FCT Portal App — Privacy Policy

Effective date: 8/25/2026 Last updated: 8/25/2026

This Privacy Policy describes how First Class Tutoring Inc. (“First Class Tutoring,” “FCT,” “we,” “us,” or “our”) collects, uses, and protects information in connection with the FCT Portal mobile application (the “App”).

The App is a restricted-access tool for tutors contracted with First Class Tutoring and authorized FCT administrative staff. It is not intended for students, parents, or the general public, and accounts cannot be created by the public.

1. Who This Policy Covers

This policy applies to:

• Tutors contracted with FCT who use the App to submit tutoring sessions, upload proof of work, view assignments, and track performance; and
• Administrative staff authorized by FCT who use the App to manage students, tutors, and sessions.

It also explains how student information entered into or displayed by the App is handled. Students do not use the App themselves; their information is processed by FCT as part of delivering tutoring services to school districts (see Section 5).

2. Information We Collect

2.1 Information you provide

• Account information: your name, email address, phone number, and role (tutor or administrator). Accounts are provisioned by FCT administrators; you cannot create an account yourself in the App.
• Session records: details of tutoring sessions you submit, including date, time, duration, student and assignment references, and session notes.
• Proof of work and uploads: files you attach to sessions, such as labs, worksheets, notes, photos, and other supporting documents. These may be captured with your device camera or selected from your photo library or files.
• Communications: feedback, support requests, or other messages you send us.
  
  

2.2 Information collected automatically

• Device and technical information: device type, operating system version, app version, unique device identifiers, and IP address.
• Push notification token: a device token that allows us to deliver notifications about new assignments and important announcements, if you enable notifications.

2.3 Information about students

Tutors and administrators may enter, upload, or view information about students receiving tutoring services, including names, assignment details, session attendance, and educational progress. This information is collected and processed by FCT for the sole purpose of delivering and documenting tutoring services under FCT’s agreements with school districts. See Section 5.

3. How We Use Information

We use the information described above to:

• provide, operate, and maintain the App and FCT’s tutoring services;
• record and verify tutoring sessions, including reviewing proof of work;
• display assignment information and performance dashboards;
• send push notifications about new assignments and service-related announcements;
• respond to support requests and feedback;
• monitor, troubleshoot, and improve the App, and protect its security and integrity;
• meet our contractual obligations to school districts and comply with applicable law, including education privacy laws.

We do not use information collected through the App for advertising or marketing to third parties, and we do not sell personal information.

4. Legal Bases and Purposes Limitation

Information collected through the App is used only for the purposes described in this policy. Student information in particular is used exclusively to deliver, document, and administer tutoring services and for no other purpose, consistent with our agreements with school districts and applicable education privacy laws.

5. Student Information, FERPA, and NY Education Law §2-d

First Class Tutoring provides tutoring services to school districts, including districts in New York State. In that capacity, FCT may receive or process personally identifiable information from student education records, which is protected by the federal Family Educational Rights and Privacy Act (FERPA) and, for New York districts, New York Education Law §2-d and Part 121 of the Regulations of the Commissioner of Education.

With respect to such student data:

• FCT acts as a third-party contractor to the school district, and the district (and parents/eligible students, through the district) retains its rights in the data;
• student data is used only for the purposes of the underlying tutoring agreement and never for commercial or marketing purposes;
• student data is not sold or released for any commercial purpose;
• FCT maintains administrative, technical, and physical safeguards for student data (see Section 8), including encryption of data in transit [AND AT REST — confirm before stating];
• access to student data within the App is limited to the contracted tutors and authorized staff who need it to perform their duties;
• tutors and staff with access to student data are required to complete data privacy and security training [reference your training program here];
• student data is retained only as long as required by the applicable district agreement and law, and is securely deleted or returned when no longer needed;
• in the event of a breach or unauthorized release of student data, FCT will notify the affected school district(s) in accordance with Education Law §2-d and its district agreements.

Parents or eligible students who have questions about student data handled by FCT in connection with a school district’s tutoring program should contact their school district. Each district’s Parents’ Bill of Rights for Data Privacy and Security and any supplemental information for FCT’s agreement with that district are available from the district [OR: link to where FCT publishes its §2-d supplement].

6. How We Share Information

We share information only as follows:

• Service providers. We use third-party providers that process data on our behalf to run the App, including:
  
  • Bubble Group, Inc.  –  application hosting and database
  • Apple Push Notification service and Firebase Cloud Messaging / Google  –  delivery of push notifications
  • Amazon Web Services –  These providers are bound by contractual obligations to protect the data and use it only to provide services to us.
• School districts. Session records, proof of work, and related student data may be shared with the school district that contracted the tutoring services, as required under our agreements.
• Within FCT. Administrators can view tutor and session information needed to manage tutoring operations.
• Legal requirements. We may disclose information if required by law, subpoena, or legal process, or to protect the rights, safety, or property of FCT, our users, or others.
• Business transfers. If FCT is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this policy’s commitments (student data transfers remain subject to district agreements and §2-d).
  
  

We do not sell personal information, and we do not share it with third parties for their own advertising or marketing.

7. Data Retention

• Tutor and administrator account data is retained for the duration of your engagement with FCT and afterwards as needed for legitimate business purposes (such as invoicing records, audits, and legal compliance).
• Session records and proof of work are retained as required by our agreements with school districts and applicable record-keeping laws, and are securely deleted when no longer required.
• Student data is retained and deleted in accordance with the applicable district agreement and Education Law §2-d (see Section 5).
• Device and diagnostic data is retained for 12 months and then deleted or aggregated.

8. Security

We use administrative, technical, and physical safeguards designed to protect information in the App, including:

• encryption of data in transit (TLS);
• encryption of data at rest;
• role-based access controls (tutors see only their own assignments and sessions; administrative functions are restricted to authorized staff);
• authentication required for all access; no public or anonymous access;
• security and privacy training for personnel with access to student data.

No system is perfectly secure. If we become aware of a breach affecting your personal information, we will notify you and, where student data is involved, the affected school district(s), as required by applicable law.

9. Your Choices and Rights

• Access and correction. You may review and update certain account information in the App, or contact us to request access to or correction of your personal information.
• Push notifications. You can disable push notifications at any time in your device settings. Note that notifications are the App’s primary channel for new-assignment alerts.
• Camera and photo access. The App requests camera and photo library access only to let you attach proof of work. You can revoke these permissions in device settings; attaching files from those sources will then be unavailable.
• Account deletion. Accounts are provisioned and managed by FCT. To request deactivation or deletion of your account and associated personal data, contact us at [SUPPORT_EMAIL] or [DELETION_REQUEST_URL]. We will honor deletion requests except where retention is required by law, by our district agreements, or for legitimate record-keeping (for example, session records underlying district invoices).
• State privacy rights. Depending on your state of residence, you may have additional rights (such as access, deletion, or portability) under state privacy laws. Contact us to exercise them; we do not discriminate against users for exercising privacy rights.

Requests concerning student data should be directed to the relevant school district, which controls that data; we will support the district in responding as required by FERPA and §2-d.

10. Children’s Privacy

The App is intended solely for adults — contracted tutors and FCT staff — and is not directed at children. We do not knowingly allow anyone under 18 to hold an App account, and we do not knowingly collect personal information directly from children through the App.

Information about students, including students under 13, is processed only as described in Section 5, at the direction of school districts and under FERPA and NY Education Law §2-d — not under a direct relationship between FCT and the child. If you believe a child has gained access to an App account, contact us immediately at info[at]firstclasstutoring.net.

11. International Users

The App and our services are operated from the United States, and information is processed and stored in the United States. The App is intended for use by FCT’s contracted tutors and staff located in the United States.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated through the App or by email, and the “Last updated” date above will be revised. Continued use of the App after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

First Class Tutoring Inc. 350 Higbie Lane, West Isplip, NY 11795
Email: info[at]firstclasstutoring.net

For student-data questions related to a school district’s tutoring program, please contact your school district directly.