Introduction of Privacy Protections

(a) GiftedApples Reading and Math Center LLC , 3724 Riedham Road, Shaker Heights, Ohio 44120-5215, is committed to protecting the privacy of Personal Information we collect and handle. This Privacy Policy explains how we handle Personal Information we collect from individuals from time to time.

(b) We are bound by the In the U.S., several federal laws protect the privacy of individuals with disabilities. The Americans with Disabilities Act (ADA) is a key piece of legislation that ensures equal opportunity and prohibits discrimination based on disability. Specifically, the ADA includes privacy safeguards for medical information obtained during disability-related inquiries, requiring employers to keep such information confidential and separate from other personnel files. Other relevant laws and regulations include Section 504 of the Rehabilitation Act and the Individuals with Disabilities Education Act (IDEA), which address discrimination in federally funded programs and education, respectively

(c) We may modify or amend this Privacy Policy as our organizational requirements or the law changes. We will display a notice on our website https:giftedapplesread.com (Website) indicating when any such revisions have been made. This Privacy Policy was last updated on 3, July 2025.

What is FERPA

The Family Educational Rights and Privacy Act (FERPA) is a federal law that affords parents the right to have access to their children’s education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records. When a student turns 18 years old, or enters a postsecondary institution at any age, the rights under FERPA transfer from the parents to the student (“eligible student”). The FERPA statute is found at 20 U.S.C. § 1232g and the FERPA regulations are found at 34 CFR Part 99.

Audience

Early Childhood Educators

Education Technology Vendors

Parents and Students

Researchers

K-12 School Officials

Postsecondary School Officials

2 Definitions of Privacy Protection

Definition of The Child Privacy Protection

In this policy the expressions “we“, “us” and “our” are a reference to GiftedApples Reading.  The expressions “you” and “your” refer to each individual whose Personal Information we may handle from time to time where we are required to comply with Privacy Laws in respect of such Personal Information of Children.

Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.

Privacy Policy protecting children In the U.S.

The primary federal law protecting children’s online privacy is the Children’s Online Privacy Protection Act (COPPA). COPPA applies to websites and online services directed at children under 13, as well as those that knowingly collect information from them. It requires parental consent for the collection of children’s personal information and outlines specific procedures for obtaining and verifying consent. 

Related Organization means any corporate body, trust, partnership or association that is a related body corporate of GiftedApples Reading, or is otherwise permitted to GiftedApples Reading and Math Center LLC and other registered names for our organization.

Sensitive Information means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices or criminal record that is also personal information, health information, genetic information, biometric information or biometric templates.

Spam Act means the Spam Act 2003 (Cth).

Parents and the Children are protected by FERPA

What is FERPA

The Family Educational Rights and Privacy Act (FERPA) is a federal law that affords parents the right to have access to their children’s education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records. When a student turns 18 years old, or enters a postsecondary institution at any age, the rights under FERPA transfer from the parents to the student (“eligible student”). The FERPA statute is found at 20 U.S.C. § 1232g and the FERPA regulations are found at 34 CFR Part 99.

Audience

Early Childhood Educators

Education Technology Vendors

Parents and Students

Researchers

K-12 School Officials

Key aspects of FERPA:

• Access to Education Records:

FERPA grants parents (or eligible students) the right to inspect and review their child’s education records. 

• Amendment of Records:

If a parent believes information in a student’s education record is inaccurate, misleading, or otherwise inappropriate, they have the right to request that the school amend the record. 

• Control over Disclosure:

Generally, schools cannot disclose personally identifiable information from a student’s education record without written consent. However, there are exceptions, such as disclosures to school officials with legitimate educational interests, or to comply with a subpoena. 

• Directory Information:

Schools can designate certain information as “directory information” (e.g., name, address, phone number, date and place of birth) and disclose it without consent, unless a parent has opted out. 

• Enforcement:

FERPA is enforced by the U.S. Department of Education’s Family Policy Compliance Office. 

In essence, FERPA aims to balance the need for educational institutions to maintain records with the right of individuals to control the privacy of their personal information. 

(a) We only collect Personal Information to the extent that this is reasonably necessary for one or more of our functions or activities.

(b) We may collect Personal Information from you when you:

(i) become a member or friend of GiftedApples Reading (make an Application);

(ii) make a donation to GiftedApples Reading and Math Center LLC;

(iii) apply to be included on, or make use of, the SPELD NSW referral database;

(iv) participate in an educational assessment;

(vi) buy teaching aids and resources from us; or

(vii) contact us by any method, such as telephone, email, post, facsimile, through our website or in person.

(c) The type of Personal Information we collect may include:

(i) details such as your name, phone number, address, email address, credit card number, expiry date and bank details (to the extent necessary to provide our services to you);

(ii) if you apply to be listed on our professional referral database, your professional qualifications, employment history and Working with Children Check number;

(iii) for the purpose of referring your child for psychological educational assessments or providing other our referral services, we may also collect Sensitive Information such as health records, psychological or other professional assessments, educational and employment history and details of an individual’s learning difficulties.

(d) When collecting Sensitive Information from you, we will obtain your consent, or the consent of a parent or guardian, to such collection, except where otherwise permitted under the Privacy Laws.

(e) As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. For example, we may collect reports from a child’s school, tutor or treating doctor where required for the purpose of assessing the child’s learning difficulties.  We will only collect information from a third party where it is unreasonable or impractical to collect that information from the individual directly.

Purpose of collection of your Personal Information

• We may use and disclose your Personal Information for the primary purpose for which we collected your Personal Information, for reasonably (or directly, if the Personal Information is Sensitive Information) related secondary purposes within your reasonable expectations and where required or authorized by law.
• (a) We only collect Personal Information to the extent that this is reasonably necessary for one or more of our functions or activities.

(b) We may collect Personal Information from you when you:

• (i) become a member or friend of GiftedApples Reading (make an Application);
• (ii) make a donation to GiftedApples Reading and Math Center LLC;
• (iii) apply to be included on, or make use of, the GiftedApples Reading referral database;
• (iv) participate in an educational assessment;
• (vi) buy teaching aids and resources from us; or
• (vii) contact us by any method, such as telephone, email, post, facsimile, through our website or in person.
• The type of Personal Information we collect may include:

details such as your name, phone number, address, email address, credit card number, expiry date and bank details (to the extent necessary to provide our services to you);

• If you apply to be listed on our professional referral database, your professional qualifications, employment history and Working with Children Check number;

or the purpose of referring your child for psychological educational assessments or providing other our referral services, we may also collect Sensitive Information such as health records, psychological or other professional assessments, educational and employment history and details of an individual’s learning difficulties.

• When collecting Sensitive Information from you, we will obtain your consent, or the consent of a parent or guardian, to such collection, except where otherwise permitted under the Privacy Laws.
• As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. For example, we may collect reports from a child’s school, tutor or treating doctor where required for the purpose of assessing the child’s learning difficulties.  We will only collect information from a third party where it is unreasonable or impractical to collect that information from the individual directly.
• The purposes for which we collect, use and disclose Personal Information include the following:
• (i) for the provision of our products and services or conduct of our business activities;

(ii) if you use our Website or Facebook page, to track your usage and to evaluate the performance of our Website;

(iii) to communicate with you, and provide you with information, in relation to the products and services we provide;

(iv) for dealing with related parties, including psychologists, treating doctors, tutors and teachers;

• To provide the names, contact numbers and other details of professionals and tutors on our referral database;
• To respond to your questions or suggestions;
• To improve the quality of our products or services; and
• To improve the quality of your visit to our Website or Facebook page.
• If you do not provide us with the Personal Information listed above, we may be unable to provide our services to you

Communications from GiftedApples Reading

(a) We do not use Sensitive Information for marketing purposes.

(b) We may use and disclose your Personal Information (other than Sensitive Information) to provide you with information on offers, products and services offered by us and you consent to us doing so.

(c) If at any time you no longer wish to receive any direct marketing from us or do not     want your information disclosed for direct marketing, contact our Chief Privacy Officer using the details we have stated, or use any unsubscribe facility we provide for that purpose.  Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services and other factual information as permitted under the Privacy Act and the CAN-SPAM Act of 2003 is a U.S. law of the Federal Trade Commission that sets the rules for commercial email.

6 Disclosure of your Personal Information

(a) We do not sell, rent or trade Personal Information to or with any other third parties.

(b) At present we are not likely to disclose Personal Information to overseas recipients.  From time to time we may share your Personal Information with a third party in the United States. 

   (i) you (or your authorized representative, as appropriate) has consented to the transfer;

   (ii) we reasonably believe that the recipient of the information is subject to equivalent or    

   substantially similar obligations for the protection of your Personal Information that we  

   are; or

   (iii) we are otherwise permitted or authorized by law to transfer your Personal  

   Information.

(c) We typically disclose Personal Information to third parties in the following circumstances:

    (i) that third party is the seller of a product you have purchased;

    (ii) that third party is a contractor engaged to provide goods or services to us (including   

    goods or services that assist us in providing our Website). Our agreements with such

    independent and subcontractors require that they keep your Personal Information

    confidential, and that they only use or disclose your Personal Information for the purposes

    of providing those goods or services to us;

    (iii) that third party is a psychologist or healthcare professional who we have contracted  

    with or you have been referred in the delivery of services to your child;

    (iv) that third party is an employee, independent contractor, subcontractor, or

    consultant chosen to deliver and improve our services;

    (v) you have consented for us to share the information for this purpose; or

    (vi) the disclosure is authorized by Privacy Laws including:

(d) to lessen or prevent a serious threat to life, health or public safety;

(e) if authorized or required by law;

(f) if we have reason to suspect that unlawful activity, or misconduct of a serious nature,

    that relates to our functions has been, is being or may be engaged in;

(g) if we believe it is reasonably necessary to assist in locating a missing person;

(h) to establish, exercise or defend a legal or equitable claim;

(i) if we believe it is reasonably necessary for an enforcement related activity conduct by, or

    on behalf of, an enforcement body; or

(j) you would reasonably expect or we have told you that your Personal Information is

    usually used or disclosed to third parties in this way.

Access and correction of your Personal Information

1. We will, on request, provide you with access to the Personal Information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under Privacy Laws.
2. If you require access to your Personal Information, before we provide you with  
3. access to your Personal Information we require some proof of identity. For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if actually providing you with access requires a substantial effort on our part.
4. If we refuse to provide you with access to the information, we will provide you with

reasons for the refusal and inform you of any exceptions relied upon under the Privacy Laws.  We take such steps as are reasonable in the circumstances to ensure that your Personal Information is accurate, complete, and up-to-date whenever we collect or use it. If the Personal Information we hold about you is inaccurate, incomplete, irrelevant, misleading or out-of-date, please contact us (details provided below) and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

1. We will respond to all requests for access within a reasonable time.

Security and retention of Personal Information

(a) The security of your Personal Information is important to us. We take such steps as are reasonable in the circumstances to protect your information from misuse, interference or loss, and from unauthorized access, use, modification or disclosure. This includes the use of technologies and processes such as access control procedures and physical security to protect the privacy of your Personal Information.

(b) We will retain your Personal Information for no longer than is necessary for the purpose of collection. Once we no longer require your Personal Information for the provision of services or another purpose of collection, we take such steps as are reasonable in the circumstances to destroy in a secure manner or permanently de-identify your Personal Information.

(c) However, when using our Website you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you provide to us over the Internet and you do so at your own risk.

(d) The steps we take to protect Personal Information include:

(i) password protecting your Personal Information on our systems; and

(ii) using an encrypted payment processing method to protect your payment data.

Links to other websites

Sometimes our Website contains links to other websites or we may provide links to third party websites as a service to you. Those links are provided for convenience only and may not remain current or be maintained. When you access a website other than our Website, we are not responsible for the content or privacy practices of that site. We recommend that you review and understand the privacy policies of each website you visit before providing any information to them.

Complaints

If you wish to make a complaint about an alleged breach of Privacy Laws, we ask that you send us your complaint in writing to inquiries@giftedapplesreading.com. Our promise is to respond to complaints within a reasonable period, and in any event, acknowledge your complaint within 30 days.

Or you may contact at FERPA.Complaints@ed.gov, or mail it to the following address:

U.S. Department of Education
Student Privacy Policy Office
400 Maryland Ave, SW
Washington, DC 20202-8520

Our promise is to respond to complaints within a reasonable period, and in any event, acknowledge your complaint within 30 days.

How to Contact Us

If you have any queries or complaints with regard to our collection, use or management of your Personal Information, please contact:

A: GiftedApples Reading and Math, LLC 3724 Riedham Road
Shaker Heights, Ohio 44120-5215

Email: info@giftedapplesreading.com

Inquiries: inquiries@giftedapplesreading.com

T: 1(440) 825-1920
T 1 (216) 820-3800