June 2026

Preamble
Welcome to At-Home Tutoring Services® (“A-HTS®,” “we,” “our,” or “us”). At A-HTS®, we are deeply committed to providing world-class, personalized educational support while upholding the highest standards of privacy and data security for our students, parents, and all users.

This Privacy Policy serves to clearly explain how we collect, use, store, share, and protect your information when you interact with our website, utilize our personalized tutoring services, and engage with our various online tools and platforms. Our data handling practices are designed to ensure transparency and accountability, and they strictly comply with applicable privacy laws and regulations, including the Children’s Online Privacy Protection Act (COPPA), the Family Educational Rights and Privacy Act (FERPA), and the General Data Protection Regulation (GDPR) for our international users.

By accessing or using any of our Services, you signify your agreement to the terms outlined in this Privacy Policy. We encourage you to read this policy thoroughly to understand our commitments and your rights regarding your Personal Information.

Summary of Key Concepts

Privacy policies can be extensive, so we’ve provided a brief overview of our core practices:

• We Value Your Privacy: Our fundamental commitment is to protect your Personal Information with care and respect, guided by principles of transparency, data minimization, and strong security.
• What We Collect: We gather Personal Information (like names, contact details, educational records) and Usage Information (like IP addresses, website interactions) to provide and improve our services. We only collect what’s necessary.
• How We Use Data: Your information is primarily used to deliver personalized tutoring, communicate with you, process payments, enhance service quality, and ensure security.
• Personalized Marketing: We do not sell your Personal Information for profit. However, we do use cookies and hashed data to provide personalized advertisements on platforms like Facebook and Google to help families find our services.
• Limited Sharing: We share information only with essential service providers (e.g., payment processors, virtual classroom tools), our authorized staff, and, in specific cases, with contracted educational partners.
• Children’s Privacy (COPPA): We have strict measures for children under 13, including verifiable parental consent before collecting their data.
• Your Rights: You have rights to access, correct, delete, and control your data. For EEA+ users, additional GDPR rights apply.
• Transparency & Updates: This policy details our practices, and we commit to updating it as our services or regulations change.

1. Our Core Privacy Principles

Our approach to privacy is guided by the following fundamental principles, ensuring a trustworthy and secure environment for all users:

• Transparency: We are committed to being open and clear about the types of information we collect and how we use it. This Policy aims to provide a comprehensive and easily understandable overview of our data practices.
• Data Minimization: We collect only the Personal Information that is necessary to fulfill the specific purposes outlined in this Policy and to provide our Services effectively. We avoid collecting superfluous data.
• Purpose Limitation: We use your Personal Information solely for the purposes for which it was collected, as explicitly stated in this Policy. We do not use it for unrelated purposes without your consent.
• Security: We implement robust technical, administrative, and physical safeguards to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction.
• Accuracy: We strive to maintain accurate, complete, and up-to-date Personal Information. We provide mechanisms for you to review and correct your data.
• Accountability: We are responsible for the Personal Data under our control and are committed to complying with all applicable privacy laws. We hold our third-party partners to similar high standards.
• Children’s Privacy First: We uphold strict standards for the privacy of younger learners, adhering to COPPA and FERPA, and obtaining verifiable parental consent where required.

2. Information We Collect

We collect various types of Personal Information and other data to effectively provide, maintain, and continually improve the quality and personalization of our tutoring Services. This information falls into several categories, depending on your role (e.g., Parent/Guardian, Student, Tutor Applicant) and how you interact with our Services.

A. How We Collect Personal Information

1. Information You Provide Directly: We collect Personal Information that you voluntarily provide directly to us when you interact with our Services. This occurs, for example, when you:

   • Register for an account or create a Profile (as a parent, student, or tutor).
   • Sign up for our tutoring Services or submit an inquiry.
   • Complete forms, surveys, or questionnaires.
   • Communicate with us via email, phone, chat, or through our online support channels.
   • Participate in tutoring sessions (e.g., notes, shared documents, chat logs, if recorded with consent).
   • Provide feedback or submit reviews.
   • Make payments or donations.

2. Information Collected from Third Parties: We may receive Personal Information from other sources, such as:

   • Parents/Guardians & Schools: Information provided by parents or schools regarding student enrollment, educational context, or specific learning requirements, consistent with FERPA.
   • Single Sign-On (SSO) Providers: If you choose to register or log in using an SSO service (e.g., Google), we may receive certain Identity Data and Contact Data that you authorize the SSO provider to share, as detailed in Section 5.B.
   • Educational Partners: Data shared by educational institutions or partners under contract with A-HTS® to facilitate our services.
   • Publicly and Commercially Available Databases: In some cases, we may supplement the information you provide with data from public sources to verify information or for legitimate business purposes (if applicable, as detailed in Section 4).

3. Information Collected Automatically (Automatic Data Collection): When you access or use our Services, we may automatically log information about you, your computer or mobile device, and your activity over time. This data is collected to ensure our Services function properly, enhance user experience, and for analytical purposes. This includes:

   • Device Data: Your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, language settings, and general location information (e.g., city, state).
   • Online Activity Data: Pages or screens you viewed, how long you spent on a page or screen, the website you visited before Browse to the Services, navigation paths between pages or screens, access times, and duration of access.
   • Technical Data: Data routinely collected by online services, such as your log-in data, browser plug-in types and versions, operating system and platform, and other technology on the devices you use.
   • Cookies and Similar Technologies: Some of our automatic data collection is facilitated by cookies, web beacons, and other tracking technologies. For detailed information about our use of these technologies, what they do, and how you can manage them, please refer to our dedicated Cookie Policy (Section 9).

4. Collection of Information by Payment Services:Payment Data and Donation Data are processed directly by our Payment Services providers (e.g., QuickBooks Online/Inuit) via secure payment pages or integrated forms. While these services process payments on our behalf, they typically act as ‘processors’ for your payment data. They may also have their own legal and regulatory obligations that might require them to use your Payment Data for their own compliance-related purposes (e.g., security and fraud prevention).

5. This Policy does not address Payment Services’ independent processing of Payment Data or Donation Data for such purposes, which will be subject to that Payment Service’s privacy policy rather than this Policy. A-HTS® may need to temporarily store sensitive payment card details (like full card numbers or security codes) on its servers or its vendors’ servers for the limited purpose of confirming the viability of payments.  We only receive confirmation of payment and, in some cases, the last four digits of your card for reference and redact sensitive information immediately.

B. Categories of Personal Information Processed

This section describes the categories of Personal Information that we process, collected through the methods described above. Please note that the specific data collected will vary based on your interaction with A-HTS® (e.g., whether you are a prospective student, a registered student or a parent).

• Identity Data: This includes personal identifiers such as your full name, username or similar identifier, age, and password and other log-in credentials. For students, this may include their preferred name. For parents, this would include your name as the legal guardian. For tutors, this would include your professional name and potentially a profile picture.
• Contact Data: This category includes information that allows us to communicate with you, such as your email address, phone number, and mailing address (including street address, city, state, country, and ZIP code).
• Parental Data: When children’s Personal Information is collected, we may receive your email address as a parent where we need your parental consent to comply with applicable law. This also includes any other Personal Information that you choose to provide us during the course of our correspondence relating to the administration of your child’s Profile or services.
• Educational Information: This category encompasses data related to the learning process, such as session records, diagnostic results, learning progress, assessments, coursework, grades, and specific learning needs or preferences. This information is crucial for tailoring and improving our tutoring services.
• Student Profile Data: This includes information related to a student’s academic context, such as their school’s name, grade level, and subject interests.
• Tutor Profile Data: For tutors, this includes professional qualifications, subjects taught, biographical details, and any optional profile information provided.
• Service Personalization Data: This category includes the preferences that you set by configuring your Profile to identify the topics, content, or types of tutoring you want to receive or provide as part of the Services.
• Communication Interaction Data: This involves information about your engagement with our email newsletters or other electronic communications (e.g., whether an email was opened or links were clicked), which may be collected by web beacons or similar technologies.
• Payment Data: This refers to information necessary to process payments for our services, such as the name as shown on your card, billing address (street address, city, state, country, ZIP code), expiration date, and payment card number (though we only receive the final four digits, with full details handled by our Payment Services provider).
• Analytics Data: This category includes internet log information and details of user behavior patterns gathered by analytics tools (e.g., Google Analytics). This data is often aggregated or de-identified.
• Technical Data: Data routinely collected by online services, such as Browse activity, Internet Protocol (IP) address, your log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services. Certain elements of this Technical Data may be linked to online identifiers as outlined in our Cookie Policy.
• Review and User Submitted Data: Where you post a comment or submit feedback, in addition to certain Identity Data attached to your account, we also collect any Personal Information that you choose to include in that content.
• Survey Data: Depending on the survey, in addition to certain Identity Data, Contact Data, and Technical Data, we also collect any other information requested by, or that you submit in response to, a survey. This may include demographic data such as gender, race/ethnicity, income, education level, or living situation.
• Event and Webinar Data: If you register for or attend events or webinars, we collect your email address (and in certain instances other requested Identity Data and Contact Data) to sign you up, provide details, and if the event is recorded and you choose to share your image/audio or participate, your image, audio, questions, and comments may be published or recorded.

3. How We Use Information

The information we collect is primarily used for the following specific purposes, all aimed at delivering high-quality educational services and a seamless user experience. We use Personal Information for the following purposes:

• Fulfillment of Requests and Service Delivery: To deliver personalized tutoring services and support, fulfill the purpose for which such information was provided (e.g., sending newsletters, responding to inquiries, providing customer service), and ensure the effective operation of your account. This includes scheduling sessions, matching students with appropriate tutors, and facilitating online learning environments.
• Additional Communications: To communicate with parents and students regarding session schedules, progress updates, billing inquiries, important service announcements, and educational opportunities. We may additionally use Personal Information to contact you about A-HTS content, features, opportunities, and products that may be of interest to you.
• Membership & Profile Maintenance: To maintain and update your Profile and postings in our online systems. All content that you submit to the Services is governed by our Terms of Use. We may also use Personal Information to send updates and communications to our Members, such as our e-newsletters, surveys and other important A-HTS communications such as information regarding the Services or changes to our terms, conditions and policies.
• Internal Operations and Analysis: For our internal business purposes, such as data analysis, audits, enhancing or modifying our products and services, and so forth. This also includes managing internal workflows and operations, and troubleshooting issues that might occur on our systems.
• Personalization: To personalize your experience on the Services by presenting content and opportunities tailored to you, or to allow you to participate in promotions and administer these activities. For example, we might send you emails encouraging engagement or push notifications recommending learning resources based on your past Browse behavior or learning progress.
• To Process Payments and Manage Billing: Your payment information is used solely for processing transactions and managing your account’s financial aspects through our secure payment gateway.
• To Ensure Security and Prevent Fraud: We utilize information to maintain the security and integrity of our services, detect and prevent fraudulent activities, and protect our systems and users from unauthorized access.
• Use of AI: We may process Personal Information in connection with our use of artificial intelligence (AI) technologies to enhance your experience on our platform by providing personalized recommendations based on your preferences and interactions, as well as for content moderation (if applicable to user-generated content). AI analyzes your activity to suggest relevant materials or services and automates the review of user-generated content to ensure compliance with our community guidelines. While we strive for accuracy, please note that AI is not infallible, and human oversight is involved in review processes. If you have any questions or concerns regarding the use of AI in our services, please contact us. We do not use automated decision-making that produces legal or similarly significant effects on users.
• Advertising (Limited to Our Own Services): Regarding our media site or app (if applicable), we may use your Personal Information to deliver marketing and promotional campaigns exclusively related to A-HTS services and enhance your experience on our platform. This includes analyzing your interactions and preferences to present you with relevant content. Any advertising or marketing activities are exclusively related to At-Home Tutoring Services and its direct offerings; no data is used for third-party advertising or collected on other domains for such purposes. For more detailed information, please refer to our Cookie Policy (Section 9).
• Compliance: We may also use your Personal Information for the purposes described in the Law Enforcement; Emergencies; Compliance section (Section 5.C).

You may opt out of receiving our e-newsletters or any other e-mail marketing communications at any time by clicking the “unsubscribe” or “manage my email preferences” links at the bottom of the email or by contacting us directly as described in Section 12.A. We will not sell or use your Personal Information for profiling in furtherance of decisions that produce legal or similar significant effects.

4. Legal Bases for Processing Data (for GDPR Compliance)

For users located in the European Economic Area (EEA) and the UK (together, the EEA+), our processing of your Personal Data is based on specific lawful grounds as required by the General Data Protection Regulation (GDPR). Most commonly, we will rely on one of the following legal bases:

• Contractual Necessity: Where we need to perform a contract we are about to enter into or have entered into with you, such as delivering the agreed-upon educational services.
• Legal Obligations: Where it is necessary for us to comply with a legal or regulatory obligation, including tax regulations, educational mandates, and other applicable laws.
• Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. This includes improving our Services, enhancing user experience, and ensuring effective communication.
• Consent: Where we have your specific consent to carry out the processing for the Purpose in question. This applies to specific activities, such as sending certain marketing communications or processing of minors’ data beyond what is strictly necessary for the service. You have the right to withdraw consent at any time where consent is the legal basis for processing.

What happens when you do not provide necessary Personal Data or you withdraw consent?
Where we need to process your Personal Information either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. Similarly, if we rely on your consent to process your Personal Information, you are entitled to withdraw your consent, but if you do, we may not be able to provide certain services or features to you. We will keep you informed of when your access to service or features depends on your consent.

5. Data Sharing and Disclosure

Your privacy is paramount, and we are committed to transparent practices regarding data sharing.

• Absolutely No Sale of Personal Data: We do not sell, rent, or trade your Personal Information to any third parties under any circumstances.
• No Third-Party Marketing or Targeted Advertising: We do not share Personal Data with advertisers for their direct marketing purposes, nor do we permit third parties to use your data for targeted advertising based on your Personal Information, cross-site tracking, cross-app tracking, or commercial profiling of our users.

We only share information under strict conditions and for specific purposes as outlined below:

A. Limited & Necessary Disclosures for Service Operations

• With Tutors and Internal Staff: Your information, particularly educational and Personal details, is shared with our qualified tutors and authorized internal staff solely as necessary to provide the tutoring services and manage your account. All personnel are bound by strict confidentiality agreements.
• Payment Processors: We share necessary payment information with our trusted payment processor, QuickBooks, to facilitate secure billing and transaction processing.
• Technology Providers: We utilize third-party technology providers for essential services that support our operations. This includes HubSpot for customer relationship management and communication tracking, Pearl for virtual classroom functionality, and Google Meet for video conferencing during sessions. These providers are selected for their robust security and privacy standards and are restricted from using your Personal Information for purposes other than providing services for us. We ascertain that our third-party service providers are capable and obligated to provide at least the same level of data privacy and protection as we hold ourselves to. When engaging a third-party who will need to access and process your Personal Information as part of their services, we monitor for compliance to our data protection terms based on the nature of the services being provided.
• Educational Partners (Under Contract): In instances where A-HTS® is contracted by an educational institution (e.g., a school district or private school) to provide services, student educational data may be shared with that specific educational partner, but only under explicit contractual agreements that comply with FERPA and other applicable privacy laws.

B. Single Sign-On (SSO) Services

If you choose to register or log in to our Services through a Single Sign-On Service (e.g., Google), we may ask for your permission to access certain data on that SSO Service to create and link your A-HTS account. We may use this data for purposes such as:

• Populating Account and Profile Fields: To pre-populate and update your account and Profile fields with data from the SSO Service that you allow us to access. You can update this information at any time in your Account and Profile settings.
• Personalizing the Services: To personalize your experience, for example, by displaying your name or profile picture (which you can often choose not to display) on your profile page or next to your posted content.
• Aggregate Reporting: To learn more about the demographic information of our users in an aggregated, non-identifiable format.

We will not share any information about you collected on the Services with a linked SSO Service without your explicit approval. This means we will not post anything to your Google account or similar unless you give us specific permission. Please be aware that the privacy policies and terms of use of linked SSO Services may differ from ours, and we encourage you to review them. Additionally, familiarize yourself with the privacy controls and account settings of these services to understand how to customize your privacy preferences.

C. Other Disclosures

• Legal Compliance and Protection: We may disclose Personal Information if required to do so by law, in response to a subpoena, court order, or other legal process, or if we believe in good faith that such action is necessary to protect the rights, privacy, safety or property of A-HTS®, you or others. This also includes for assistance in fraud detection and prevention, or in emergencies.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a substantial portion of our business, assets, or stock, user information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your Personal Information.
• Aggregated or De-identified Data: We may share aggregated or de-identified information that cannot reasonably be used to identify any individual. This data may be used for research, analytics, or statistical purposes to improve our services and understand educational trends.

D. International Data Transfers

Personal Information about you may be transferred, stored, and processed by us or the third-parties we work with in countries whose data protection laws and regulations may be different to those of your country (e.g., the United States where A-HTS® is headquartered). It is our policy to ensure that adequate contractual or other safeguards are applied to Personal Information transferred outside of the EEA+ where required by the GDPR. If you have questions about the safeguards applied to your Personal Information, you may contact us at the details provided in Section 16.

6. Children’s Privacy and COPPA Compliance

At-Home Tutoring Services® is fully committed to protecting the online privacy of Children, especially those under the age of 13. We strictly comply with the Children’s Online Privacy Protection Act (COPPA).

• Verifiable Parental Consent: We do not knowingly collect Personal Information online from Children under 13 without obtaining verifiable parental or guardian consent, unless otherwise permitted by COPPA for specific educational contexts.
• Minimal Data Collection: We collect only the minimal amount of Personal Information from Children necessary to deliver our educational services, as outlined in COPPA guidelines.
• Parental Rights: Parents and legal guardians have the right to review their child’s Personal Information, request its deletion, or refuse to permit its further collection or use. Please contact us using the information in Section 16 to exercise these rights.
• A-HTS® does not permit behavioral profiling, targeted advertising, or tracking of minors by itself or any third parties.

7. FERPA and Educational Privacy

While At-Home Tutoring Services® is not a school, we recognize the importance of safeguarding educational records. Therefore, we voluntarily adhere to the principles and guidelines of the Family Educational Rights and Privacy Act (FERPA) concerning the handling of student educational information.

• We ensure that educational records are handled confidentially and shared only with authorized parties directly involved in the student’s education, such as our tutors, parents/guardians, and specifically contracted schools.
• Parents and eligible students have rights under FERPA to inspect and review educational records maintained by A-HTS® and to request amendments if they believe the records are inaccurate or misleading.

8. AI and Automated Processing

At-Home Tutoring Services® may utilize artificial intelligence (AI) tools to enhance and streamline our services. These tools may assist in processes such as tutor matching, analyzing learning patterns, and tracking student progress more efficiently. It is crucial to understand that while AI tools may provide valuable insights and support, any decisions significantly affecting a student’s learning or educational path are always reviewed and guided by qualified human educators. AI is used as an assistive technology, not as a replacement for human judgment and interaction. AI may also be used for content moderation (if applicable to user-generated content) to ensure compliance with our community guidelines. We do not use automated decision-making that produces legal or similarly significant effects on users.

9. Cookie Policy

This section provides more detailed information about how At-Home Tutoring Services® uses cookies and similar tracking technologies on our website and through our services.

• What are Cookies? Cookies are small text files stored on a user’s device (computer, tablet, or mobile) by a website. They help websites remember information about the user, such as preferences or login status, for future visits.
• How We Use Cookies: We use cookies for:
  • Essential Website Functionality: These cookies are necessary for the website to function properly, enabling core features like secure login, session management, and remembering your preferences.
  • Analytics: We use analytics tools, primarily Google Analytics, to understand how users interact with our website. This helps us to improve website performance, identify popular content, and understand user navigation patterns. The data collected is typically aggregated and does not directly identify you.
  • Communication Tracking: We use HubSpot for customer relationship management and communication tracking, which may involve cookies to track interactions with our communications (e.g., whether an email was opened or a link clicked) to better serve your needs.
• Your Control Over Cookies: Most web browsers allow you to control cookie preferences through their settings. You can typically set your browser to refuse all cookies or to indicate when a cookie is being sent. However, please note that disabling essential cookies may impact the functionality and performance of our Services. We may also provide a “Cookie Settings” link on our website footer or within our Services to allow you to manage your preferences for non-essential cookies.
• Meta Pixel & Custom Audiences: We use the Meta Pixel and Meta’s Conversions API to track website activity and measure ad effectiveness. We may also upload “hashed” versions of your email address to Meta to create Custom Audiences. This process converts your email into a unique code that cannot be read by humans, allowing Meta to show you our ads only if you already have an account with them. You can opt-out of this by adjusting your Facebook Ad Preferences.

10. Data Security

The security of your Personal Information is a top priority for At-Home Tutoring Services®. We implement robust technical, administrative, and physical safeguards to protect your data against unauthorized access, disclosure, alteration, and destruction.

Our security measures include:

• Encryption: We implement safeguards such as encryption (e.g., SSL/TLS for data in transit) to protect data against unauthorized access.
• Secure Logins: User accounts are protected with secure authentication methods.
• Restricted Access: Access to Personal Data is limited to authorized personnel who have a legitimate need to access it for their job functions.
• Employee Training: We implement safeguards such as employee training on data privacy and security best practices to ensure they understand their responsibilities in handling Personal Information.
• Regular Audits: We conduct periodic reviews and assessments of our security practices to identify and address potential vulnerabilities. A-HTS® conducts regular Data Protection Impact Assessments (DPIA) to ensure that privacy risks are identified and mitigated, especially for student data.

At At-Home Tutoring Services®, we implement reasonable administrative, organizational, technical, and physical safeguards to protect your Personal Information from unauthorized access, loss, misuse, alteration, or disclosure. Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. As such, we cannot guarantee absolute security.

In the event of a data breach that compromises your Personal Information, we follow a Data Incident Response Plan designed to mitigate harm and comply with applicable laws.

• For residents of the United States, including Texas: We will notify affected individuals without unreasonable delay, consistent with the Texas Identity Theft Enforcement and Protection Act (Texas Business & Commerce Code § 521.053) and any other applicable laws. Where the breach affects more than 250 Texas residents, we will also notify the Texas Attorney General within 30 days of discovery.
• For individuals located in the European Economic Area (EEA) or the United Kingdom (UK): If required under the GDPR or UK GDPR, we will notify the appropriate supervisory authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to your rights and freedoms.

If you have any questions about how we protect your data or how we respond to security incidents, please contact us at info@athometutoringservices.com

While we strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with Section 16. A-HTS® follows its Data Breach Incident Response Plan to respond to incidents that could compromise Personal Information.

11. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including providing our services, meeting our legal obligations, resolving disputes, and enforcing our agreements.

• Billing records are retained for a period of 7 years to comply with tax and financial regulations.
• Educational data (such as session records, diagnostic results, and progress reports) is generally retained through a student’s graduate school completion after the cessation of tutoring Services, unless an earlier deletion is requested by the parent or eligible student and is not prohibited by law.
• Other Personal Information is retained for varying periods based on its nature and purpose, always aligned with the principle of data minimization.

When Personal Information is expired, or is no longer needed and does not have to be retained, we may return, delete, destroy, or anonymize it, depending on what method is systematically and procedurally possible, most secure, and what our related retention commitments are.

12. User Rights and Choices

We respect your privacy rights and provide you with mechanisms to control your Personal Information. Applicable laws in some states in the United States and various countries and regions grant individuals certain rights. Regardless of the applicable law, A-HTS® offers all US residents and to the residents of other jurisdictions that use and participate in our Services the following options:

A. Your Data Choices

• Access Your Data: You have the right to request access to the Personal Data we hold about you. This includes the choice to request a report on what categories of Personal Information we have collected and processed about you.
• Request Corrections: You may request that we rectify inaccurate or incomplete Personal Information we hold about you.
• Request Deletion: You have the right to request the deletion of your Personal Data, subject to certain legal obligations or legitimate business needs that may require us to retain certain information. Note that if you choose to delete your Personal Information from our systems, this may also unsubscribe you from all A-HTS® Communications and delete other information such as your membership information or submitted content. Once we process a deletion request, we may be unable to provide access or support to our Services.
• Opt Out of Marketing Communications: You can opt out of receiving marketing communications from us at any time by following the unsubscribe instructions included in those communications or by contacting us directly as described in Section 12.A. Please note that you cannot opt out of service-related communications that are essential for the operation of your account.
• Cookie Preferences: As detailed in Section 9, you can manage your cookie preferences through your browser settings or via a “Cookie Settings” link on our website (if available). Your request to opt out will only apply to the browser and device from which you submit the request.
• No Opt-Out for Non-Existent Practices: As we do not sell Personal Information for profit and do not profile (as defined by applicable privacy laws) or undertake automated decision-making with legal or similar effects, we do not offer an option to opt-out of them.

These rights are not absolute, and in certain cases, we may decline your request as permitted by law. You are entitled to exercise the options described above free from discrimination. We typically do not charge any fees for exercising these choices; however, we may charge a reasonable fee for requests that are clearly unfounded, repetitive, or excessive.

B. Submitting a Request

To make submitting a request as easy as possible, we have provided the following methods:

• Email or Phone: You may contact us directly via email or phone using the contact information in Section 16.

C. Further Notes on Making Requests

• Identity Verification: When you or an authorized agent on your behalf make a request, we will confirm your identity. We may reach out to you for additional information to verify your identity beyond what is included in your initial request. Information collected to verify your identity will never be used for any other purpose than to verify your identity to fulfill your request.

13. International Users and GDPR Rights

If you are accessing our Services from the European Economic Area (EEA) or the UK (together, the EEA+), you have specific rights under the General Data Protection Regulation (GDPR) in addition to those listed in Section 12.

A. Your GDPR Rights

• Access: Request access to your Personal Information.
• Correction: Request correction of inaccurate or incomplete Personal Information that we hold about you.
• Erasure: Request erasure of your Personal Information.
• Objection: Object to our reliance on our Legitimate Interests (as described in Section 4) as the legal basis of processing of your Personal Information.
• Restriction: Request the restriction of processing of your Personal Information until we address your request, establish its accuracy or our reasons for processing it.
• Portability: Request the transfer of your Personal Information in a portable format to you or a third party of your choice.
• Withdraw Consent: Withdraw your consent to any Processing that relies on it as a legal basis.

B. Exercising Your GDPR Rights & Complaints

If you want to exercise any of these rights, you can do so by contacting us via email or phone as described in Section 16. We typically do not charge any fees for exercising these rights, but we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

• Right to Complain: If you feel we have not been able to satisfactorily resolve an issue, you may contact your local data protection supervisory authority. For contact information of Data Protection Authorities in the EEA+, please refer to official GDPR resources (e.g., European Data Protection Board website). For the UK, the Information Commissioner’s Office (ICO) is the relevant authority.

C. Our Representatives (for EEA+ Users)

For EEA+ Users, we have designated representatives to facilitate your GDPR inquiries.

• Our EU representative appointed under the EU GDPR is Sara Downey. She can be contacted by mail at: sara@athometutoringservices.com
• Our UK representative appointed under the UK GDPR is Sara Downey. She can be contacted by mail at: sara@athometutoringservices.com

Alternatively, you can always contact A-HTS® directly using the information in Section 16.

D. Purposes for Processing (for EEA+ Users)

Below, we set out the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Information. This section directly addresses our internal data mapping for GDPR compliance, detailing how we process Personal Information.