation call:

• Parent/guardian full name
• Parent/guardian email address and phone number
• Student first and last name
• Student grade level
• Subject(s) of concern (Math, ELA, Writing, SAT Prep)
• Description of academic concerns or goals
• How the family heard about our services

3.2 Information Collected Through the Platform

Once enrolled, our diagnostic assessment platform and live tutoring service collect the following information in the course of providing tutoring services:

Student Data

• System-generated username and password (students do not choose their own credentials)
• Grade level and enrolled subjects
• Diagnostic assessment responses, scores, and performance analytics
• Scholar Snapshot (progress check) results and growth tracking data
• Session tracking data, including phase ratings and root cause analysis categories (Conceptual Gap, Procedural/Fluency Weakness, Confidence/Anxiety Barrier, Attention/Executive Function, Prerequisite Knowledge Gap)
• Progress reports generated by the tutor
• Workspace board activity and collaboration data
• Rewards program data (points earned, tickets, raffle entries)

On-Demand Session Data

• Session booking requests submitted through live.thescholarsroom.com
• Session metadata (start and end time, duration, subject, session status)
• In-session chat messages and whiteboard activity
• Live video and audio stream data (not stored unless recording consent is obtained per Section 5.5)
• Session recording, if recording consent is given by the parent/guardian (stored for a maximum of 30 days, then permanently deleted)
• Session request history and booking activity

Parent/Guardian Data

• Name, email address, and contact information
• Contract and digital signature records
• Invoice and payment history
• Communication records stored in the parent correspondence log
• Exit survey responses (if applicable upon disenrollment)

3.3 Automatically Collected Information

When you visit our websites or use our platform, we may automatically collect:

• Device type, browser type, and operating system
• IP address and approximate geographic location
• Pages visited and time spent on our platform
• Referring website or source

Important: We do not use cookies or tracking technologies for advertising or marketing purposes. Any cookies used are strictly necessary for platform functionality (e.g., session authentication).

4. How We Use Information

We use the information we collect solely for the following purposes:

We never sell, rent, or trade personal information. We do not use personal information for targeted advertising, behavioral profiling, or any commercial purpose unrelated to providing our tutoring services.

5. Children's Privacy (COPPA Compliance)

Because many of our students are under the age of 13, we are committed to full compliance with the Children's Online Privacy Protection Act (COPPA). The following safeguards are built into our platform and practices:

5.1 Verifiable Parental Consent

We obtain verifiable parental consent before collecting any personal information from a child under 13. Our consent process works as follows:

• All student accounts are created by the administrator (tutor), never by the student or parent directly.
• Before creating a student account, the parent or guardian participates in a consultation call, reviews a diagnostic assessment proposal, and signs a Tutoring Services Agreement that explicitly authorizes us to collect and use the student's information as described in this Privacy Policy.
• The signed contract serves as verifiable parental consent under COPPA. The parent's digital signature is captured and stored securely within the platform.

5.2 Data Minimization

We collect only the information reasonably necessary to provide our tutoring services. We do not ask students to provide social media handles, photographs, precise geolocation, or any information beyond what is needed for academic assessment and instruction.

5.3 Parental Rights

Parents and legal guardians have the right to:

• Review their child's personal information at any time through the parent portal, which displays assessment results, progress reports, and account information.
• Request deletion of their child's personal information by contacting us in writing. Upon receiving a verified request, we will delete the child's data within 30 days, except where retention is required by law or necessary to complete a transaction.
• Refuse further collection by terminating services. If a parent withdraws consent or terminates the tutoring agreement, we will cease collecting data from the student and delete their account within 30 days unless otherwise required by law.
• Receive notice of any material changes to our data collection practices before those changes take effect.

5.4 No Third-Party Commercial Use

We do not disclose children's personal information to third parties for commercial purposes. We do not allow third parties to collect personal information from children through our platform. Our platform does not serve advertisements of any kind.

5.5 Session Recording Consent (On-Demand Sessions)

Connecticut General Statutes § 52-570d requires the consent of all parties before any communication may be recorded. In compliance with this requirement, The Scholars' Room has implemented the following recording consent process for on-demand live tutoring sessions:

• Before each session begins, the booking parent or guardian is presented with a standalone recording consent disclosure.
• The parent or guardian must affirmatively check a consent checkbox to authorize recording. This checkbox is not pre-checked and cannot be bypassed.
• Each consent record captures: user ID, date and time of consent (UTC), session identifier, and IP address. Consent records are retained for seven (7) years to demonstrate compliance with Connecticut General Statutes § 52-570d.
• If consent is declined, the session proceeds as normal and no recording is made.
• Sessions are not recorded by default. Recording occurs only when explicit affirmative consent has been provided.
• Session recordings are retained for a maximum of thirty (30) days from the date of the session, after which they are permanently and irreversibly deleted.

6. When We Share Information

We share personal information only in the following limited circumstances:

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. We do not share personal information with data brokers.

7. Data Security

We implement the following security measures to protect personal information:

• All data transmitted between your browser and our servers is encrypted using HTTPS/TLS
• Student credentials are system-generated; students must change their temporary password on first login
• Our database (PostgreSQL) is hosted on Railway's infrastructure with encryption at rest
• Administrative access to the platform is restricted to the sole proprietor/tutor via authenticated login
• Regular database backups are performed, and backup exports are available to the administrator
• We conduct periodic reviews of our security practices and update them as needed

While we take reasonable measures to protect personal information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but are committed to promptly addressing any breach in accordance with applicable law.

Data Breach Notification. In the event of a data breach involving personal information, we will notify affected parents, guardians, and users without unreasonable delay and no later than sixty (60) days from the date of discovery, in compliance with Connecticut Public Act 16-189 and Connecticut General Statutes § 36a-701b. Our notification will describe the nature of the breach, the categories of information affected, and the steps we are taking to address it. Where required, we will also notify the Connecticut Attorney General concurrently with notification to affected individuals.

8. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected:

• Active students: Data is retained for the duration of the tutoring relationship and is continuously updated with new assessment results and progress tracking.
• Disenrolled students: Upon disenrollment, student data is retained for up to one (1) year to allow families to re-enroll or request records. After that period, data is permanently deleted unless retention is required by law.
• Intake leads: Information from prospective families who do not enroll is retained for up to six (6) months, then permanently deleted.
• Financial records: Invoices and payment records are retained for seven (7) years in accordance with IRS record-keeping requirements.
• Signed contracts: Retained for seven (7) years from the date of termination of the agreement.
• Session recordings: If recording consent is provided, session recordings are retained for a maximum of thirty (30) days from the session date, then permanently deleted.
• Recording consent records: Retained for seven (7) years to demonstrate compliance with Connecticut General Statutes § 52-570d.

9. Your Privacy Rights

Depending on your state of residence, you may have some or all of the following rights regarding your personal information and your child's personal information:

To exercise any of these rights, contact us using the information in Section 13 below. We will respond to verified requests within 45 days. If additional time is needed, we will notify you of the extension and the reason. For requests involving a child's data, we will verify the identity of the requesting parent or guardian before fulfilling the request.

10. State-Specific Disclosures

10.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the rights described in Section 9 above, including the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell or share personal information as defined by the CCPA/CPRA. We do not use sensitive personal information for purposes beyond what is necessary to provide our services.

10.2 Connecticut Residents (CTDPA and CT PA 16-189)

If you are a Connecticut resident, you have the right to access, correct, delete, and obtain a portable copy of your personal data. You also have the right to opt out of targeted advertising and the sale of personal data. We do not engage in either practice. Beginning July 1, 2026, the CTDPA imposes additional protections for minors' data, including a ban on targeted advertising and the sale of minors' personal data. Our practices already satisfy these requirements.

In addition, Connecticut Public Act 16-189 (An Act Concerning Student Data Privacy) applies to our services. Under PA 16-189, we are prohibited from using student personal information for targeted advertising, selling or renting student data, and disclosing student information except for school purposes or as required by law. In the event of a data breach involving student information, we will provide notification as described in Section 7. Parents may request deletion of their child's student data at any time.

10.3 Other States

Residents of Colorado, Virginia, Utah, Oregon, Texas, New Jersey, Delaware, Maryland, Minnesota, Nebraska, New Hampshire, Tennessee, Iowa, Indiana, Montana, and other states with comprehensive privacy laws have similar rights. We honor all verified consumer rights requests regardless of your state of residence, applying the highest applicable standard.

11. Note Regarding FERPA

The Family Educational Rights and Privacy Act (FERPA) applies to educational institutions that receive federal funding. As a private tutoring service, The Scholars' Room is not a FERPA-covered entity. However, if a school or school district shares student education records with us, we will treat that information with FERPA-equivalent protections, including restricting its use to the educational purpose for which it was shared, prohibiting re-disclosure, and destroying records when they are no longer needed.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. If we make material changes, we will:

• Provide written notice to parents and guardians of enrolled students via email at least 30 days before the changes take effect.
• Post the updated policy on our website with a revised "Last Updated" date.
• Obtain new verifiable parental consent if the changes involve the collection or use of children's personal information in a materially different way.

13. Contact Information

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle personal information, please contact us:

The Scholars' Room
Bridgeport, Connecticut
Email: info@thescholarsroom.com
Website: thescholarsroom.com

For COPPA-related inquiries or to exercise parental rights regarding a child's data, please include "COPPA Request" in the subject line of your email. We will respond within 48 hours to acknowledge receipt and within 30 days to fulfill the request.

14. Governing Law and Legal References

This Privacy Policy is governed by the laws of the State of Connecticut. The following federal and state laws informed its development:

This Privacy Policy was drafted to reflect the actual data practices and technical architecture of The Scholars' Room platform. It should be reviewed by a licensed attorney in the State of Connecticut before being published or relied upon as a legal instrument.