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PASS Personal Tutoring

Privacy Policy

Version 2026-06-17 · Closed beta

Beta notice. This Privacy Policy is a good-faith draft for the closed beta. It has not been reviewed by an attorney.

This Privacy Policy explains what data PASS collects, how we use it, who we share it with, and the controls you have. It applies to passtutoring.com and the PASS app.

1. Information we collect

  • Account info: name, email, password hash, account type (student/parent/tutor), and optional profile fields (school, major, photo, bio).
  • Minor-account info: date of birth or grade level (used only to determine whether parental consent is required), parent/guardian email.
  • Tutor application materials: any documents you submit as part of the tutor review process (such as proof of enrollment, transcript, or identification, if requested). Stored in a private bucket, viewable only by admins on a need-to-know basis.
  • Booking data: session times, subjects, locations, ratings, reviews, and messages between you and your counterparty.
  • Payment data: processed by Stripe. We store only the Stripe customer/intent identifiers, amount, and status. We do not store full card numbers.
  • Communications: emails we send and your responses to surveys/support.
  • Usage data: IP address, device, browser, pages visited, and basic error telemetry. Used to operate and secure the service.

2. How we use information

  • To create and operate your account and run bookings, matching, and payouts.
  • To verify tutor identity, enforce safety policies, and prevent fraud and abuse.
  • To send transactional emails (confirmations, reminders, receipts, password resets, consent requests).
  • To respond to your support requests.
  • To improve product quality, performance, and safety.
  • To comply with legal obligations (e.g. tax records for payouts).

We do not use your data for behavioral advertising, and we do not sell personal data.

3. Legal bases (where applicable)

We process data to perform our contract with you (running your bookings), to meet legal obligations (tax, safety), with your consent (e.g. parental consent for minors, marketing emails when offered), and for legitimate interests in operating and securing the service. You can withdraw consent at any time without affecting prior processing.

4. Sub-processors we use

  • Lovable Cloud (database, auth, file storage, hosting).
  • Stripe (payments and payouts).
  • Resend (transactional email delivery).
  • Google (optional "Continue with Google" sign-in).
  • Twilio (optional SMS notifications, when enabled by the user).

Each sub-processor receives only the data needed for its function and is bound by contractual obligations to protect that data.

5. Children's privacy (COPPA)

PASS is not directed to children under 13. A learner under 13 may use PASS only with verifiable parental consent collected through our in-product flow. Until that consent is verified, the under-13 account is restricted and cannot book sessions or message tutors.

Parents and guardians have the right to: review the personal information collected from their child, request correction or deletion, and refuse further collection. Email privacy@passtutoring.com from the email on file to exercise these rights. We will verify the request and respond within 30 days. We will not condition a child's participation on disclosure of more information than is reasonably necessary.

Data minimization for minors: we collect only the data needed to operate the account and the consent flow. We do not enable third-party advertising or behavioral profiling for minor accounts.

6. School and district pilots (FERPA-adjacent)

When PASS is used through a partnering school or district, certain student information may constitute an "education record" under FERPA. In those cases, PASS acts as a school official with a legitimate educational interest, processes data only at the direction of the district, and does not use student information for any purpose other than providing the tutoring service to that school. Districts may request export or deletion of their roster data at any time.

7. Sharing

We share information only with: (a) the other party to a booking (limited profile info needed to meet); (b) sub-processors listed in §4; (c) authorities when required by law or to protect safety; and (d) a successor entity in the event of a merger or acquisition, under the same protections described here. We never sell your data.

8. Data retention

  • Booking and payout records: 7 years for tax/accounting compliance.
  • Account profile, messages, and reviews: deleted within 90 days of account closure (anonymized in aggregates kept for product analytics).
  • Minor account data: deleted within 30 days of a parent's verified deletion request, except where law requires longer retention.
  • Verification documents: deleted within 90 days after a tutor account is closed or denied.

9. Your rights

You can: edit your profile in app, request a copy of your data, ask us to correct or delete data, and close your account. Email privacy@passtutoring.com; we respond within 30 days. We do not discriminate against users who exercise these rights.

10. Security

Data is encrypted in transit (TLS) and at rest. Verification documents live in a private bucket with admin-only access. Role-based access controls and row-level security gate every database table. We log admin access to sensitive records. No system is perfectly secure; please notify support@passtutoring.com of any suspected vulnerability.

11. Cookies

PASS uses only essential cookies required for authentication and session management. We do not use third-party advertising cookies, cross-site tracking pixels, or behavioral analytics. See our Cookie Notice for details. Because we set no non-essential cookies, no cookie-consent banner is shown.

12. Do Not Track

We honor the spirit of Do-Not-Track by not running cross-site advertising or behavioral analytics regardless of the DNT header.

13. International users

PASS operates from the United States; data is stored on US infrastructure. PASS is currently offered only to users in the United States. If you access PASS from outside the US, you consent to the transfer of your information to the US.

14. Changes

We will notify users of material changes by email or in-app notice at least 14 days before they take effect.

15. Contact

Email privacy@passtutoring.com. Mailing address available upon verified legal request. PASS is operated by Seals Enterprises LLC.