Effective Date: Sep 24, 2025

Introduction: Dewey Smart (“Company”, “we”, “us”, or “our”), as a service provided by Abrega, Inc. (Delaware), is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information. It applies to information collected through our website (https://www.deweysmart.com), our service platform, and in the course of providing coaching and tutoring services. By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use our services.

1. Information We Collect:
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We collect several types of information from or about our clients (students and parents/guardians):

• Personal Identifiable Information (PII): This includes information you provide to us when creating an account or purchasing services. For example: your name, email address, phone number, billing address, and payment information. For students, we may collect the student’s name, age, school, grade level, and academic details relevant to coaching (e.g., courses taken, target test scores, college goals).
  
• Student Academic Information: To tailor our services, we might collect information such as academic transcripts or grades (if provided by the parent/student), standardized test scores, college application materials or essays (if our coaches are advising on them), and any other educational information you choose to share with us. We only collect what is needed to perform the coaching services.
• Usage and Technical Information: When you use our website or online platform, we automatically collect certain information through cookies and other tracking technologies. This might include your IP address, browser type, device information, pages you visit on our site, and the dates/times of your visits. (See Cookie Policy below for more details.) We also may keep records of communications and interactions, such as email correspondence or chat logs with our support team or coaches (for example, if scheduling via our platform messaging).
• Session Data: If sessions are conducted via our online platform or through video calls arranged by us, we may record certain metadata about the session (such as date, duration, participants). We do not record video or audio of sessions without consent, as noted in our Terms of Service. Coaches may keep notes on student progress which are shared with the Company and possibly with parents (these notes are also considered personal data related to the student).
• Payment Information: Payments are handled by third-party processors (e.g., Stripe). We ourselves do not store your full credit card numbers. We may retain records of transactions (amount, date, method, last4 of card, etc.) for accounting and dispute purposes.
• Children’s Data: We do not knowingly collect personal information from children under 13. Our services are intended for high school students (generally ages 13 and up) and require parent/guardian involvement for minors. If we learn that we have inadvertently collected personal data from a child under 13, we will delete that information. If you believe a child under 13 has provided us data, please contact us immediately. For students between 13 and 18, we might collect their information as provided by the parent or by the student with parent’s consent; by enrolling a minor student in our services, the parent consents to our collection and use of the student’s information as described in this Policy.

2. How We Use Your Information:
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Dewey Smart uses the collected information for various purposes consistent with providing our educational services to you:

• Service Delivery: We use personal and academic information to match students with an appropriate coach, to plan and deliver tutoring sessions, and to personalize the coaching to the student’s needs. For example, a student’s SAT score goal and current practice test results help the coach tailor test prep strategy.
  
• Communication: We use contact information (email, phone) to communicate with you about scheduling sessions, service updates, payment confirmations, and any customer support issues. We may send session reminders, progress reports, or feedback requests. We also use email to send newsletters or informational updates about new services if you opt-in to such communications (you can unsubscribe at any time).
• Payment Processing: Billing information is used to charge for the services you purchase. (Credit card processing is done by our payment processor, but we handle things like issuing receipts, tracking payment status, etc.) If there are issues with payment (e.g., a chargeback or dispute), we use purchase records and agreement confirmations to address it.
• Improvement of Services: We may analyze usage data (like which pages on our site are visited or how users navigate) to improve our website and services. Session notes or feedback may be used in aggregate (without identifying specific students) to improve our curriculum or coaching methods. We might also conduct surveys or ask for reviews to gauge satisfaction.
• Safety and Integrity: Information may be used to monitor for violations of our Terms of Service, to ensure the safety of our students and coaches. For instance, we may review communications if there’s a report of misconduct. We also use data to detect and prevent fraud or unauthorized use of our services.
• Legal Compliance: If required, we use personal information to comply with legal obligations such as maintaining financial records for tax purposes or responding to lawful requests by public authorities.

3. How We Disclose or Share Your Information:

We are careful with sharing personal data and do so only in certain circumstances:

• With Coaches/Tutors: The student’s assigned coach will have access to relevant personal information and academic information about the student in order to provide effective coaching. This includes the student’s name, contact (often communications go through our platform or via parent’s email), academic history as provided, and any notes from consultations. Coaches are contractually required to keep this information confidential and use it only for tutoring purposes.
  
• With Parents/Guardians: For minor students, information about the student’s progress and sessions will be shared with their parent or guardian. We consider the parent as part of the client entity, so this is not so much “third-party” sharing as it is internal sharing within the family. If a student over 18 is receiving services (or a minor who for some reason has separate communications), we abide by their reasonable requests for privacy, but generally in a high school context, parents will be kept informed.
• Service Providers: We use third-party companies to facilitate our services (e.g., scheduling software, video conferencing platform, email service, payment processor, data storage/CRM). These third parties may have access to personal information as needed to perform their functions on our behalf. For example, our payment processor will handle your credit card details; our email service will process emails we send you; a scheduling app may store your name and appointment times to send reminders. We strive to use reputable providers and we require that they implement security measures to protect your data. They are not permitted to use your data for their own unrelated purposes.
• Legal Requirements: We may disclose your information if required to do so by law or in response to a valid subpoena, court order, or government request. We may also disclose information if we believe in good faith that such action is necessary to (i) comply with the law, (ii) protect and defend our rights or property, (iii) prevent or investigate possible wrongdoing (such as fraud or security issues), or (iv) protect the personal safety of users or the public. For example, if a dispute arises and evidence is needed to demonstrate our policies (such as your agreement to a no-refund policy in a chargeback case), we might provide the necessary portion of our terms or communications as evidence .
• Business Transfers: In the event that Dewey Smart (Abrega, Inc.) is involved in a merger, acquisition, sale of assets, or reorganization, your information may be transferred as part of that transaction. We would ensure that the new owner is bound by similar privacy obligations to protect your data, and we would notify you of any change in data ownership if required.
• With Consent: If we want to share your information in ways not covered by this Privacy Policy, we will ask for your consent. For instance, if we have an opportunity for a student to be featured in a success story or testimonial on our website, we would only share their name or likeness publicly with the explicit permission of the student (and parent, if minor).

We do not sell personal information to third-party marketers. We also do not share personal information with third parties for their direct marketing purposes unless you give us permission.

4. Data Security:

We take the security of your personal information seriously and implement appropriate safeguards to protect it from unauthorized access, disclosure, or misuse. These measures include encryption of data in transit (e.g., our website is served over HTTPS), secure hosting environments, firewalls, and access controls limiting who at our company can view personal data. Client data is stored securely and is only accessible to authorized team members who require it to deliver our services. We also require our coaches and staff to adhere to strict confidentiality obligations.

However, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Clients acknowledge that no system is completely secure and accept the risks of providing personal information. Dewey Smart shall not be liable for any unauthorized access or hacking incident that is beyond our reasonable control . In the unlikely event of a data breach that affects your personal information, we will notify you and the appropriate authorities as required by law.

5. Data Retention:

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, which typically means for as long as you have an active relationship with us. For example, we keep student records while they are actively receiving tutoring and for a period thereafter in case they return for additional services (especially since services can be used up to 2 years post-graduation). We may retain certain data for longer if necessary to comply with legal obligations (e.g., financial transaction records for accounting/tax), to resolve disputes, or to enforce our agreements. When personal information is no longer needed, we will securely delete or anonymize it.

6. Your Rights and Choices:

Depending on your jurisdiction, you may have certain rights regarding your personal information:

• Access and Update: You can request access to the personal data we hold about you and ask that we correct or update any inaccuracies. Much of your basic contact information can be updated by you through your account profile on our website, or by contacting us.
  
• Deletion: You can request that we delete personal information we hold about you. For example, a parent might request deletion of a student’s data after services are completed. We will honor deletion requests to the extent we are able, but please note we might need to retain certain information for legitimate business or legal reasons (as noted in Data Retention). If you request deletion of data that is necessary for us to provide the service, we may need to terminate your service as a result.
• Opt-out of Communications: If you have subscribed to any marketing emails or newsletters, you can opt-out at any time by clicking the “unsubscribe” link in those emails or contacting us. Please note that we will still send you transactional or service-related communications (e.g., session reminders, payment receipts) as those are not promotional.
• California Privacy Rights: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) or similar laws, such as the right to know what categories of information we collect and for what purposes, the right to request disclosure or deletion of your information, and the right to opt-out of the “sale” of personal information (we do not sell data, as stated). You also have the right not to receive discriminatory treatment for exercising your privacy rights. If applicable, to exercise any of these rights, please contact us via the methods below. We will need to verify your identity before fulfilling certain requests.
• GDPR (EU/EEA) Rights: Although Dewey Smart primarily operates in the US, if you are an EU resident using our services, you have rights under the GDPR, including the right to access, correct, or delete your data, and the right to data portability and to object to or restrict processing. You also have the right to lodge a complaint with a supervisory authority. Where GDPR applies, Abrega, Inc. would be the data controller for your information. We would base our processing on the necessity to perform our contract with you (providing tutoring services), our legitimate interests (in improving our services, securing our platform, etc.), or your consent where applicable (for optional uses like marketing).

To exercise any data rights or if you have any privacy-related inquiries, please contact us at support@deweysmart.com or via mail at the address provided at the end of this policy. We will respond to verifiable requests within the timeframe required by law.

7. Cookies and Tracking Technologies:

We use cookies and similar tracking technologies on our website and platform to enhance user experience (see the Cookie Policy section below for details on what cookies we use and your choices).

8. Third-Party Links:

Our website or communications may occasionally contain links to third-party websites (for example, a resource link to a college admissions site or a practice test on another platform). If you click on a third-party link, you will be directed to that third party’s site which is outside our control. This Privacy Policy does not apply to third-party sites or services; we encourage you to review the privacy policies of any third-party websites or services before providing any information to them. Dewey Smart is not responsible for the content or privacy practices of any linked sites.

9. Social Media:

If Dewey Smart maintains a presence on social media platforms (e.g., Facebook, Instagram), any information you submit or post on social media (including tagging us or commenting) is done at your own risk and is subject to those platforms’ privacy policies. We might see information you make public on those channels, but we won’t collect or store it systematically beyond engaging with you on those platforms.

10. Updates to this Privacy Policy:
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We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any significant changes by posting the new Privacy Policy on our website and updating the effective date. In some cases, if changes are material, we may provide a more prominent notice or seek your consent as required by law. We encourage you to review this Privacy Policy periodically for any updates.

11. Contact Us:

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Dewey Smart (Abrega, Inc.) – Privacy Team
651 N Broad St, Suite 201
Middletown, Delaware 19709, USA
Email: support@deweysmart.com
Phone: +1(877)749-6539

By using Dewey Smart’s services, you acknowledge that you have read and understood this Privacy Policy.