Privacy Policy

Adaptive Tutors LLC, doing business as Third Mind Learning, www.thirdmindlearning.com ("Third Mind Learning," "us," "we," or "our"), thanks you for visiting the online resources we publish. We use the words "you" and "your" to mean you, the reader, and other visitors to our online resources. Because our Services are purchased by parents and legal guardians on behalf of their teens, "you" usually means a parent or guardian, and "your student" means the high school student enrolled in our program. Our privacy policy ("this policy") explains from whom and what types of personal information we collect, how we use it, who we share it with and why, and what we do to protect it.

Online resources mean the websites, landing pages, forms, scheduling pages, and other internet features we own or operate that let you interact with us, and the emails and text messages we send.

WHO WE ARE

Third Mind Learning is a coaching and consulting company that helps families of ambitious, college-bound teens who struggle with SAT and ACT test anxiety perform at their best when it matters most. We operate primarily in the United States. Adaptive Tutors LLC is responsible for the personal information described in this policy.

WHO WE COLLECT PERSONAL INFORMATION FROM

We may collect personal information from the following groups: visitors to and users of our online resources; parents and guardians who contact us, book a call, or enroll; students enrolled in our programs (with their parent's or guardian's permission); and vendors, contractors, and business partners.

Personal information generally means information that can be used to identify you or that can be easily linked to you (for example, your name, address, telephone number, or email address). Where a privacy law that applies to us defines personal information more broadly, our use of the phrase includes the elements that law requires.

Most of this policy addresses the personal information we collect from website visitors, parents and guardians, and students.

WHAT WE COLLECT

There are two types of information that we obtain and then store and use: (i) information you voluntarily provide to us; and (ii) information that is collected automatically when you use our online resources.

By using our online resources or purchasing our Services, you are signifying to us that you agree with this section of our privacy policy and that we may use and disclose your information as described.

Voluntarily Submitted Information.

If you participate in certain activities through our online resources, you may be asked to provide information about yourself and your student. The types of personal information we collect in those situations include identifiers (such as your name, email address, mailing address, and phone number) and payment information (such as your billing details, which are collected by our payment processor). We do not sell, rent, or trade voluntarily submitted personal information.

If you don't want us to collect this type of personal information, please don't provide it. Participation is strictly your choice. Not participating may limit your ability to book a call or enroll, but will not affect your ability to access information available to the general public on our website.

Some of the ways you voluntarily give us your personal information and how we use it:

Emails and Online Forms – When you email us or fill out an online form, such as to contact us, download a resource, or join our email list, we keep your email address and any other personal information in your message and use it to respond to you and process your request. Depending on the information you provide, we may reply by email, phone, or text message (see "TEXT MESSAGING (SMS)" below). We may also send you information about our programs that we think may interest you.

Booking a Call – When you schedule a consultation or strategy call, we collect your name, email address, phone number, and the answers you give to any application or intake questions (for example, your student's grade, planned test dates, and the challenges your family is facing). We use this information to prepare for and hold the call and to send reminders about it.

Enrolling in a Program – When you enroll, we collect the information needed to deliver the program and manage your account, including parent and student contact details, billing information (through our payment processor), and the student information described below. We use it to perform our agreement with you and to communicate with you about the program.

Student and Wellness Information – To tailor coaching, we collect information about your student, such as their name, grade, school, target colleges, test dates, and, if provided, their own email address or phone number. We also collect academic information (diagnostic and practice test results, official scores you choose to share, practice work, and progress notes) and wellness and performance information you choose to share (such as descriptions of test anxiety, stress, focus, study habits, and goals, and any heart-rate-variability or biofeedback readings you choose to share). We use this information only to deliver and personalize coaching. We never use it for advertising.

Registering for Events – When you register for a webinar, workshop, or other event we host, you provide the identifiers described above, and payment information if the event has a fee. We use this information to register you and send you communications about the event.

Automatically Collected Information.

When you visit our online resources, basic information is collected automatically through your web browser, mobile device, and similar technologies. This includes the domain name and IP address you visited from; the type of browser and operating system you use; the date, time, and length of your visit; the pages you viewed; and the links you used to arrive at and leave our site. For a description of the cookies, pixels, and other tracking technologies we and our partners use, and your choices about them, see "ONLINE TRACKING TECHNOLOGIES AND ADVERTISING" below.

If you access our online resources from a mobile device, we may receive general location information (such as city or region) derived from your IP address. We do not collect precise geolocation.

We use automatically collected information to understand how visitors use our online resources, fix problems, and make our website better.

ONLINE TRACKING TECHNOLOGIES AND ADVERTISING

We, service providers operating on our behalf, and third parties may collect information about your activity on our online resources using tracking technologies such as cookies, pixels, tags, and scripts. Our online resources use the following types of technologies for the purposes described below:

Essential Cookies – These cookies are needed for our website, forms, scheduling pages, and checkout to work. Without them, the services you have asked for cannot be provided.

Functionality Cookies – These cookies let our website remember choices you make, such as information you've entered in a form, so you don't have to re-enter it.

Analytics and Performance Cookies – These cookies collect information about how visitors use our website, such as the number of visitors, the pages they visit, and the sites that referred them. We use this information to operate and improve our website.

Pixel Tags – We may use "pixel tags" (small pieces of code) from advertising platforms on our marketing and landing pages. A pixel can collect information such as your IP address, the page you visited, and the time of your visit, and lets the platform measure the results of our ads and show our ads to people who have visited our site. You can opt out as described below. We do not place advertising pixels on client portals or pages where students access program materials, and we do not share student information with advertising platforms.

We may use this tracking data to:

Keep our forms and scheduling tools working and remember your choices;
Measure and improve our website and the advertising you see; and
Show relevant advertising to parents who have visited our site.

We may provide advertising platforms with limited personal information about parents, such as a hashed (encrypted) email address, so the platform can match it to its own users and show our ads to them, avoid showing them our ads, or find similar audiences. We do not do this with student information.

You can limit this kind of advertising through the ad settings in your social media accounts and on your devices, by blocking or deleting cookies in your browser, or by using the opt-out form below.

Opt Out Preference Signals and Do Not Track

Some browsers offer a "Do Not Track" setting or other automatic opt-out signals. Our website does not currently respond to these signals.

Opt Out Form

To ask us not to use your personal information for targeted advertising, including matching your email address with advertising platforms, send an email to hello@thirdmindlearning.com with the subject line "Advertising Opt-Out" and include:

Contact Email
First Name
Last Name
State

We will stop using your information for targeted advertising once we receive your request.

User Beware: External Sites, Apps, Links, and Social Media.

We may maintain a presence on social media platforms, and our online resources may link to websites or tools controlled by third parties, such as scheduling, video-conferencing, and practice-test platforms. We are not responsible for the content or privacy practices of those platforms, sites, or tools. They have their own privacy policies and terms, which you should read.

TEXT MESSAGING (SMS)

We use text messaging primarily to send appointment reminders and updates about upcoming sessions and meetings.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service and messaging platform providers, is permitted.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
You can opt out at any time by replying STOP. Reply HELP for help. Message and data rates may apply. Message frequency varies.
Text messages are sent to the parent or guardian who provides their number. We text a student's own mobile number only with the parent's or guardian's consent.
For full text-messaging terms, see our Terms and Conditions: https://thirdmindlearning.com/terms/.

HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

To respond to your inquiries and schedule calls.
To deliver, personalize, and improve our coaching programs.
To track your student's progress and adjust their plan.
To send appointment reminders and service updates by email and text message.
To manage your account and enrollment.
To process payments and prevent fraud.
To send periodic emails about your program, sessions, and billing.
To improve our website and customer service.
To develop new programs and improve current ones.
To protect the security and integrity of our online resources and our business.

We may also use parents' information for the following marketing purposes:

To send you educational content, updates, and offers by email, if you have joined our list (you can unsubscribe at any time).
To show relevant advertising to parents, as described in "ONLINE TRACKING TECHNOLOGIES AND ADVERTISING."

We may also use information for other purposes disclosed when you provide it, or with your consent.

WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION

We do not sell or rent your personal information or your student's personal information to data brokers or marketing companies. We share information only as described below.

Vendors and Service Providers.

We share information with vendors who help us run our business, such as our customer relationship management (CRM) and messaging platform, scheduling and video-conferencing tools, email delivery services, payment processors, and website hosting. We share only the information each vendor needs, and we expect them to use it only to provide services to us, keep it confidential, and protect it. We cannot guarantee that every vendor will always fully comply, but we choose reputable providers and review their practices.

At Your Request.

We never share your student's test scores, academic information, or wellness information with schools, colleges, tutors, or anyone else unless you ask us to.

Legally Compelled Disclosures.

We may disclose information to government authorities or other third parties when required by law, such as in response to a court order or subpoena.

To Prevent Harm.

We may disclose information when we believe it is necessary to protect the safety of a student or anyone else, or to protect our rights or property.

Business Transfer.

If our business, or substantially all of its assets, is sold, merged, or reorganized, personal information may be among the transferred assets, and it will remain subject to this policy.

YOUR RIGHTS AND OPTIONS

You can opt out of certain uses of your information and ask us to access, correct, or delete it.

Emails. If you join our email list, you can unsubscribe from marketing emails at any time by clicking the link at the bottom of any email or by emailing hello@thirdmindlearning.com. Some emails are transactional (for example, scheduling, enrollment, and billing messages). While you are an active client, you cannot unsubscribe from those, so that you have accurate information about your program.

Text messages. Reply STOP to any text to stop receiving them.

Access, correction, and deletion. You can ask us to tell you what personal information we hold about you or your student, to correct it, or to delete it, by contacting us at hello@thirdmindlearning.com. When we receive an opt-out or deletion request, we will take reasonable steps to act on it promptly. It may take a short time to process, so you may receive messages for a brief period afterward.

For cookie- and tracking-based choices, including the advertising opt-out form, see "ONLINE TRACKING TECHNOLOGIES AND ADVERTISING" above.

CHILDREN'S AND STUDENTS' PRIVACY

Federal law places special restrictions on websites that collect personal information from children under 13. Our Services are purchased by parents and guardians, our website is directed to adults, and our programs are designed for high school students, typically ages 13 to 18.

We do not knowingly collect personal information directly from children under 13. If we learn that we have collected information from a child under 13 without verifiable parental consent, we will delete it. If you believe this has happened, please contact us at hello@thirdmindlearning.com.
Information about students ages 13 to 17 is collected from, or with the permission of, the student's parent or guardian.
A parent or guardian may review, correct, or ask us to delete their student's information at any time.
We do not use students' information for advertising, and we do not sell or share it.

We encourage parents and guardians to talk with their teens about sharing personal information online.

HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We take reasonable administrative, technical, and physical precautions to protect personal information, including limiting access to people who need it, using reputable service providers with their own security programs, and using secure (encrypted) connections for forms and payments. No method of transmission or storage is completely secure, so we cannot guarantee that information will be free from unauthorized access, loss, or misuse. If we learn of a security incident that affects your personal information, we will notify you as required by law.

DATA RETENTION

We keep personal information, including session recordings, for as long as needed to provide our Services and for business, tax, and legal purposes. You may ask us to delete your or your student's information at any time, and we will do so unless we are required by law to keep it.

CALIFORNIA PRIVACY RIGHTS

This section describes the rights California residents have under California law, including the California Consumer Privacy Act ("CCPA"), to the extent those laws apply to us. For this section, "you" and "your" mean California residents.

What do we collect from California residents?

In the past 12 months, we have collected the following categories of personal information: identifiers such as name, email address, phone number, mailing address, and IP address; customer records information such as name, address, telephone number, and payment information; commercial information such as programs purchased; internet or electronic activity such as pages viewed on our website; education information such as your student's grade, school, and test results; audio or video information such as session recordings, if you consent to them; and sensitive personal information limited to the wellness information you choose to share, which we use only to provide our Services. We collect this information from the sources and for the purposes described in this policy. We keep it for the periods described in "DATA RETENTION." We do not sell personal information for money. If we use advertising pixels, you can opt out of that advertising as described above. We do not sell or share the personal information of anyone we know to be under 16.

Rights of California Residents

If you are a California resident, you have the right to request:

Access: the categories and specific pieces of personal information we have collected about you, the sources, the purposes for collecting it, and the categories of third parties we disclose it to.
Deletion: that we delete personal information we have collected from you, subject to legal exceptions (for example, if we need it to complete a transaction or comply with a legal obligation).
Correction: that we correct inaccurate personal information.
Opt-out of targeted advertising: see "ONLINE TRACKING TECHNOLOGIES AND ADVERTISING" above for the opt-out form.

We will not discriminate against you for exercising these rights. To exercise them, contact us at hello@thirdmindlearning.com. We may need to verify your identity, or your authority to make a request for someone else, before we respond. We will confirm receipt and respond within the time frames the law requires.

Shine the Light. California Civil Code Section 1798.83 lets California residents ask whether we have shared personal information with third parties for their own direct marketing purposes. We do not.

RESIDENTS OF OTHER STATES

Residents of some other states, such as Virginia, Colorado, Connecticut, Texas, and Oregon, may have similar rights under their state's privacy laws, including the rights to access, correct, delete, and obtain a copy of personal information, to opt out of targeted advertising, and to appeal our decision on a request. We honor these requests from all U.S. residents, whether or not their state law requires it. To make a request or an appeal, contact us at hello@thirdmindlearning.com.

AGENT AUTHORIZATION

You may authorize someone to make a privacy request on your behalf (an authorized agent). Authorized agents must show that you have authorized them to act for you, or that they hold power of attorney. We may confirm the request directly with you or ask for more information to verify the agent's identity. A parent or legal guardian may make requests on behalf of their minor student without separate authorization. An authorized agent may use your information only to fulfill your request, for verification, or for fraud prevention.

VISITORS FROM OUTSIDE THE UNITED STATES

Our online resources are operated in the United States and our Services are intended for families in the United States. If you visit from outside the United States, your information will be transferred to, stored, and processed in the United States. We do not sell personal information or use it for automated decision-making.

CHANGES TO THIS PRIVACY POLICY

This privacy policy was last updated on October 2, 2026 and is effective as of that date.

We may change or update this policy from time to time. We will post the updated policy on our website and change the date above, and for significant changes we will notify clients by email. Please check this page periodically.

CONTACTING US

If you have questions about this privacy policy or our privacy practices, please contact us at hello@thirdmindlearning.com or by mail at:

Attention: Privacy
Adaptive Tutors LLC (DBA Third Mind Learning)
11870 Santa Monica Blvd STE 106467
Los Angeles, CA 90025