Raise The Stars Inc.
1. Our Commitment to Privacy
Raise The Stars Inc. ("Raise The Stars", "we", "us") is committed to protecting the privacy of all users of the raisethestars.ca Platform ("Platform"), with particular care for the personal information of minors. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and applicable Ontario privacy law.
2. Scope — Special Protections for Minor Data
The Platform serves children between Grades 5 and 12. We treat the personal information of minors with heightened sensitivity. We do not:
- Collect personal information from minors directly without verified parental consent;
- Use minor data for marketing, profiling, or advertising purposes;
- Sell or disclose minor personal information to third parties except as required for Platform operations (e.g., tutor matching, session scheduling);
- Retain minor personal information beyond what is necessary for active account management and legal compliance.
3. Information We Collect
3.1 Parent / Family User Information
- Full name, email address, phone number, billing address;
- Payment information (processed by third-party PCI-DSS compliant processors - not stored by Raise The Stars);
- Account login credentials (stored in hashed form);
- Session booking history and communication records.
3.2 Minor / Student Information
- First name and grade level (collected from Parent registration);
- Learning track preferences and session progress (aggregate and anonymized where possible);
- Signature Project details (stored on Platform, visible to Parent).
3.3 Tutor Information
- Full legal name, contact information, proof of identity;
- Background check results (stored securely, access-restricted);
- Banking or payment details for disbursements;
- Session history and ratings.
3.4 Automatically Collected Information
- IP address, browser type, and device information;
- Cookies and similar tracking technologies (see Cookie Policy);
- Session logs and Platform usage data.
4. How We Use Personal Information
We use personal information only for purposes a reasonable person would consider appropriate:
- To operate and administer the Platform;
- To match Parents with Tutors;
- To process bookings and payments;
- To conduct background screening of Tutors;
- To send transactional communications (confirmations, receipts, session reminders);
- To send marketing communications, subject to CASL consent requirements;
- To monitor session safety and platform integrity;
- To comply with legal obligations;
- To improve Platform functionality and curriculum (using anonymized aggregate data).
5. Legal Basis and Consent
We rely on the following bases for processing personal information under PIPEDA:
- Express consent: for marketing communications and optional features;
- Implied consent: for information necessary to fulfil the service requested;
- Legal obligation: for background check disclosures and regulatory requirements;
- Legitimate interest: for fraud prevention and platform security (subject to privacy balancing).
Consent for the collection and use of a Minor's information is obtained from the Parent or legal guardian. Minors do not have independent accounts on the Platform.
6. Disclosure of Personal Information
We do not sell personal information. We may disclose information to:
- Tutors (limited to information necessary for session delivery);
- Background screening service providers (Tutor data only);
- Payment processors;
- Cloud hosting and infrastructure providers (subject to data processing agreements);
- Law enforcement or government authorities when legally required;
- Professional advisors (lawyers, accountants) under confidentiality obligations.
Any third-party processors are required to maintain data security standards consistent with this Policy and applicable law.
7. Data Retention
We retain personal information only as long as necessary:
- Active account data: retained for the duration of the account plus 7 years for financial/tax records;
- Background check results: retained for the duration of tutor engagement and deleted within 1 year of account closure;
- Minor session data: retained while the student account is active plus 2 years, then anonymized or deleted;
- Marketing consent records: retained in accordance with CASL (6 months after withdrawal of consent or 3 years from last activity).
8. Data Security
We implement administrative, technical, and physical safeguards appropriate to the sensitivity of personal information, including:
- Encryption of data in transit (TLS) and at rest;
- Role-based access controls;
- Regular security reviews;
- Incident response procedures aligned with PIPEDA breach notification requirements.
In the event of a privacy breach that poses a real risk of significant harm, we will notify the Office of the Privacy Commissioner of Canada and affected individuals as required by PIPEDA.
9. Individual Rights
Under PIPEDA and applicable law, individuals have the right to:
- Access their personal information held by us;
- Correct inaccurate or incomplete information;
- Withdraw consent (subject to legal and contractual limitations);
- Request deletion of personal information (subject to retention obligations);
- Lodge a complaint with the Office of the Privacy Commissioner of Canada.
To exercise these rights, contact our Privacy Officer at: legal@raisethestars.ca
10. Cookies and Tracking
We use cookies and similar technologies. See our separate Cookie Policy for full details, including how to opt out of non-essential cookies.
11. Cross-Border Data Transfers
Our infrastructure may involve processing or storage of data outside Ontario or Canada (e.g., cloud services). Where this occurs, we ensure contractual protections consistent with PIPEDA requirements for cross-border transfers.
12. Updates to this Policy
We will notify users of material changes to this Policy by email or Platform notice at least 30 days before changes take effect. Continued use of the Platform after that date constitutes acknowledgement of the updated Policy.