Privacy Policy

Effective Date:

This Privacy Policy outlines Suhbah School’s practices regarding the collection, use, disclosure, and protection of your personal information. It applies to all users of Suhbah School’s online platform, including parents, learners, and educators (collectively, “Users,” “you,” or “your”). Suhbah School is committed to safeguarding user privacy and ensuring transparency in its data handling practices.

1. INTRODUCTION AND REGULATORY COMPLIANCE

Suhbah School operates with a steadfast commitment to regulatory compliance, particularly concerning the sensitive nature of educational data and children’s online privacy. We adhere to the Children’s Online Privacy Protection Act (COPPA), a federal law designed to protect the online privacy of children under 13.[4, 26, 27] Compliance with COPPA requires obtaining verifiable parental consent before collecting, using, or disclosing personal information from children.[4, 27]

Furthermore, Suhbah School is committed to complying with the Family Educational Rights and Privacy Act (FERPA), which protects the privacy of student education records.[4, 28] FERPA grants parents and eligible students certain rights regarding their educational records, including the right to inspect and review them, request corrections, and provide consent before disclosure of personally identifiable information (PII).[28]

In addition to federal mandates, Suhbah School operates in accordance with Texas-specific data privacy laws, including provisions under the Texas Business and Commerce Code, such as Chapter 541 (regulation of consumer personal data) and Chapter 521 (identity theft), and Texas Penal Code Section 32.51 (penalties for misuse of personally identifying information).[29, 30] This Privacy Policy incorporates by reference these applicable country, state, and other privacy laws, ensuring that any conflict between this Privacy Policy and required elements of these regulations will favor the stricter legal requirements.[4]

2. CHILDREN’S PERSONAL INFORMATION

Suhbah School places paramount importance on the protection of children’s personal information, particularly for learners typically under 13 years of age. Our practices are designed to be fully compliant with COPPA and other applicable global regulations concerning children’s data privacy.[4]

2.1. Limited Features for Children. For users identified as children, Suhbah School implements limited features to block or restrict data collection or sharing and to prevent direct interaction with adults outside of supervised class settings.[4]

2.2. Verifiable Parental Consent. A cornerstone of our compliance is the requirement for verifiable parental consent before collecting, using, or disclosing any personal information from children. This consent is typically verified through robust authentication methods, which may include credit card verification, to ensure the consenting individual is indeed the parent or legal guardian.[4, 27] Parents have the option to consent to the internal collection and use of their children’s personal information while prohibiting its disclosure to third parties, unless such disclosure is reasonably necessary and integral to the provision of the Services.[4]

2.3. Parental Rights. Parents or legal guardians of children with registered accounts have comprehensive rights regarding their child’s data. They can manage their child’s access to the platform, review or request corrections to their child’s personal information, and discontinue further collection, use, or disclosure of their child’s personal information at any time.[4] Requests for deletion of a child’s information can be submitted through specified channels, and Suhbah School may ask further questions or take additional steps to verify parental identity before responding to such requests.[4]

2.4. Data Minimization and Retention for Children’s Data. Personal information collected from children is retained only for as long as is necessary to fulfill the purpose for which it was collected, and it is then deleted using reasonable measures to protect against unauthorized access or use.[4, 27] Any information collected in violation of applicable laws is promptly deleted.

2.5. FERPA Compliance. Suhbah School ensures that student education records are handled securely. This involves notifying parents and eligible students annually of their rights under FERPA, obtaining written consent before disclosing personally identifiable information from education records (except in authorized situations), and implementing safeguards to prevent unauthorized access to sensitive student data.[1, 28] For instance, if class recordings include identifiable student information, consent is obtained, or the recordings are edited to de-identify students who have not provided consent.[31] Suhbah School will also implement measures such as encrypted databases, secure logins, multi-factor authentication, and regular system updates to protect digital student records.[28]

3. INFORMATION COLLECTION (TYPES AND METHODS)

Suhbah School collects various categories of information to operate, manage, and improve its Services. This collection occurs through information you provide directly, information collected automatically through platform use, and information obtained from other sources.

3.1. Information You Provide:

• Account Data: When you create an account, we collect credentials (usernames, passwords, security information) and profile information such as name, email address, phone number, and postal address. Learners may submit video for verification purposes, and live classes are recorded, often requiring cameras for safety and participation.[4]

• Content Data: Information related to your engagement in Services, shared content (e.g., uploaded drawings, photos, video, audio), activity history within the platform, feedback, and class/educator reviews are collected.[4]

• Demographic Data: Optional surveys or quizzes may collect demographic information such as age, birth date, gender, pronouns, household income, and country.[4]

• Payment Data: For purchases, third-party payment processors (e.g., Stripe, PayPal) collect data necessary to process payments, including name, payment instrument details, billing address, and transaction information. Suhbah School does not store or process sensitive payment card data directly. For payments made to you (e.g., educators), financial account information and payment details are collected.[4]

• Referral and Promotion Data: Information related to referral programs (e.g., codes provided) and participation in sweepstakes or contests (e.g., email, screen name, home address for prizes, SSN/TIN for tax reporting if required) is collected.[4]

• Customer Support Data: Information provided during customer support interactions, such as name, phone, address, and email, is collected for assistance, identity confirmation, and training purposes.[4]

• Sensitive Data: You may voluntarily provide sensitive information (e.g., racial/ethnic origin, financial, health, or disability information). This data is handled with extreme care, processed only when necessary with explicit consent, or as required by law. Educators and learners are generally prohibited from discussing sensitive personal information.[4]

• Fraud Prevention Data: In cases of suspected age or identity misrepresentation, proof of age/identity (e.g., video clip, birth certificate, passport) may be requested, with only necessary information (e.g., date of birth) retained.[4]

• Background Check Information: For educators and potential employees, background check information, including criminal history, professional qualifications, and work history, is collected with separate notices and consent forms.[4]

3.2. Information Collected Automatically (Tracking Technologies):

Suhbah School utilizes various technologies to collect data automatically to enhance user experience and analyze platform usage:

• Service Use Data: Information about features used, products viewed or purchased, browsing time, interactions with Services, search terms, clicks, error messages, and web pages visited is collected.[4]

• Device, Connectivity, and Configuration Data: This includes device and browser type, IP-derived location, operating software, regional and language settings, push notification settings, and mobile device identifiers.[4]

• Video Data: Camera activation is required for live classes and activities for participation and learner safety (e.g., verifying the person in class is a child). Access may be denied if video is refused. This data is used for Service provision, customer support, platform improvement, fraud prevention, and legal obligations, but not for other purposes or shared outside Services unless instructed by you or legally required.[4]

• Tracking Technologies:

  • Log Files: Record website activity and gather statistics about browsing habits, helping to determine user visit frequency and page views for internal marketing and demographic studies.[4]

  • Cookies/Browser Cookies: Placed on devices to enhance user experience and understand interaction with the platform. Suhbah School does not knowingly track children or collect data from third-party ad trackers on learners.[4]

  • Session Recordings: Capture interactions (taps, scrolling, clicks, mouse movements, keystrokes) to understand navigation patterns and improve user experience.[4]

  • Clear GIFs (Pixel Tags/Web Beacons): Small graphic files on web pages, ads, or emails used to count visitors and understand navigation.[4]

  • Location-Identifying Technologies: GPS, WiFi, and Bluetooth may be used for device location to deliver or restrict content.[4]

  • Voice Processing Technologies: Audio may be collected with consent to effectuate instructions, immediately deleted afterward. Non-audio data may be used for analytics.[4]

  • App-Specific Technologies: SDKs and APIs in mobile applications (e.g., mobile Ad ID) are utilized.[4]

3.3. Information from Other Sources:

• Information from Partners: Organizations such as schools, non-profits, or employers may provide user information for participation in Suhbah School’s Services. You are encouraged to review the privacy notices of such partners.[4]

• Information from Vendors: Data may be purchased or leased from third-party vendors, generally through advertising services, with reliance on vendors to legally obtain such data. This information may be shared with vendors for purposes like mailing lists.[4]

• Information from Other Third Parties: Information may be obtained from linked accounts (e.g., Facebook, Apple, Google) if used for login. You should check the privacy notices of these providers. Information may also be obtained from third-party tools used in classes or activities.[4]

• Information We Create or Generate (Inferences): New information, such as likely interests, preferences, or general geographic location (inferred from IP address), may be generated from collected data and combined with other sources to create a comprehensive user view.[4]

4. HOW WE USE YOUR INFORMATION

Suhbah School utilizes the collected information for a variety of purposes essential to operating, managing, and improving its Services, while upholding user privacy. The primary uses include:

• Operating and Providing Services: Delivering the core functionalities of the platform, enabling access to classes, and facilitating interactions between learners, parents, and educators.

• Customer Support: Performing requested services, responding to inquiries, and providing effective customer assistance.

• Security and Fraud Prevention: Processing data to send technical notices, updates, and security alerts. It is also critical for preventing and addressing fraud, policy breaches, and any activities that could cause harm to users or the platform.[4]

• Monitoring and Analytics: Helping in monitoring and analyzing trends, usage patterns, and activities to understand how Services are used and to continually improve the platform’s offerings.

• Fulfilling Purchases and Payments: Processing transactions, managing subscriptions, and facilitating payments to educators.

• Internal Research and Marketing: Supporting internal research and demographic studies aimed at enhancing service delivery and tailoring marketing efforts.

• Tailored Advertisements: Providing more relevant advertisements, aligning with user interests and preferences.[4, 32]

• Promotional Activities: Verifying eligibility and delivering prizes for sweepstakes or contests.

• Legal and Business Compliance: Processing data to fulfill other business or commercial purposes with user consent, or as required by law.

Suhbah School may also use publicly available or de-identified/aggregated information for any purpose permitted by law, as such data does not identify individuals.

5. HOW WE SHARE YOUR INFORMATION

Suhbah School shares information with various entities as necessary to provide its Services, comply with legal obligations, and for other legitimate business purposes, always striving to protect user privacy.

• Educators: When parents sign up for Services, they agree that educators may receive certain personal data about parents and their learners, including account data, content data, and automatically collected information. Educators are independent contractors and are required to adhere to specific data handling requirements. In cases where classes are taught by an organization or team of instructors, class recordings may be accessed by the entire organization, and access is not necessarily limited to a single individual educator.[4]

• Other Customers: Members of a class or activity can see, hear, and read interactions with other members, unless engaging in private messaging with an educator. This may include other parents, learners, and necessary individuals (e.g., interpreters) required for participation. However, Suhbah School prohibits non-approved individuals from engaging with learners or other customers on the platform.[4]

• Educators Using Third-Party Sites or Tools: Suhbah School requests that educators only use or share tools and third-party sites that are COPPA-compliant. However, educators may sometimes use tools not reviewed by Suhbah School. Parents are encouraged to review the sites or tools educators list for specific classes and can either agree to their use or notify Suhbah School or the educator of their disagreement.[4]

• Partners: Information about learner engagement is shared with organizations (e.g., schools, non-profits, employers) that provide opportunities or funding. Information is also disclosed for co-branded services, sales, or joint marketing activities, including contact data, credentials, and profile data.[4]

• Service Providers: Information is disclosed to entities that process data on Suhbah School’s behalf, such as platform hosting providers, community operations support, video hosting services, data analytics providers, technical support, and payment processors. These service providers are contractually prohibited from using the information for purposes other than those specified by Suhbah School and are required to maintain confidentiality. Aggregate or de-identified information may also be used by service providers.[4]

• Vendors: Information is disclosed to vendors, including data analytics, marketing, advertising, and promotional technology companies. Vendors may act as service providers or independently process information, and they are required to adhere to privacy standards at least as protective as Suhbah School’s.[4]

• Information Disclosures Requested by You: You may voluntarily transmit information to third parties or request Suhbah School to do so (e.g., messaging others, uploading to a profile, disclosing to educators/participants, participating in public forums). You are expected to respect the privacy of others in these interactions.[4]

• General Disclosures:

  • Merger or Acquisition: Personal information may be disclosed to successors, assigns, or third parties during actual or proposed mergers, acquisitions, reorganizations, or bankruptcies.[4]

  • Security and Compelled Disclosure: Information may be disclosed to comply with legal obligations, legal processes, public authority requests (e.g., security, law enforcement), or in connection with investigations of illegal activity, policy violations, or to protect the rights, property, or safety of Suhbah School, its users, or the public.[4]

  • Consent: Information may be disclosed for any other business or commercial purpose with explicit notice and consent from you.[4]

  • Aggregated or de-identified information may be disclosed with third parties for any purpose permitted by law.[4]

6. DATA RETENTION

Suhbah School retains personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. This includes retaining data to comply with legal obligations, resolve disputes, conduct regulatory investigations, or enforce agreements and policies.[4] For instance, class recordings are typically stored for 90 days, with exceptions for legal requirements.[3] Usage information is generally retained for shorter periods unless it is required for security purposes, functionality improvement, or legally mandated for a longer duration.[4] Suhbah School employs reasonable measures to protect against unauthorized access or use of information once it is no longer needed.

7. YOUR PRIVACY RIGHTS AND CHOICES

Suhbah School respects user privacy rights, which may vary based on your jurisdiction. You may have specific rights, including:

• Confirmation of Processing: The right to request confirmation that your personal data is being processed.

• Access and Copies: The right to request copies of your personal data.

• Updates and Corrections: The right to request updates or corrections to inaccurate or incomplete personal information.

• Deletion: The right to request the deletion of your personal information, subject to certain exemptions.[30]

• Restriction of Use: The right to request restriction of the use of your personal information.

• Objection to Processing: The right to object to the processing of your personal information, particularly for direct marketing purposes.[30]

• Withdrawal of Consent: The right to withdraw consent previously given for data processing.

• Lodging Complaints: The right to lodge complaints with data protection authorities.

For Texas residents, specific rights under Texas Privacy Laws include the ability to submit a State Privacy Act Report containing collected personal information, the right to opt-out of the “sale” or “sharing” of personal information for targeted advertising or profiling, and the right to be free from discrimination for exercising these rights.[30] While Suhbah School does not sell personal information to third parties as a data broker, certain data sharing with third parties for service improvement and relevant advertising may be considered a “sale” or “sharing” under California and other state privacy laws.[32] You can opt-out of such data sharing through your account settings or by utilizing opt-out preference signals supported by your device or browser.[30, 32]

Requests to exercise these rights can typically be submitted via an online Data Subject Request Portal, with identity verification required to protect user data.[4] Registered account holders can also review and update their personal information directly through their account settings.[4] Parents or legal guardians can request the deletion of their child’s information, understanding that deleting an an account may affect all associated learners.[4] While users own their personal information and created content, they grant Suhbah School a limited license to use it as outlined in this policy and the Terms of Service.[4]

8. DATA SECURITY MEASURES

Suhbah School is committed to protecting personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. The platform implements industry-standard security measures, including administrative, technical, and physical safeguards. These measures encompass using encrypted databases for storing sensitive information, requiring secure logins and multi-factor authentication (MFA) for accessing student records, and regularly updating software and systems to address vulnerabilities.[1, 4, 28]

Despite these robust security efforts, it is important to acknowledge that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, Suhbah School cannot guarantee absolute security of user data. You also bear responsibility for protecting your account credentials, including not sharing passwords and safeguarding your username and password information.[4] You are encouraged to manage your profile settings to control account access and enhance your personal security.

9. INTERNATIONAL DATA TRANSFERS

Suhbah School is based in the United States, and its Services are provided globally. Personal information collected through the Services may be transferred to, processed in, and stored in the United States and other jurisdictions where Suhbah School or its service providers operate. Suhbah School’s service providers are primarily located in the US, Canada, Australia, New Zealand, and the UK. Third-party analytics and advertising vendors may also be located in these countries, as well as potentially local vendors in regions such as the EU, UK, South Korea, and Japan. Support services are also provided from locations like Kenya, Africa.[4]

By using the Services, you consent to the transfer, processing, usage, sharing, and storage of your information in the United States and other jurisdictions that may have different data protection laws than your country of residence.[4] For data collected from individuals in the European Economic Area (EEA), UK, or Switzerland, Suhbah School ensures that such transfers are subject to appropriate safeguards, such as the implementation of Standard Contractual Clauses, to maintain data protection standards.[4]

10. CHANGES TO THIS PRIVACY POLICY AND CONTACT INFORMATION

Suhbah School reserves the right to update and amend this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised policy on the Suhbah School website. Your continued use of the Services after such changes constitutes your acceptance of the updated Privacy Policy. For material changes, Suhbah School will provide prominent notice or obtain consent if required by applicable law.[4] You are encouraged to review this Privacy Policy periodically to stay informed about how Suhbah School collects, uses, and protects your information.

For any questions, comments, or concerns regarding this Privacy Policy or Suhbah School’s data practices, you may contact Suhbah School through the following channels:

Suhbah School, LLC

Email: Admin@Suhbahschool.com