Privacy Policy

Introduction

This Privacy Policy describes how information is collected, used, and shared through Online Reading Tutor’s website, web application, the Dyslexia Reading Test Android application, and the Dyslexia Test iOS application.

The web application contains Screener, which identifies signs of reading difficulty, and Classroom, which provides reading instruction and progress monitoring. The mobile applications contain Screener only. Screener does not create or use user accounts. Classroom uses learner, parent or guardian, teacher, and other authorized accounts.

The Android app, Dyslexia Reading Test, is published on Google Play by Mojility Inc. on behalf of Online Reading Tutor Services Inc. The iOS app, Dyslexia Test, is published by Online Reading Tutor Services Inc.

In this policy, references to “we,” “our,” or “us” mean Online Reading Tutor Services Inc. ORT operates the services and is responsible for the personal information collected through them. The Android app sends Screener information directly to ORT’s systems.

Mojility Inc. also provides software and IT infrastructure services to ORT. Mojility personnel may access submitted information when needed to operate, support, secure, or maintain those systems under ORT’s instructions. Mojility does not use that information for its own independent purposes. Google may separately provide the Android publisher with app-store operational information under Google’s terms.

Our privacy commitment

This Privacy Policy describes the way in which Online Reading Tutor Services Inc. (referred to in this Privacy Policy as “Online Reading Tutor,” the “Company,” “we,” or “us”, or words of similar meaning) collects, uses, discloses, and safeguards personal information provided to us by Learners, Parent/Guardians, teachers and others (collectively “Users” or “you”) when they train on our website or mobile applications (collectively, together with any other services that Online Reading Tutor may from time to time provide at onlinereadingtutor.com or at any other Online Reading Tutor website that links to our Terms of Use, the “Services”).

Classroom Users are required to accept this Privacy Policy when they accept our Terms of Use. Screener presents a privacy notice and the applicable choices before submission without requiring an account. Capitalized terms used and not defined in this Privacy Policy have the meanings given to them in the Terms of Use.

In support of Online Reading Tutor’s mission to help every learner in the world learn to read and read to learn, we are committed to protecting the privacy of our Users and providing a safe, online learning environment. Online Reading Tutor is committed to only collecting from Learner Users of Online Reading Tutor’s training materials the information needed to individualize the Learner’s learning, enable progress monitoring for Parent/Guardians and teachers, and optimize the Training experience.

Online Reading Tutor does not permit third-party advertising in our training, and Online Reading Tutor does not sell, lease, or otherwise trade for value any personal information of learners. Learners’ information is only used to provide and improve our services.

1. Types of User information we collect

We and our service providers collect information when Users visit our website, complete a Screener, create an account, or use the Services. The types of information we collect vary depending on the type of User who engages the Services, including:

“Parent/Guardian Users” (also called “Parent/Guardians”), which means parents or guardians of Learner Users.

“Learner Users” (also called “Learners”), which means a child or other learner who uses the Services.

A Learner User account can be linked to one or more Parent/Guardian Users in order to facilitate a continuous learning journey for that Learner User both in and outside of the classroom. Any Parent/Guardian Users linked to that Learner User account will have access to the information in that account, including activity recorded both in and outside of the classroom.

Screener users

Screener collects information about a child or an adult taking the assessment and the adult submitting it. Depending on the path and choices shown, this includes:

• The learner’s name and grade or reading level, and whether the Screener is for a child or the adult completing it.
• The parent, guardian or adult learner’s name, email address, telephone number, telephone country code, and country.
• Optional comments.
• Each answer, correctness, timeout state, response time, section results, total score, and reading-risk category.
• The privacy notice and follow-up choices shown, the choices made, and the versions, identifiers, dates and times used to record them.
• Technical details submitted with the record, such as platform, app version, and device model.

Contact details, answers and the result are stored together as an identifiable Screener record. In the child path, the submitting adult confirms that they are the child’s parent or legal guardian. In the adult self-screening path, the person confirms that they are at least 18 and submits their own information.

A Screener result is an indicator of reading difficulty, not a clinical diagnosis. The account descriptions below apply to Classroom.

Information collected from users

We collect information from Users when they send it to us, for example when you sign up and purchase a product or service, sign up to receive our newsletter, or otherwise contact us with a customer support question, chat, comment, or request.

If you submit any information relating to other people in connection with your use of the Services, you represent that you have the authority to do so and you permit Online Reading Tutor to use and share that information in accordance with this Privacy Policy.

Learner users

We collect information about Learner Users when the Learner creates an account directly with us or when the Learner User account is created by a Parent or Guardian. We are committed to collecting the minimum amount of information about Learners needed for us to operate the Services effectively. When an Online Reading Tutor Learner User account is created, we collect the Learner’s first name and grade. Learners are assigned a unique username based on their first name which is used to log in but is not visible to other Users except for that Learner’s linked Parent/Guardians. The Learner then selects a fictional avatar name and appearance from a list of options.

Parent/Guardian users

When registering with Online Reading Tutor, Parent/Guardian Users are asked to provide personal information, including but not limited to their first and last name, email address, password, and Location (country, state or province) for their account. Online Reading Tutor also collects Learner User information regarding Learner Users associated with Parent/Guardians for purposes of linking the Learner and Parent/Guardian accounts.

For Parent/Guardian Users with a paid membership, those Users must also provide payment information. Online Reading Tutor does NOT directly collect and store that credit card information. All credit card information and purchase transaction information is instead collected and stored by our third-party payment providers, such as Stripe or the app store through which you purchased our membership.

Information collected from devices and use of the services

Performance data. As Learners train on the Online Reading Tutor apps or use other Online Reading Tutor Services, we collect information on the features they interact with, reading skills they encounter, and questions answered (“Performance Data”). This may include data on which activities a Learner completes, the number of questions answered correctly or incorrectly, where the Learner is in the curriculum, and time taken to answer questions. Where a Parent/Guardian is linked to a Learner, the Learner’s Performance Data is reported to that Parent/Guardian to allow for monitoring of progress.

Health-related data

Online Reading Tutor is a neuroscience-based reading intervention designed for learners with dyslexia and other reading difficulties. Because our Services are designed to support learners with a health and learning condition, certain data we collect may be considered health-related data under applicable laws and platform policies. Specifically, the following data may constitute health-related information:

Reading performance metrics: response times, accuracy rates, number of attempts per lesson, and processing speed measurements collected during training exercises. Intervention progress data: curriculum position, lesson completion status, trial records, warm-up and ramp-up performance, and progression through training stages. Learning profile indicators: grade level, areas of reading difficulty, and patterns derived from a Learner’s interaction with training materials that may indicate the nature or severity of reading challenges.

This health-related data is collected solely for the purpose of delivering, personalizing, and improving the reading intervention Services. It is used to adapt lesson difficulty, track Learner progress, generate progress reports for linked Parent/Guardian Users, and improve the effectiveness of our training methodology. We do not sell, lease, or otherwise trade health-related data for any purpose, and it is not used for advertising, marketing, or any purpose unrelated to delivering and improving the Services. Health-related data is not shared with third parties except as described in Section 3 of this Privacy Policy.

Screener answers, response times, scores and reading-risk categories may also be health-related information. ORT uses them to run the assessment, deliver and explain the result, provide support, and improve the educational service. They are not used to select advertisements, build advertising audiences, or personalize unrelated marketing. Any selected result-explanation follow-up is subject to the limits in sections 2 and 3.

Website cookies and device information

When you visit our website, Online Reading Tutor and our third-party providers automatically collect certain technical information from your computer or mobile device, such as your IP address, browser type, operating system, and the pages you view, through cookies and similar technologies like pixel tags. This includes high-level geographic location (such as state or region) and analytics data (for example through tools such as Google Analytics) to measure traffic and usage trends. We also use third-party advertising providers to collect information about Parent/Guardian Users who visit areas of the Services that are not directed to Learner Users, for interest-based advertising purposes.

Our website uses two categories of cookies. Strictly necessary cookies (for example, a cookie that remembers your region so we can display pricing in the correct currency, and a cookie that remembers your cookie choice) are required for the site to function and are set automatically. Analytics and advertising cookies and tracking technologies (such as Google Tag Manager and the tags we manage in it, which currently include Google Ads, Meta (Facebook) Pixel, Reddit Pixel, and Microsoft Clarity), and optional embedded content such as our HubSpot forms, are only loaded after you accept them using the cookie consent pop-up shown when you first visit. If you reject, they are not loaded. You can change your choice at any time using the “Cookie Preferences” link in our website footer.

Cookies and similar technologies placed within areas of the Services directed to Learners are used only in support of internal operations: providing access to Trainings and their features, individualizing content, and improving and optimizing the Services. We do not allow third-party targeted advertising providers to collect information from the Learner-directed portions of the Services.

The mobile Screener apps do not use advertising identifiers, advertising SDKs, or cross-app tracking to deliver targeted advertising. Website cookie and advertising practices described above are separate from the app and device context submitted with a mobile Screener record.

Information from third parties

We may obtain information about you or your use of the Services from third parties and sources, such as single sign-on providers, web hosting providers, analytics providers, or advertisers. When you access the Services through third-party platforms, you are authorizing us to collect, store, and use such information in accordance with this Privacy Policy.

2. How we use User information

Screener purposes and requested follow-up

ORT uses Screener information to:

• Run the assessment, calculate and display the result, and deliver the requested report.
• Provide support and respond to access, correction or deletion requests.
• Record the privacy notice shown and the person’s choices.
• Protect the service, diagnose technical problems, and apply the retention schedule in section 6.
• Where offered and selected, provide a follow-up through the chosen method. Choices may include a call using an AI-generated or synthesized voice, a call from a person, or email without a call.

A requested follow-up may explain the result and discuss ORT services. A choice of email without a call does not authorize a telephone call or text message. The result and requested report do not depend on agreeing to an optional call. ORT uses the choice recorded for that submission; it does not assume that an older submission carries permission for a newly offered option.

Contact details may be used for commercial communications where permitted and consistent with the person’s choices. Permission for a result-explanation follow-up does not by itself authorize unrelated marketing or a recurring marketing sequence. Commercial emails include a way to unsubscribe.

The restrictions on using answers and reading-risk information for marketing continue to apply even where ORT has permission to contact the adult.

Classroom and other service purposes

How we use Parent/Guardian User information: to allow registration and use of the Services; to analyze and provide progress reports on linked Learner User accounts; to process payments (Online Reading Tutor does NOT directly collect or store credit card information); to communicate about your account, including Terms of Use changes, security alerts, and support responses; to send marketing communications (you can opt out at any time); and to deliver, tailor, and measure advertising to Parent/Guardian Users.

How we use Learner User information: to measure a Learner’s reading progress and performance, including health-related reading intervention metrics, and to provide associated progress reports to linked Parent/Guardian Users; to adapt, personalize, and customize the Learner’s training experience; and to improve the effectiveness of our neuroscience-based reading intervention methodology through analysis of aggregated and de-identified performance data. Health-related data collected from Learner Users is used exclusively to provide and improve the reading intervention Services, and is never used for advertising, profiling, or any purpose unrelated to the Learner’s educational experience.

How we use all User information: to monitor, maintain, analyze and improve the functionality of the Services; to assess and improve our products, services, and educational content; and as necessary to detect violations of and enforce our Terms of Use, protect the security of the Services, and protect the rights, privacy, property, or safety of Online Reading Tutor, you, or others.

De-Identified or Aggregated Information. We may create de-identified or aggregated data by removing identifiers that make data personally identifiable to a particular User. We may use or disclose such data for lawful and legitimate business purposes, including to analyze, build and improve the Services. Such information will not be shared in a way that could be used to identify a User.

For Screener analysis, ORT uses de-identified or aggregated information only once it cannot reasonably identify a person. Removing a name alone is not enough if ORT or a provider can reconnect the record to the person.

3. How we share User information

We only share information collected in limited circumstances, and we do not disclose the personal information of Learners to third parties for marketing or promotional purposes.

Health-Related Data Sharing Restrictions. Health-related data is only shared: with Parent/Guardian Users linked to the relevant Learner User account, for the purpose of monitoring progress; with service providers who assist in operating the Services (such as cloud hosting and infrastructure providers), subject to contractual obligations to safeguard the data; or as required by law, regulation, or valid legal process.

We share User information with third parties: where a Learner User account is linked to a Parent/Guardian; with service providers who perform services for us (such as analytics, credit card processing, or research), subject to confidentiality obligations; to support the consideration, negotiation, or completion of a possible merger, sale, financing, or transfer of all or a portion of our business; where you have instructed us to; and as necessary to detect violations of and enforce our Terms of Use, protect the security of the Services, or pursue available remedies.

We may disclose your information if we believe it is reasonably necessary to comply with a law, regulation, or legal request; to protect rights, privacy, property, or safety; or to address fraud, security, or technical issues. In some cases, personal information may be transferred, stored, or processed outside of Canada, subject to appropriate safeguards.

For Screener, service providers may host records, deliver reports and email, provide support, or perform the follow-up selected by the person. They act under ORT’s instructions and may use the information only to provide those services. Their agreements must restrict independent use and protect the data. Mojility’s access is limited to the software and infrastructure role described in the introduction.

A provider performing a selected follow-up receives only the contact details and minimum result summary needed to explain that result. It must not use answers, scores or reading-risk information for advertising, audience building, or unrelated marketing. Individual answers are not sent into marketing systems. ORT and its Screener providers may process information in Canada and the United States. Information processed abroad may be accessible to authorities under that country’s laws.

Where ORT processes learner information for a school or another institution, it follows the institution’s lawful instructions for the educational service. That information is not used for consumer lead generation or advertising.

4. How we protect User information

The User information we collect is stored and processed in environments designed to allow only authorized individuals to access the infrastructure where this information is stored. Online Reading Tutor and its service providers maintain strict administrative, technical, and physical measures, including industry-standard SSL encryption, data encryption, firewalls, multi-factor authentication for personnel, and physical-access controls.

Given the sensitive nature of health-related data collected through our Services, we apply the same rigorous security measures to all health-related information: encrypted in transit using industry-standard SSL/TLS encryption, stored in access-controlled environments, and restricted to authorized personnel who require it to support the Services.

Personnel access is limited to work that requires it. ORT and Mojility use authenticated connections between systems and work to keep Screener answers and result content out of ordinary application logs.

5. Users’ rights regarding their information

Access, correction or deletion. Parent/Guardian Users may contact our customer support at any time to access, correct, or delete their personal information, or personal information collected from or about their linked Learner Users, including a request to cease collecting personal information from those Learner Users. A request to delete or cease collecting personal information may lead to closing the relevant account or losing access to certain portions of the Services.

Screener requests and follow-up choices

Screener users do not need an account to request access, correction, deletion, or withdrawal of follow-up permission. Email info@onlinereadingtutor.com with the subject “Privacy request”. Include the name, email address and approximate date used for the Screener. ORT may request enough further information to verify identity and authority, including a parent’s authority to act for a child.

A person can withdraw permission for an automated call, a human call, or email follow-up. ORT applies the withdrawal to pending follow-up and instructs its providers to stop the affected contact. Withdrawing optional follow-up does not prevent delivery of a requested report. It does not undo processing that was lawful before withdrawal.

When a deletion request is completed, ORT deletes or de-identifies the relevant record and directs its providers to do the same, subject to any applicable legal exception. Limited consent evidence, do-not-contact records and backups are handled under section 6. ORT explains any information it must retain and responds within the applicable legal period.

Other choices and regional rights

Advertising & your choices. To learn more about interest-based advertising and how you can opt out, you may review tools including the Network Advertising Initiative, Digital Advertising Alliance (and its Canadian counterpart), and your device’s ad-tracking settings (iOS “limit ad tracking”, Android “opt-out of interest-based ads”).

Opting out of email communications. You can opt out of receiving commercial or promotional emails by following the unsubscribe instructions in the email or by contacting customer service.

California privacy rights. California residents have the right to know what personal information we’ve collected and how it’s used and shared, the right to request deletion of personal information (subject to exceptions), the right to opt out of “sales” as broadly defined under California law (Online Reading Tutor does not sell personal information for money, but allows advertising partners to collect information from non-Learner-directed areas of the Services, which California law may treat as a sale; you can opt out using the “Cookie Preferences” link in our website footer), and the right not to be discriminated against for exercising these rights. Requests can be submitted to info@onlinereadingtutor.com with the subject line “California Rights Request.”

Users in the EEA, UK, and Switzerland. We process personal information on the basis of your consent, as necessary to perform our obligations under an agreement for Services, or as necessary for our legitimate business interests. You have rights under the EU GDPR, UK GDPR, or Swiss Federal Act on Data Protection to access, correct, delete, restrict, or object to our use of your personal information, or to receive a portable copy of it, and the right to lodge a complaint with your local data protection regulator. Contact info@onlinereadingtutor.com to exercise these rights.

6. Storage and retention of User information

Classroom and other account records

Information may be transferred, stored, and processed in Canada, the United States, or any other country where we or our processors maintain offices. For Classroom and other account-based services, we retain your personal information for as long as we have a relationship with you, and may retain it after that relationship ends as required by law or to investigate or defend against potential legal claims. Health-related data is retained for as long as a Learner User account is active and as needed to provide the Services, and is deleted upon account deletion or a valid deletion request in accordance with our standard procedures and applicable law.

Screener records

For someone who uses Screener and does not enroll as an ORT learner:

• An anonymous technical session or incomplete identifiable Screener record is deleted seven days after its last activity.
• Completed identifiable answers and results are deleted or irreversibly anonymized 90 days after completion.
• An email address used only to deliver a report is removed from report delivery systems 30 days after confirmed delivery.
• A result-explanation job is removed 30 days after completion or abandonment; provider payloads are removed within 24 hours.
• Operational security logs are normally retained for 90 days and do not contain answers or result content.
• Backups expire within 90 days. A restored backup must reapply completed deletion and do-not-contact records before use.

A legal obligation, dispute or documented legal hold may require a different period. When a person enrolls, information needed for their educational service is handled under the Classroom retention provisions above.

Where follow-up is requested, ORT keeps the minimum contact and permission records needed while that permission remains active. ORT reviews an inactive marketing contact after 12 months without meaningful engagement. Withdrawal or unsubscription is applied promptly. A minimal do-not-contact record may be kept to prevent an unwanted contact from being imported again; it contains no answers or reading result.

Consent evidence is kept for the period needed to demonstrate that a message or call was authorized. It is limited to the person, contact channel, notice version, choice, source, and relevant dates and times.

7. Updates to this policy

This Privacy Policy may change from time to time. If we materially increase a User’s obligations or materially reduce our obligations to a User, we will provide at least thirty (30) days’ notice before the change takes effect, either by emailing affected Users or displaying an alert on our website or apps.

When publishing an update, ORT identifies its last-modified date and effective date. ORT keeps prior policy and Screener notice versions so it can identify what a person was shown when a choice was recorded. A policy update does not replace a person’s consent where new consent is required.

8. How to contact us

If you have questions or concerns regarding the way in which your personal information has been used, please contact us at info@onlinereadingtutor.com.