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Privacy Policy

Last updated: April 14, 2026

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French-language versions of our policies are available upon request. / Des versions françaises de nos politiques sont disponibles sur demande.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Tampa Bay Learning, LLC, 1553 Boren Dr, Ocoee FL 34761.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: FL, United States

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to GradePower Learning, accessible from https://gradepowerlearning.us

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

GDPR Compliance

As we serve customers globally, we comply with the General Data Protection Regulation (GDPR) for European Union residents. This section outlines your rights under GDPR and how we protect your data.

Lawful Basis for Processing

We process your personal data based on the following lawful bases:

Contractual Necessity: To fulfill our tutoring service agreements and provide educational services
Legitimate Interest: To communicate with parents/students about educational progress, schedule sessions, and improve our services
Legal Obligation: To comply with educational record-keeping requirements and applicable laws
Consent: For marketing communications and optional services where you have given explicit consent

Your GDPR Rights

Under GDPR, you have the following rights regarding your personal data:

Right to Access: Request a copy of the personal data we hold about you
Right to Rectification: Request correction of inaccurate personal data
Right to Erasure: Request deletion of your personal data (see "Delete Your Personal Data" section)
Right to Restrict Processing: Request limitation of how we use your personal data
Right to Data Portability: Request transfer of your personal data to another service provider
Right to Object: Object to processing of your personal data for direct marketing
Right to Lodge a Complaint: Contact a supervisory authority if you believe our processing violates GDPR

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place for such transfers, including:

Standard Contractual Clauses with our service providers
Adequacy decisions where the European Commission has determined a country provides adequate protection
Compliance with GDPR's requirements for international transfers

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant authorities without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach.

Third-Party Service Providers and Data Processing Agreements

We share your personal data with trusted third-party service providers who help us deliver our educational services. All providers are carefully vetted and bound by data processing agreements that ensure they protect your data to the same standards we do.

Categories of Service Providers

Communication Services: Twilio (SMS/text messaging), Mailgun (email communications)
Cloud Infrastructure: Google Firebase (database, hosting, authentication)
Payment Processing: QuickBooks Online (billing and payment processing)
Analytics and Monitoring: Google Analytics (website usage analytics)
Educational Tools: Third-party assessment and learning platforms

Data Processing Agreement Requirements

Our data processing agreements with third parties include:

Strict confidentiality obligations
Purpose limitation (data only used for specified services)
Data security requirements equal to or exceeding our own standards
No further processing without our explicit consent
Right to audit and verify compliance
Data deletion or return upon contract termination
Assistance with data subject rights requests
Immediate notification of any data breaches

Google reCAPTCHA

We use Google reCAPTCHA v3 on our contact forms and chat widgets to help protect our site from spam and abuse. Your use of reCAPTCHA is subject to Google's Privacy Policy and Terms of Service.

Data Retention Policy

We retain personal data for no longer than necessary to fulfill the purposes for which it was collected, in accordance with legal requirements and business needs.

Retention Periods

Student Records: 15 years from the date of last enrollment or until the student reaches age 25, whichever is longer
Financial Records: 7 years to comply with tax and accounting requirements
Communication Records: 3 years from the date of communication
Website Analytics: 26 months (Google Analytics default)
Marketing Consent Records: As long as consent remains active or until withdrawal

Data Deletion Process

When retention periods expire, we securely delete or anonymize personal data. You may also request earlier deletion of your data as outlined in the "Delete Your Personal Data" section.

Legal Hold

We may retain certain data beyond standard retention periods if required for legal proceedings, regulatory investigations, or to comply with legal obligations.

FERPA Compliance

As an educational institution, GradePower Learning complies with the Family Educational Rights and Privacy Act (FERPA), which protects the privacy of student education records.

Your FERPA Rights

Parents and eligible students (students who are 18 years of age or older) have the following rights under FERPA:

Right to Inspect and Review: The right to inspect and review the student's education records maintained by the school
Right to Seek Amendment: The right to seek amendment of the student's education records that the parent or eligible student believes are inaccurate, misleading, or otherwise in violation of the student's privacy rights
Right to Consent to Disclosures: The right to provide written consent before the school discloses personally identifiable information from the student's education records, except to the extent that FERPA authorizes disclosure without consent
Right to File a Complaint: The right to file a complaint with the U.S. Department of Education concerning alleged failures by the school to comply with FERPA

FERPA Privacy Concerns

If you have concerns about your child's educational records, believe your FERPA rights have been violated, or have questions about our privacy practices, please contact our Data Privacy Officer:

Email: alearned@gradepowerlearning.com
Response Time: We will investigate and respond to all FERPA-related concerns within 5 business days

Directory Information

FERPA allows schools to disclose "directory information" without consent, unless the parent has opted out. GradePower Learning considers the following as directory information:

Student's name, grade level, and enrollment status
Participation in officially recognized activities and sports
Dates of attendance and graduation

Parents may opt out of directory information disclosure by contacting us at the email address above.

Ontario Law-25 (CPPA) Compliance

GradePower Learning complies with Ontario's Law-25 (Consumer Privacy Protection Act, CPPA) for our Ontario-based customers and operations. This legislation strengthens privacy protections for Canadian consumers.

Your Rights Under Law-25

Under Ontario's Law-25, you have the following rights regarding your personal information:

Right to Know: The right to know what personal information is being collected, used, and disclosed
Right to Consent: The right to meaningful consent for collection, use, and disclosure of personal information
Right to Withdraw Consent: The right to withdraw consent at any time, subject to legal or contractual restrictions
Right to Access: The right to access and request correction of your personal information
Right to Data Portability: The right to request transfer of your personal information in a structured, commonly used format
Right to Be Informed: The right to be informed about privacy breaches that pose a real risk of significant harm
Right to Complain: The right to complain to the Privacy Commissioner of Canada about our privacy practices

Law-25 Specific Requirements

We comply with the following Law-25 requirements:

Privacy Management Program: We maintain a comprehensive privacy management program to ensure compliance with Law-25
Record-Keeping: We maintain records of our privacy policies, practices, and consent management
Privacy Breach Reporting: We report privacy breaches to the Privacy Commissioner and affected individuals when required
Employee Training: Our staff receive regular training on privacy obligations and Law-25 compliance

Ontario Privacy Concerns

For Ontario customers with privacy concerns or questions about Law-25 compliance, please contact our Data Privacy Officer:

Email: alearned@gradepowerlearning.com
Response Time: We will respond to Law-25 related inquiries within 30 days, as required by the legislation
Complaints: You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: OcoeeFL@gradepowerlearning.com
By visiting this page on our website: https://gradepowerlearning.us/privacy

Data Privacy Officer

For matters related to data protection, privacy rights, and GDPR compliance, please contact our Data Privacy Officer:

Name: Andrew Learned
Title: Data Privacy Officer
Email: alearned@gradepowerlearning.com
Address: GradePower Learning Valrico, 2470 Bloomingdale Avenue, Valrico, FL 33596
Phone: (813) 669-3690

Our Data Privacy Officer is responsible for overseeing data protection strategies, handling data subject requests, managing data breach notifications, and ensuring ongoing compliance with privacy regulations including GDPR, COPPA, and FERPA.