Learn Your Way Literacy — Privacy Policy
LYWL serves K-12 students, including children under thirteen. Protecting student data is foundational. This Privacy Policy explains what we collect, why, how we share it, how long we keep it, and the rights parents and (where applicable) older students have to control it. Capitalized terms not defined here have the meanings given in our Terms of Service. For children under thirteen, see also our separate COPPA Direct Notice to Parents.
1. Plain-Language Summary
- We collect information from parents to set up accounts, take payment, and run sessions.
- We collect limited information about students (first name or initials, grade, learning needs, assessment results) to teach them effectively.
- We do not sell student or parent personal information.
- We do not use student data for targeted advertising.
- We do not allow third parties to use our platform to track students for advertising.
- We retain data only for as long as the program runs plus a short audit window.
- Parents can review, correct, export, or delete their child's data at any time by emailing info@learnyourwayliteracy.com.
2. Information We Collect
2.1 From Parents and Guardians
- Identifiers: full name, email, phone number, mailing and billing address.
- Payment data: processed by Stripe and, where applicable, a BNPL Provider (as defined in the Terms of Service). LYWL receives transaction confirmations and the last four digits of the card; we do not store full card numbers.
- Communications: emails, support tickets, scheduling messages, and recorded support calls (if any).
- Device and site-usage data on the marketing site: IP address, browser type, pages visited, referrer, and basic analytics provided by gamma.app.
2.2 From or About Students
- Identifiers: Student first name (or parent-provided initials), age or grade level, time zone.
- Educational profile: learning needs reported by the parent (including, when applicable, a dyslexia or other learning-difference diagnosis the parent provides so the tutor can teach effectively); reading-level placement; assessment scores produced by LYWL.
- Session metadata: Zoom join and leave timestamps, attendance, instructor notes, and in-session work product (worksheets, reading samples).
- Session recordings: session recordings are part of LYWL's standard service delivery, used for instructional improvement, parental review, dispute resolution, and tutor training. Enrollment in LYWL programs requires parental consent to session recording, captured at enrollment in a granular, separate consent step. A parent may withdraw recording consent prospectively at any time; doing so ends the program with refund of unused sessions under the Terms of Service. Recording is conducted via a recording-eligible video service (Zoom for Education) under an executed Data Processing Agreement.
- Initial Assessment audio: the initial reading assessment is delivered through the LYWL enrollment portal. With the parent's affirmative permission grant to the browser microphone, the Student's reading is captured by the parent's device through the browser and transmitted with the Student's written assessment answers to LYWL for asynchronous review by the LYWL program lead. No separate file upload is required of the parent.
- Not collected: social security numbers, government identifiers, biometric identifiers, geolocation more precise than time zone, or persistent advertising identifiers tied to the Student.
2.3 Dyslexia and Learning-Difference Information
A diagnosis of dyslexia or another specific learning disability, when shared by a parent so we can match the Student to appropriate instruction, is sensitive educational information. LYWL treats it with heightened care: it is stored only in the Student's enrollment profile, accessed only by the assigned tutor and supervisor, not used for any purpose other than instruction and progress tracking, and deleted on request or per the retention schedule in Section 7.
3. How We Use Information
We use the data we collect to:
- create and operate parent accounts;
- process payments, refunds, and BNPL Provider installments;
- match Students to appropriate tutors and small groups;
- deliver, schedule, record (where consented), and improve sessions;
- communicate about scheduling, program updates, and billing, and — with separate consent — optional newsletters;
- monitor session quality through supervisor review and tutor training using anonymized excerpts;
- comply with law, respond to lawful requests, and protect the safety of users; and
- detect and prevent fraud and abuse.
We do not use Student personal information to sell to data brokers or marketers, to build advertising profiles or display behavioral ads, or to train third-party AI models for general-purpose products.
4. Legal Bases for Processing
For United States users, we rely on the parent's contractual agreement under the Terms of Service, parental consent under COPPA for children under thirteen, and our legitimate operational interests in delivering and improving the Service. For Students aged thirteen to seventeen, we rely on the parent's contractual agreement. In California, additional opt-in consent applies before any sale or sharing for cross-context behavioral advertising; as a matter of policy, LYWL does not engage in such sale or sharing.
5. How We Share Information
We share personal information only with the categories of recipients listed below, and only as needed:
We do not share Student personal information with advertising networks, data brokers, social-media trackers, or analytics vendors that monetize through advertising. We do not permit third-party trackers on pages used by Students.
We require all processors handling Student data to sign a Data Processing Agreement that prohibits use of the data for any purpose other than providing the service to LYWL.
6. Children Under Thirteen — COPPA Treatment
LYWL knowingly collects personal information from children under thirteen only after we obtain verifiable parental consent ("VPC") from the child's parent or legal guardian. The full direct notice to parents, including the VPC mechanism, is in our COPPA Direct Notice to Parents. In summary:
VPC method. We obtain VPC through the parent's credit-or-debit-card transaction for the Initial Reading Assessment via Stripe Checkout (the "Assessment Checkout"), combined with the parent's contemporaneous acceptance of two unbundled consent checkboxes presented in the Assessment Checkout: (i) acceptance of the Terms of Service and (ii) acknowledgment of this Privacy Policy and the COPPA Direct Notice. This method satisfies 16 CFR §312.5(b)(2)(iii) — a monetary transaction in connection with the Service. Buy-now-pay-later financing is not available at the Assessment Checkout precisely to preserve the card-of-record VPC pathway.
Carry-forward. Once VPC is obtained at the Assessment Checkout for the disclosed data practices, it extends to all subsequent collection and use of that child's personal information for the same disclosed purposes. Subsequent Tuition transactions — whether by card or by BNPL Provider — do not require a fresh VPC step under 16 CFR §312.5(a)(1).
Parental rights. Parents may at any time review, correct, delete, or refuse further collection of their child's personal information by emailing info@learnyourwayliteracy.com. We respond within ten business days for COPPA review and deletion requests.
No surplus collection. We do not condition participation on the child providing more information than is reasonably necessary.
7. Data Retention
We retain personal information only as long as reasonably necessary for the purposes described, then delete or de-identify it.
A parent's deletion request overrides these defaults except where retention is required by law (notably, the 7-year payment-records window).
8. Security
We use commercially reasonable administrative, technical, and physical safeguards: encryption in transit (TLS 1.2 or higher) and at rest for databases holding student records; least-privilege access controls; multi-factor authentication on staff accounts; periodic access reviews; vendor security review for new processors; and a documented incident-response process. No system is perfectly secure; in the event of a data breach affecting personal information, we will notify affected parents and applicable authorities as required by law.
9. Your Privacy Rights
Regardless of where you live, you may email info@learnyourwayliteracy.com to:
- access the personal information we hold about you or your child;
- correct inaccurate information;
- delete personal information;
- export your data in a portable format; and
- withdraw consent for optional uses (recordings, newsletters).
We respond within thirty days (ten business days for COPPA review and deletion requests). We may verify identity before fulfilling, typically by confirming details from the account of record. We do not discriminate against you for exercising any privacy right.
9.1 California Residents (CCPA / CPRA, AB 1949)
You have the right to know, delete, correct, and port your personal information; to opt out of sale or sharing; and to limit use of sensitive personal information. LYWL does not sell or share personal information for cross-context behavioral advertising, including (and especially) personal information of any consumer under eighteen. We do not "process sensitive personal information" for purposes other than those permitted under Cal. Civ. Code §1798.121 and CCPA Regulations §7027(m). Categories collected in the past twelve months: identifiers, customer records, commercial information (transactions), internet activity (site analytics), audio (recorded sessions with consent), education information, and sensitive personal information (learning-difference diagnoses where provided by the parent). To exercise CCPA rights, email info@learnyourwayliteracy.com or use any "Do Not Sell or Share" link present on the site (the link is posted for clarity even though there is nothing to opt out of).
9.2 Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and Similar Comprehensive-Privacy-Law States
You have analogous rights of access, deletion, correction, portability, and opt-out of targeted advertising and sale. None of those activities (targeted advertising, sale) take place at LYWL. To exercise these rights, email the address above. You may appeal a denial by responding to the denial email; we will review at the supervisor level within forty-five days.
9.3 Washington Residents — My Health My Data Act
To the extent dyslexia or other learning-difference information shared with us is treated as "consumer health data" under RCW 19.373, LYWL collects this data only with affirmative parent authorization at enrollment, uses it only to deliver the requested tutoring service, and does not sell it. A separate Washington Consumer Health Data Privacy Policy, mirroring this section, is published at learnyourwayliteracy.com/wa-health-privacy.
9.4 European, United Kingdom, and Italian Residents
LYWL does not currently offer the Service to EU or UK residents. A GDPR-compliant addendum will be published before LYWL Italy launches.
10. International Transfers
LYWL is based in the United States, and data is processed in the United States. By using the Service from outside the United States, you consent to that transfer.
11. Cookies and Tracking
The marketing site uses essential cookies for site functionality and basic, privacy-respecting analytics provided by gamma.app. We do not use advertising cookies, tracking pixels, or social-media trackers on the parent or Student dashboards. Cookie preferences can be managed in your browser.
12. Do Not Track and Global Privacy Control
We honor browser-level Global Privacy Control ("GPC") signals as opt-out-of-sale-or-sharing requests where required by law. Because LYWL does not sell or share personal information for advertising, GPC has no operational effect, but we recognize it.
13. Changes to This Policy
We will notify parents by email of any material change at least fourteen days before it takes effect. The "Last Updated" date above reflects the most recent revision.
14. Contact
Questions, requests, or complaints:
Email: info@learnyourwayliteracy.com
Mailing address: LYWL LLC c/o Northwest Registered Agent LLC, 30 N Gould St Ste R, Sheridan, WY 82801.
If you believe we have not addressed a complaint adequately, you may contact your state attorney general's office or, for COPPA matters, the Federal Trade Commission at ftc.gov/complaint.