This Privacy Notice for REAL Center of Learning LLC (doing business as StudyHall) (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Download and use our mobile application (StudyHall), or any other application of ours that links to this Privacy Notice
• Use Private Tutoring. Studyhall is a mobile-based tutoring coordination platform that connects students and parents with independent tutors for scheduled, in-person academic support sessions at approved physical locations. Studyhall operates as a marketplace that facilitates: Tutor discovery and booking, session scheduling, payment processing, background screening of tutors, attendance verification via QR confirmation, and communication between users.

Studyhall does not provide tutoring services directly. Tutoring services are delivered by independent tutors who contract directly with students and parents through the platform. Sessions arranged through Studyhall occur at third-party physical locations, including but not limited to libraries, cafés, and community spaces.

Studyhall’s role is limited to: Providing the technology platform, processing payments through third-party payment processors, facilitating background checks through third-party screening providers, and enforcing platform policies and standards.

Studyhall does not: Employ tutors, supervise tutoring sessions, guarantee academic results, or guarantee safety beyond reasonable screening measures. Parents and guardians are responsible for supervising and making appropriate decisions regarding tutoring services for minors.

• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@joinstudyhall.org.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by visiting privacy@joinstudyhall.org, or by contacting us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. PLATFORM ROLE AND SERVICE STRUCTURE
13. INDEPENDENT TUTORS AND BACKGROUND SCREENING
14. IN-PERSON SESSIONS AND THIRD-PARTY LOCATIONS
15. CHILDREN’S DATA AND PARENTAL RESPONSIBILITY
16. PAYMENT PROCESSING AND FINANCIAL DATA
17. DATA RETENTION AND LEGAL COMPLIANCE
18. NO SALE OF PERSONAL INFORMATION
19. FUTURE PLATFORM CHANGES
20. DO WE MAKE UPDATES TO THIS NOTICE?
21. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
22. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• parent name
• minor name
• grade level
• mailing addresses
• billing addresses
• payment information via Stripe
• communication messages, including in-app chat
• session history
• profile photo
• emergency contact
• date of birth
• government ID, if required by Stripe
• bank account information via Stripe Connect
• resume / education information
• certification documents
• background check authorization information
• IP address
• device information
• usage data
• cookies, if website

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• social security numbers or other government identifiers
• driver’s license number
• government-issued ID
• payment card details
• bank account information
• criminal background screening
• screening results
• authorization consent

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice here: https://stripe.com/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Data. We automatically collect device information such as your mobile device ID, model, manufacturer, operating system, version information, browser type and version, hardware model, Internet service provider, mobile carrier, IP address, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). You may opt out in your device settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for internal analytics and reporting purposes.

Information automatically collected

In Short: Some information — such as your Internet Protocol address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, usage information, and other technical information.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://joinstudyhall.org/privacy-policy.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information automatically collected by our servers.
• Device Data. Information about your computer, phone, tablet, or other device used to access the Services.
• Location Data. Information about your device’s location, which can be precise or imprecise.
• Booking & Session Metadata. System-generated information related to tutoring sessions, including booking timestamps, modification history, cancellation records, QR check-in and check-out times, and session completion status.
• Payment & Transaction Metadata. Information related to payment processing, including authorization timestamps, capture timestamps, transaction status, payout records, and service fee calculations.
• Background Check Status Data. System-generated information related to tutor screening, including background check initiation date, screening status, expiration date, and renewal records.
• Communication Metadata. Information related to in-app communications, including message timestamps, sender and recipient identifiers, and conversation status.
• Security & Fraud Prevention Data. Information generated for security purposes, including failed login attempts, account lock events, session activity logs, and suspicious behavior flags.

Google API. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In Short: We may receive limited information from third-party service providers necessary to operate the platform, including payment processors and background screening providers. We do not purchase consumer data from data brokers or marketing data providers.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries and offer support to users.
• To send administrative information to you.
• To enable user-to-user communications.
• To send you marketing and promotional communications.
• To protect our Services.
• To evaluate and improve our Services, products, marketing, and your experience.
• To comply with our legal obligations.
• To verify tutor identity, qualifications, and background screening compliance.
• To enforce platform eligibility standards, safety requirements, and community guidelines.
• To process payments, release funds to tutors, calculate service fees, and facilitate payout distributions through third-party payment processors.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.

The third parties we may share personal information with are as follows:

• Stripe, Inc. — Payment Processing
• Checkr, Inc. — Background Screening
• Microsoft Corporation — Email & business services
• Cloud hosting provider, such as AWS, Firebase, etc.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition.
• Other Users. When you share personal information or interact with public areas of the Services, such information may be viewed by other users.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies like web beacons and pixels to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We may use cookies and similar technologies for analytics, performance monitoring, and essential functionality. We do not use third-party advertising networks, targeted advertising cookies, or behavioral advertising technologies on the Studyhall platform.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://joinstudyhall.org/privacy-policy.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details. Where you choose to do this, we will receive certain profile information about you from your social media provider.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than twenty four (24) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or securely store it until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: Studyhall serves K–12 students. Accounts for minors must be created and managed by a parent or legal guardian.

We do not knowingly collect personal information directly from children under 13 without verifiable parental consent. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@joinstudyhall.org.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided below.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in our emails or by contacting us.

Account Information: If you would like to review, change, or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, although we may retain some information where required for fraud prevention, troubleshooting, investigations, legal compliance, or enforcement of our legal terms.

If you have questions or comments about your privacy rights, you may email us at privacy@joinstudyhall.org.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect

• A. Identifiers: YES
• B. Personal information as defined in the California Customer Records statute: YES
• C. Protected classification characteristics under state or federal law: NO
• D. Commercial information: YES
• E. Biometric information: NO
• F. Internet or other similar network activity: YES
• G. Geolocation data: YES
• H. Audio, electronic, sensory, or similar information: NO
• I. Professional or employment-related information: YES
• J. Education Information: YES
• K. Inferences drawn from collected personal information: NO
• L. Sensitive personal Information: YES

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories when you interact with us in person, online, by phone, or by mail, including through customer support, surveys, contests, and facilitation of the Services.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information

Your Rights

You have rights under certain US state data protection laws. These rights may include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of your personal data
• Right to non-discrimination for exercising your rights
• Right to opt out of targeted advertising, sale of personal data, or profiling
• Right to limit use and disclosure of sensitive personal data, where applicable

How to Exercise Your Rights: To exercise these rights, you can contact us by emailing privacy@joinstudyhall.org.

Request Verification: Upon receiving your request, we will need to verify your identity. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals: Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing privacy@joinstudyhall.org.

12. PLATFORM ROLE AND SERVICE STRUCTURE

Studyhall is a technology platform operated by REAL Center of Learning LLC that facilitates connections between students, parents, and independent tutors for in-person academic sessions. Studyhall does not provide tutoring services directly.

Tutoring services are provided by independent tutors who are not employees, agents, or representatives of Studyhall. Studyhall’s role is limited to providing the platform infrastructure, facilitating bookings, processing payments through third-party providers, conducting background screening through third-party providers, and enforcing platform policies.

13. INDEPENDENT TUTORS AND BACKGROUND SCREENING

Tutors using Studyhall may be subject to identity verification and background screening through third-party service providers. Background screening is conducted to support platform safety. However:

• Screening is limited to the scope of the third-party provider’s report.
• Screening does not guarantee the safety, suitability, or conduct of any tutor.
• Studyhall does not independently verify the accuracy of third-party screening reports beyond status confirmation.
• Parents and guardians remain responsible for evaluating tutor suitability for their child.

14. IN-PERSON SESSIONS AND THIRD-PARTY LOCATIONS

Tutoring sessions arranged through Studyhall occur at third-party physical locations, including but not limited to libraries, cafés, and community spaces. Studyhall does not own, control, or supervise these locations.

Studyhall is not responsible for:

• The condition or safety of third-party locations
• Conduct occurring outside the scope of platform policies
• Actions taken by independent tutors or users during in-person sessions

Users acknowledge that in-person interactions carry inherent risks.

15. CHILDREN’S DATA AND PARENTAL RESPONSIBILITY

Studyhall serves K–12 students. Accounts for minors must be created and managed by a parent or legal guardian.

Parents and guardians are responsible for:

• Monitoring their child’s use of the platform
• Supervising participation in tutoring sessions
• Evaluating the suitability of independent tutors

Studyhall does not knowingly collect personal information directly from children under 13 without parental consent. Studyhall does not independently supervise or monitor in-person tutoring sessions and does not assume responsibility for on-site oversight of interactions between tutors and students.

16. PAYMENT PROCESSING AND FINANCIAL DATA

Payments and payouts are processed through third-party payment processors, including Stripe. Studyhall does not store full payment card numbers. Financial data is handled in accordance with the payment processor’s security standards.

Studyhall retains transaction metadata for compliance, accounting, dispute resolution, and fraud prevention purposes.

17. DATA RETENTION AND LEGAL COMPLIANCE

Studyhall retains personal information for operational purposes and for up to 24 months following account termination, unless a longer retention period is required by law.

We may retain certain information beyond this period for:

• Compliance with legal obligations
• Fraud prevention
• Dispute resolution
• Enforcement of platform policies

18. NO SALE OF PERSONAL INFORMATION

Studyhall does not sell personal information. Personal information is disclosed only to service providers necessary to operate the platform, including payment processors, background screening providers, and hosting providers.

Studyhall does not engage in behavioral advertising or cross-site tracking for commercial profiling purposes.

19. FUTURE PLATFORM CHANGES

As Studyhall evolves, additional features or integrations may be introduced. In the event that new categories of data are collected or new third-party processors are added, this Privacy Policy will be updated accordingly.

Users are encouraged to review this Privacy Policy periodically for updates.

20. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice.

If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

21. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@joinstudyhall.org or contact us by post at:

REAL Center of Learning LLC
1106 N 20th Street
Richmond, VA 23223
United States

22. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please contact: privacy@joinstudyhall.org.