Privacy Policy

Tuff AI Learning Academy is an online K–12 education company headquartered in Chicago, Illinois. We operate the following services:

• Tuff AI Learning Academy — AI, STEM, coding, business, and career readiness courses for K–12 students, available at tuffailearningacademy.com
• Tuff Tutors — Personalized live online tutoring with certified teachers for K–12 students, available at tuffailearningacademy.com/tuff-tutors
• Tuff AI University — Adult professional development and income-building courses, available at whop.com/tuff-ai-university

This Privacy Policy applies to all services operated by Tuff AI Learning Academy, including our websites, enrollment forms, email communications, SMS communications, and any related platforms.

We collect information in the following ways:

2.1 Information You Provide Directly

When you complete an enrollment form, book a free academic assessment, purchase a tutoring plan, or contact us, we may collect:

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain technical information, including:

• IP address and approximate geographic location
• Browser type and version
• Device type (desktop, mobile, tablet)
• Operating system
• Pages visited and time spent on each page
• Referring website or source
• Clicks, scrolls, and interactions on our pages
• Date and time of your visit

This information is collected through cookies, pixels, and analytics tools described in Section 6.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Meta (Facebook/Instagram): If you interact with our ads or pages on Facebook or Instagram
• Google: If you click on our Google Search or Display ads
• GoHighLevel CRM: Our customer relationship management platform that stores and manages contact records
• Stripe: Payment processing platform that provides transaction confirmation data
• Whop: Course platform that provides enrollment and purchase data for Tuff AI University courses

We use the information we collect for the following purposes:

3.1 To Provide Our Services

• Process your enrollment and set up your tutoring account
• Match your child with the right certified teacher
• Schedule and confirm tutoring sessions
• Deliver live online tutoring sessions
• Send progress reports and session updates to parents
• Process payments securely through Stripe
• Provide ESA documentation and reimbursement support
• Deliver online courses purchased through Tuff AI University

3.2 To Communicate With You

• Send enrollment confirmations and booking confirmations
• Send appointment reminders and session follow-ups
• Respond to your questions, support requests, and inquiries
• Send SMS messages you have consented to receive (see Section 4)
• Send email communications you have consented to receive (see Section 5)
• Send important account and service updates

3.3 To Improve Our Services

• Analyze website traffic and user behavior to improve our pages
• Measure the effectiveness of our advertising campaigns
• Identify and fix technical issues on our website
• Develop new features, courses, and tutoring programs
• Conduct internal research and analytics

3.4 For Marketing and Advertising

• Show you relevant ads on Facebook, Instagram, and Google based on your interests
• Create retargeting audiences to reach families who have visited our website
• Build lookalike audiences to find new families similar to our existing customers
• Send promotional emails and SMS messages to subscribers who have opted in
• Measure the return on investment of our advertising spend

3.5 For Legal and Compliance Purposes

• Comply with applicable federal, state, and local laws and regulations
• Respond to lawful requests from government authorities
• Enforce our Terms of Service and other agreements
• Protect the rights, property, and safety of our company, staff, students, and families
• Prevent fraud, abuse, and unauthorized access to our systems

4.1 Types of SMS Messages We Send

We send two categories of text messages:

Transactional / Service SMS (Required Consent):

• Enrollment confirmations and welcome messages
• Assessment booking confirmations and reminders
• Tutoring session reminders and scheduling updates
• Account and service notifications
• Responses to your direct inquiries

Marketing / Promotional SMS (Optional Consent):

• Special offers, discounts, and promotions
• New course and program announcements
• Educational tips and resources
• Re-enrollment and referral campaigns

4.2 Message Frequency

Message frequency varies based on your enrollment status and the services you use. Transactional messages are sent as needed based on your account activity. Marketing messages are sent no more than a few times per week.

4.3 Message and Data Rates

Message and data rates may apply depending on your mobile carrier and plan. Tuff AI Learning Academy does not charge for SMS messages, but your carrier's standard messaging rates may apply.

4.4 How to Opt Out

You may opt out of SMS messages at any time by replying STOP to any text message you receive from us. After opting out, you will receive one final confirmation message and no further promotional messages will be sent. To opt back in, reply START.

4.5 Help

Reply HELP to any SMS message for assistance, or contact us directly at [email protected].

4.6 SMS Service Providers

We use GoHighLevel as our SMS platform. Your mobile number is stored securely within our CRM system and is not sold to third parties. Carriers are not liable for delayed or undelivered messages.

When you provide your email address through our enrollment form, assessment booking, or checkout process, we may send you the following types of emails:

5.1 Transactional Emails (Service-Related)

These emails are sent as part of delivering our services and do not require separate marketing consent:

• Enrollment confirmation and welcome emails
• Assessment booking confirmations and reminders
• Tutoring session confirmations and reminders
• Progress reports and session summaries
• Payment receipts and billing notifications
• ESA documentation and reimbursement support emails
• Account security and service update notifications

5.2 Marketing Emails (Promotional)

With your consent, we may send promotional emails including:

• Special offers, discounts, and limited-time promotions
• New course and program announcements
• Educational tips, resources, and parent guides
• Referral program invitations and rewards
• Re-enrollment campaigns and retention offers
• Tuff AI University course recommendations

5.3 How to Unsubscribe

You may unsubscribe from marketing emails at any time by clicking the Unsubscribe link at the bottom of any marketing email, or by contacting us at [email protected]. Unsubscribing from marketing emails will not affect transactional service emails related to your active enrollment.

5.4 CAN-SPAM Compliance

All marketing emails we send comply with the CAN-SPAM Act. Every marketing email includes our physical mailing address, a clear identification that the message is an advertisement, and a working unsubscribe mechanism that is honored within 10 business days.

Our website uses cookies and similar tracking technologies to improve your experience, analyze traffic, and support our advertising efforts.

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences, track your activity, and deliver relevant content and advertising.

6.2 Types of Cookies We Use

6.3 Meta Pixel

We use the Meta Pixel on our website to measure the effectiveness of our Facebook and Instagram advertising campaigns. The Meta Pixel may collect information about your actions on our website (such as page views and form submissions) and share this data with Meta Platforms, Inc. This data is used to optimize our ad delivery and build retargeting audiences. For more information, see Meta's Privacy Policy.

6.4 Google Analytics

We use Google Analytics 4 (GA4) to analyze website traffic and user behavior. Google Analytics collects anonymized data about how visitors interact with our website. This data is processed by Google LLC. For more information, see Google's Privacy Policy. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

6.5 How to Control Cookies

You can control and delete cookies through your browser settings. Most browsers allow you to:

• View and delete existing cookies
• Block cookies from specific websites
• Block all third-party cookies
• Clear all cookies when you close your browser

Please note that disabling certain cookies may affect the functionality of our website. Disabling essential cookies may prevent forms from working correctly.

We share your information only in the following limited circumstances:

7.1 Service Providers (Processors)

We share information with trusted third-party service providers who help us operate our business. These providers are contractually required to protect your information and may only use it to provide services to us:

7.2 Certified Tutors

We share limited student information (first name, grade level, subject needs, and scheduling preferences) with the certified tutor assigned to your child. Tutors are required to maintain the confidentiality of all student information and may not use it for any purpose other than delivering tutoring services.

7.3 ESA Program Administrators

If you are using Education Savings Account (ESA) funds to pay for our services, we may share required documentation (such as invoices, session records, and provider verification) with your state's ESA program administrator to support your reimbursement request. We only share the minimum information required for ESA compliance.

7.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal process, including:

• Court orders, subpoenas, or other legal process
• Requests from law enforcement or government agencies
• To protect the rights, property, or safety of our company, staff, students, or families
• To prevent fraud, abuse, or illegal activity

7.5 Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transfer, your personal information may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

8.1 Our COPPA Compliance Approach

• All enrollment forms, assessment bookings, and account creation are completed by parents or guardians — not by students
• We collect student information (grade level, subjects, learning goals) only from parents and guardians
• We do not knowingly collect personal information directly from children under the age of 13
• We do not use student information for advertising or marketing purposes
• Student information is shared only with the assigned certified tutor and, where required, ESA program administrators

8.2 Parental Rights Under COPPA

As a parent or guardian, you have the right to:

• Review the personal information we have collected about your child
• Request that we delete your child's personal information
• Refuse to permit further collection or use of your child's information
• Consent to the collection and use of your child's information without consenting to its disclosure to third parties

To exercise any of these rights, contact us at [email protected].

8.3 If We Discover Unauthorized Collection

If we discover that we have inadvertently collected personal information directly from a child under 13 without verifiable parental consent, we will promptly delete that information from our systems. If you believe we have collected information from your child without your consent, please contact us immediately at [email protected].

8.4 FERPA Considerations

To the extent that any student education records are created in connection with our tutoring services, we treat such records with the same protections as required under the Family Educational Rights and Privacy Act (FERPA). Parents and eligible students have the right to inspect and review education records and request corrections to inaccurate information.

For families using Education Savings Account (ESA) funds to pay for Tuff Tutors services, we maintain certain education records to support your reimbursement requests. These records may include:

• Session attendance logs and dates
• Session duration records
• Invoices and payment records
• Provider verification documentation
• Tutor credentials and certification records
• Student progress summaries (as required by your state's ESA program)

These records are maintained securely and shared only with:

• The parent or guardian who enrolled the student
• The state ESA program administrator, upon your request or as required for reimbursement
• Authorized Tuff AI Learning Academy staff involved in ESA compliance

We do not share ESA documentation with any other third parties without your explicit written consent.

We take the security of your personal information seriously and implement reasonable technical, administrative, and physical safeguards to protect it from unauthorized access, disclosure, alteration, and destruction.

10.1 Security Measures We Use

• SSL/TLS Encryption: All data transmitted between your browser and our website is encrypted using industry-standard SSL/TLS protocols
• Secure Payment Processing: All payment transactions are processed by Stripe, a PCI-DSS compliant payment processor. We do not store full credit card numbers on our servers
• Access Controls: Access to personal information is restricted to authorized staff members who need it to perform their job functions
• Secure CRM Platform: We use GoHighLevel, a secure CRM platform with enterprise-grade security, to store and manage contact records
• Regular Security Reviews: We periodically review our security practices and update them as needed

10.2 Limitations

While we implement reasonable security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. In the event of a data breach that affects your personal information, we will notify you as required by applicable law.

10.3 Your Role in Security

You can help protect your information by:

• Using a strong, unique password for any accounts you create with us
• Not sharing your account credentials with others
• Contacting us immediately if you suspect unauthorized access to your account
• Keeping your contact information up to date so we can reach you in the event of a security issue

We retain your personal information for as long as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our agreements.

When your information is no longer needed, we will securely delete or anonymize it. You may request earlier deletion of your personal information as described in Section 12.

Depending on your location and applicable law, you may have the following rights regarding your personal information:

How to Exercise Your Rights

To exercise any of the rights listed above, contact us at:

• Email: [email protected]
• Subject line: "Privacy Rights Request"
• Include: Your full name, email address, and a description of the right you wish to exercise

We will respond to your request within 30 days. In some cases, we may need to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

13.1 Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information from California residents:

13.2 Your California Rights

As a California resident, you have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for collecting it, and the categories of third parties with whom we share it
• Delete: Request deletion of your personal information, subject to certain exceptions
• Correct: Request correction of inaccurate personal information
• Opt Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising. If this changes, we will update this policy and provide an opt-out mechanism
• Limit Use of Sensitive Personal Information: Request that we limit the use of sensitive personal information to what is necessary to provide our services
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights

13.3 How to Submit a California Privacy Request

To submit a CCPA/CPRA request, contact us at [email protected] with the subject line "California Privacy Request." We will respond within 45 days. We may need to verify your identity before processing your request.

13.4 Authorized Agent

You may designate an authorized agent to submit a privacy request on your behalf. The authorized agent must provide written proof of authorization, and we may require you to verify your identity directly with us before processing the request.

Our website and communications may contain links to third-party websites, platforms, and services that are not operated by Tuff AI Learning Academy. These include:

• Whop.com — Course delivery platform for Tuff AI University courses
• Stripe.com — Payment processing for tutoring plan purchases
• Facebook.com / Instagram.com — Social media platforms
• YouTube.com — Video content platform
• TikTok.com — Social media platform
• State ESA program portals (Arizona, Louisiana, Utah, Georgia, Florida, Iowa, Texas)

When you click on a link to a third-party website, you leave our website and are subject to that website's own privacy policy and terms of service. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policy of every website you visit.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other operational reasons. When we make material changes to this policy, we will:

• Update the "Last Updated" date at the top of this page
• Post the updated policy at tuffailearningacademy.com/privacy-policy
• Send an email notification to active enrolled families when changes are material
• Display a notice on our website for a reasonable period after significant changes

Your continued use of our services after the effective date of any updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with the updated policy, you should discontinue use of our services and contact us to close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us using any of the methods below. We are committed to responding to all privacy inquiries within 30 days.