Peregrine Privacy Policy

PEREGRINE LEARNING LLC Privacy Policy Peregrine Tutoring Marketplace 1. Information We Collect • Account information: name, email address, and optional phone number. • Learner information: name and, where applicable, grade level; a hashed PIN used for Student Mode access. • Payment information: processed directly by our payment processor, Stripe; we do not store full payment card numbers. • Identity verification data: processed directly by our verification provider; we retain only verification status, not underlying identity documents. • Background screening data: processed directly by our screening provider; we retain only screening status, not the underlying consumer report or Social Security number. • Application certifications: a tutor's certification that they hold any business license, business tax registration, or professional license, permit, certification, or registration that their local jurisdiction or the State requires for independent tutoring work, and their description of their current or prior independent tutoring or teaching business. • Background screening records: in addition to screening status, we retain identifiers such as report and adverse-action reference numbers, a record of which findings formed the basis of any adverse decision, and timestamps related to required notice and waiting periods — but not the underlying consumer report, Social Security number, or date of birth. • Session and academic information: bookings, assignments, grades, and mastery tracking data. • Communications: in-platform messages between tutors and families, support inquiries, and reviews. • For independent learners: a date of birth, collected to confirm eligibility for an independent account. • Device and usage information: browser type, device type, and pages visited, used to operate and secure the Platform. We do not use advertising cookies, and we do not allow third-party advertising cookies on the Platform. • Information from Students in Student Mode: assignment submissions, files a Student uploads, session reactions, classroom messages, progress and mastery data, and the Student's image and voice while a live video session is in progress. We transmit that audio and video to the other session participants through the video provider; we do not record or store the session. 2. Third-Party Service Providers We share limited information with the following service providers solely to operate the Platform: our payment processor, our identity verification provider, our background screening provider, our database and hosting provider, our transactional email provider, and Google, for calendar and video-conferencing integration where a tutor elects to connect their Google Calendar. We do not sell personal information to third parties. If a tutor connects their Google Calendar, we request limited access solely to create a calendar event and a unique video-meeting link for each paid tutoring session on that tutor's calendar. This access is used only for that purpose; it is not used for advertising, and Google user data obtained through this connection is not sold. A tutor may disconnect this integration at any time, which stops the creation of future events. Live Sessions. Tutoring sessions are held by live video, typically through a Google Meet link created on the tutor's connected Google Calendar, or through another video link the tutor provides. Google (or that other video provider) processes participants' audio and video to deliver the live meeting. Peregrine does not record sessions. Tutors. A tutor booked with a Student can see that Student's name, grade level where provided, the booked subject, assignment submissions and uploaded files for that tutoring relationship, classroom messages, session reactions, and progress data used to teach the Student. A tutor does not receive the parent's payment-card details, the Student's login credentials, or other tutors' background-screening information. Legal and Safety Disclosures. We may disclose information to law enforcement, child-protective services, or the National Center for Missing & Exploited Children when we believe in good faith that disclosure is required by law or reasonably necessary to protect a child, including to report apparent child sexual abuse material. Google API Services. Peregrine's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. 3. How We Use Information We use the information described above to operate and improve the Platform, process payments, verify tutor eligibility, communicate with users, and comply with applicable legal obligations, including those relating to child safety. We never use this information for third-party advertising. 4. Children's Privacy Students Under 13. Before a Student under thirteen (13) uses Student Mode, we provide the Student's parent or guardian direct notice of what information we collect from the Student and how we use it, and obtain verifiable parental consent before that Student's first session. A parent or guardian who pays for a session using a payment card, after receiving that notice, provides verifiable consent in this manner. We do not condition a Student's participation on disclosing more personal information than is reasonably necessary. Parent Rights. A parent or guardian may at any time review the information we have collected from their Student, direct us to delete it, and refuse further collection, by contacting us at the address in Section 9. A parent may exercise these rights for a Student without closing the parent's own account. 5. Data Retention and Deletion Users may request deletion of their account and associated data at any time by contacting support; deletion requests are reviewed and processed by our team rather than completed instantly. Certain records may be retained where required by law, including financial records and records relevant to a background-screening dispute. We keep information only as long as reasonably necessary for the purpose it was collected, as follows: Student information, until ninety (90) days after the parent closes the account or deletes the Student profile; tutor license and registration certifications, at least three (3) years; background screening records, five (5) years after a tutor leaves the Platform; financial records, seven (7) years; child-safety incident records, ten (10) years after the Student turns eighteen (18), or longer while a legal claim is pending; and content reported to the National Center for Missing & Exploited Children, at least one (1) year after the report, as federal law requires. We then delete or de-identify the information. 6. Data Security We employ industry-standard security measures, including encrypted storage of sensitive fields, role-based access controls, and multi-factor authentication for administrative access. We maintain a written information security program that covers Students' information and is reviewed at least annually. No system can guarantee absolute security. If a breach affects your personal information, we will notify you as required by law. 7. Your Rights Depending on your jurisdiction, you may have rights to access, correct, or delete your personal information. To exercise these rights, contact us using the information below. We will not discriminate against you for exercising these rights. We do not share personal information with third parties for their own direct marketing. We do not currently respond to browser "Do Not Track" signals. 8. Changes to This Policy We may update this Privacy Policy from time to time. We will post the updated policy with a new effective date and notify you by email before material changes take effect. We will obtain new parental consent before using a Student's information in a materially different way. 9. Contact Peregrine Learning LLC, michael@peregrine-learning.com, registered-agent address on file with the California Secretary of State. No telephone number is published; contact us by email.