Privacy
POLICY & DATA HANDLING
Last Updated: 11/13/2025
- Our Commitment to Privacy
First Class Tutoring Inc. (“FCT,” “we,” “us”) is dedicated to protecting the privacy and security of the data on our platform (the “Services”). This Privacy Policy explains how we collect, use, and protect information, particularly the sensitive student data we process on behalf of School Districts.
We are a service provider to School Districts. Our data practices are governed by our contracts with those districts and by strict federal and state laws, including the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), New York Education Law 2-d, and the New York SHIELD Act. - Our Role as a Data Processor
FCT acts as a “Data Processor” (or “school official” under FERPA) for our partner School Districts, who are the “Data Controllers.” This means:
The School District determines what data is collected and how it is used.
We only process data for the purpose of providing the contracted educational services.
We do not own the student data.
We do not sell or rent student data.
We do not use student data for marketing or targeted advertising.
We do not build profiles of students for any non-educational purpose. - Information We Collect
We collect the following types of information only as necessary to provide the Services:
Student Information (from School Districts):
This is Personally Identifiable Information (PII) from a student’s education record, provided by the School District. It may include name, student ID, school, grade, course information, and accommodation details.
Tutor-Generated Student Data:
Tutors input information related to the educational services, such as session notes, attendance, assignments, and grades.
School District Administrator Information:
Name, email, school, and role.
Tutor Information:
Name, email, contact details, and qualifications.
Parent/Guardian Information:
We collect a Guardian’s name, email, and electronic signature only when a signature request is sent to them through the Platform. This information is used solely to process and record that specific signature.
Usage and Device Information:
We automatically collect technical information (like IP address, device type, browser) for security, system integrity, and to improve the Service. - How We Use and Share Information
We use and share information only for the educational purposes for which it was collected.
Use:
To operate, maintain, and provide the features of the Services; to allow Tutors and Administrators to manage instruction and reports; and to process Guardian signatures.
Sharing:
Within the School District: Student data is accessible to authorized Administrators from that student’s district and the specific Tutor(s) assigned to that student.
Sub-processors:
We use third-party service providers (“sub-processors”) for essential functions, such as data hosting. Our hosting provider is Amazon Web Services (AWS), and all data is hosted within the United States. Our sub-processors are bound by strict confidentiality and security agreements and are not permitted to use the data for any other purpose.
As Required by Law:
We may disclose information if required by law, subpoena, or other legal process. - Data Security
We take our data security obligations very seriously. We implement and maintain “reasonable” administrative, technical, and physical safeguards as required by the NY SHIELD Act and NY Ed Law 2-d. These measures include:
Encryption: All data is encrypted at rest and in transit.
Access Controls: Data access is strictly limited by user role and permissions (e.g., a Tutor can only see their assigned students).
Secure Hosting: All data is hosted on a secure AWS infrastructure in the US.
System Design: We use security-conscious design practices, such as obfuscated URLs, to help protect data.
Breach Response: We have a plan to respond to any data security incident and will provide all required notifications to our partner School Districts and/or law enforcement as required by law. - Data Retention and Deletion
We retain Student Information for as long as directed by the School District. When our contract with a School District ends, we will return or securely destroy all student data in accordance with the district’s instructions and our legal obligations. - Student and Parent Rights (FERPA & NY Ed Law 2-d)
Parents, legal guardians, and eligible students have rights over student education records under FERPA and NY Ed Law 2-d, including the right to inspect, review, and request correction of those records.
These rights must be exercised by contacting your School District directly. As FCT is a service provider, we cannot directly respond to parent requests for data. We will assist the School District in responding to any such request they receive. - New York “Parents’ Bill of Rights”
In compliance with NY Education Law 2-d, FCT upholds the principles of the Parents’ Bill of Rights for Data Privacy and Security. A student’s PII will not be sold or released for any commercial purpose. We maintain industry-standard safeguards to protect data. A full copy of the Parents’ Bill of Rights is available on the NY State Education Department (NYSED) website and through your School District. - COPPA Compliance
We do not knowingly collect personal information from children under 13, except as provided by the School District for educational purposes. We rely on the School District to obtain any necessary parental consent under COPPA, as the Platform is provided to students for a school-run educational program. - Contact Us
If you have any questions or concerns about this Privacy Policy or our practices, please contact us. We recommend that parents and students first contact their School District with any data-related queries.
First Class Tutoring Inc.
350 Higbie Lane West Islip, NY 11795
Email: info[at]firstclasstutoring[dot]net
