ETHICS POLICY | The Academy At TSOP

Privacy Policy for The Academy at True Sanctuary of Praise

6528 US Hwy. 301 S. Suite 114 Riverview, FL. 33578

Telephone: (813) 319-5862 | Email: academy@tsop-academy.com

The Academy at True Sanctuary of Praise values its visitors’ privacy. This privacy policy is
effective 12/29/2025; it summarizes what information we might collect from a registered user or
other visitor (“you”), and what we will and will not do with it.

Please note that this privacy policy does not govern the collection and use of information by
companies that The Academy at True Sanctuary of Praise does not control, nor by individuals
not employed or managed by The Academy at True Sanctuary of Praise. If you visit a Web site
that we mention or link to, be sure to review its privacy policy before providing the site with
information.

The Academy at True Sanctuary of Praise, Inc.
(Not-for-Profit, Private Christian School – Email & Text Message Marketing and Notifications)

Last updated: 12/29/2025

1. Scope and Overview

This Privacy Policy describes how The Academy at True Sanctuary of Praise, Inc. (“The Academy,” “we,” “us,” or “our”), a Not-for-Profit, Private Christian School, collects, uses, discloses, and protects personal information in connection with our email and text message (SMS/MMS) communications. This includes messages for academic updates, school operations, emergency notifications, spiritual formation, event announcements, and fundraising initiatives.

This Policy applies to:

Parents/Guardians of students, students (where applicable), staff, volunteers, and community members who interact with The Academy.
Individuals who sign up to receive email communications from us.
Individuals who provide a mobile number and consent to receive SMS/MMS text messages from us.
Individuals who interact with us via our school website, enrollment forms, events, or other school-related programs in connection with email or SMS communications.

Where applicable, this Policy is intended to be consistent with relevant U.S. federal and Florida state laws and regulations, including:

The Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and related FCC regulations regarding marketing and automated text messages.
The Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act of 2003, 15 U.S.C. § 7701 et seq., governing commercial email messages.
The Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, which applies to operators of commercial websites and online services directed to children under 13. While The Academy is a not-for-profit educational institution, we strive to adhere to COPPA’s principles for the protection of personal information collected from children through online services directed to them.

In addition, we seek to comply with applicable Florida privacy and consumer protection laws, including but not limited to:

The Florida Telephone Solicitation Act (FTSA), Florida Statutes § 501.059, which regulates certain telephonic sales calls and automated text messages sent to Florida residents.
The Florida Telemarketing Act, Florida Statutes §§ 501.601–501.626, and associated rules, to the extent our communications fall within those statutes.
The Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Florida Statutes §§ 501.201–501.213, which prohibits unfair or deceptive acts or practices in trade or commerce.
Florida’s data breach notification law, Florida Statutes § 501.171, which sets requirements for safeguarding and notifying individuals of certain security breaches involving personal information.

We are based in Hillsborough County, Florida, and our primary operations and communications are directed to our school community and associated members in Florida.

2. Information We Collect

We may collect the following categories of personal information when you subscribe to or interact with our email and SMS communications:

Contact Information
- Name (first and last)
- Email address
- Mobile phone number
- Mailing address
Student and Family Information (primarily collected via enrollment, but may be used for communications)
- Student names, grade levels
- Parent/Guardian names
- Emergency contact information
- School affiliation, class schedules, academic progress (for direct communications)
Demographic and Preferences (as voluntarily provided)
- Religious or spiritual affiliation (optional, for spiritual development support)
- Language preferences
- Volunteer interests or alumni status
Communication Preferences and Interaction Data
- Your subscriptions to specific lists or programs (e.g., grade-level alerts, sports teams)
- Records of your consent to receive emails and/or text messages
- Message delivery and engagement data (e.g., opens, clicks, responses, opt-out actions), subject to CAN-SPAM, TCPA, and applicable Florida law.
Technical Information
- When you interact with our school website or emails, we may collect device and usage information such as IP address, browser type, pages visited, and similar data, typically via cookies or analytics tools, subject to applicable privacy and cookie laws.

We do not intentionally collect sensitive personal information (such as Social Security numbers, financial account information, or health information, beyond what is necessary for student enrollment and safety) through our routine email and SMS marketing and notifications.

3. How We Use Your Information

We use the information described above for the following purposes, consistent with applicable law:

School-Related Email and SMS Communications
- To send academic updates, class announcements, homework reminders, and parent-teacher communication.
- To send school operational notifications, including administrative information, policy changes, and important deadlines.
- To send emergency alerts and safety notifications (e.g., school closures, security incidents) to students, parents/guardians, and staff.
- To send spiritual formation messages, inspirational content, devotionals, and updates on faith-based initiatives consistent with our mission as a Christian school.
- To send event announcements, reminders for school events (e.g., sports, arts, parent meetings, prayer gatherings), and volunteer opportunities.
- To send fundraising communications and appeals for school programs, scholarships, and facility improvements, supporting our not-for-profit mission.
Purpose of SMS Communications (Required Disclosure) We use SMS/MMS messages primarily for:
- Emergency Notifications: critical alerts for immediate safety concerns, school closures, or significant disruptions.
- Academic & Operational Updates: timely reminders for assignments, school deadlines, calendar changes, and administrative notices.
- Event Reminders: alerts for upcoming school events, sports games, performances, and parent meetings.
- Spiritual Encouragement: occasional faith-based messages and prayer requests relevant to our school community.
- Fundraising & Support: information about opportunities to support The Academy’s programs and mission.
Message Frequency Expectations (Required Disclosure)
- Message frequency may vary depending on your relationship with The Academy (e.g., parent, student, staff, general supporter) and the specific lists or programs you subscribe to.
- In general, you can expect:
  - Email: approximately emails per month, which may increase during high-activity periods (e.g., enrollment, events, emergencies).
  - SMS/MMS: typically up to messages per week, though frequency may increase temporarily during emergencies, specific event campaigns, or active school operational periods.
- We will make reasonable efforts to keep messaging within these expectations and will notify you if we plan to significantly increase frequency.
Legal and Administrative Purposes
- To maintain records of consent and communications consistent with the TCPA, CAN-SPAM, FTSA, and applicable Florida and federal laws.
- To protect our rights, property, and the safety of our school community, including students, staff, and families in Hillsborough County.
- To comply with legal obligations, court orders, or law enforcement requests.
Service Improvement
- To analyze engagement and improve the quality, relevance, and accessibility of our educational programs and communications.

4. Legal Basis and Consent for Communications (U.S. and Florida Law Context)

We operate our email and SMS programs in alignment with:

Telephone Consumer Protection Act (TCPA) and FCC rules, which generally require:
- Prior express consent for informational or non-marketing text messages to your wireless number.
- Prior express written consent for marketing or promotional text messages sent using an automatic telephone dialing system or prerecorded voice.
Florida Telephone Solicitation Act (FTSA), Florida Statutes § 501.059, and related Florida laws and regulations, which may require:
- Your prior express written consent before we send certain automated or prerecorded messages or use an automated system to dial or select your phone number for telemarketing or solicitation purposes.
- Clear disclosures about the nature of the messages and that consent is not a condition of receiving our educational services, unless text communication is itself an integral part of a school function and this is clearly disclosed.
CAN-SPAM Act, which requires:
- Accurate sender information and subject lines.
- Clear identification of commercial content where applicable.
- A functional and honored opt-out mechanism.

By providing your email address and/or mobile number and confirming your subscription, you consent to receive the types of email and SMS communications described in this Policy and our Terms of Service, in compliance with applicable federal law and Florida law.

5. SMS Disclosures and Your Choices

No Sale or Sharing of Mobile Numbers (Required Disclosure)
- We do not sell, share, rent, lease, exchange, or otherwise transfer your mobile phone number to unaffiliated third parties for their own telemarketing, solicitation, or commercial advertising purposes.
- Your mobile number is used solely:
  - To send communications from The Academy at True Sanctuary of Praise, Inc. and our authorized service providers acting on our behalf; and
  - For our internal administrative, safety, and compliance purposes.
Message and Data Rates May Apply (Required Disclosure)
- Standard message and data rates may apply to all SMS/MMS messages sent to or from us, as determined by your mobile carrier and your mobile service plan.
- We are not responsible for any charges related to your mobile carrier, including message or data fees, roaming charges, or other costs.
How to Opt Out of SMS Messages (Required Disclosure)
- You may opt out of receiving SMS/MMS messages from us at any time by:
  - Replying “STOP” to any text message you receive from us.
- After you send “STOP”, you may receive a final confirmation message stating that you have been unsubscribed and will no longer receive text messages, unless you later re-enroll.
- You may also contact us directly using the information in Section 12 (Contact Us) to request removal of your mobile number from our text messaging lists.
How to Opt Out of Email Messages
- Each marketing or promotional email we send includes an “unsubscribe” or “manage preferences” link at the bottom of the email.
- You may click the link to unsubscribe from some or all email lists.
- We will honor your request within a reasonable period of time, as required by the CAN-SPAM Act and applicable Florida consumer protection laws.

6. How We Share Your Information

We may share your information in the following limited circumstances:

Service Providers and Vendors
- We may share contact and communication data with third-party vendors who assist us in operating our email and SMS programs, such as:
  - Email service providers
  - SMS gateway providers
  - IT, hosting, and analytics providers
- These providers are authorized to use your information only as necessary to perform services on our behalf and are bound by contractual privacy and security obligations.
School Operations and Safety
- Within The Academy, information may be shared with necessary staff (e.g., teachers, administrators, medical personnel) to support student education, safety, and well-being.
Legal and Safety Reasons
- We may disclose information if required to do so by law or in good faith belief that such action is necessary to:
  - Comply with a legal obligation, subpoena, or court order.
  - Respond to lawful requests by public authorities, including law enforcement and child protection authorities in Hillsborough County, Florida or elsewhere in Florida.
  - Protect and defend our rights or property.
  - Protect the personal safety of our students, staff, and school community.
Business or Organizational Transitions
- In the unlikely event of a merger, consolidation, reorganization, or other change in organizational structure involving The Academy, your information may be transferred in accordance with applicable law and subject to privacy protections equivalent to or stronger than those described in this Policy.
No Third-Party Selling of Mobile Numbers
- As stated above, we do not sell or share your mobile number to third parties for their marketing or commercial use.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect the personal information we collect, transmit, and store, considering the nature of the information and the risks involved. These measures are intended to help prevent:

Unauthorized access
Disclosure or misuse
Loss, alteration, or destruction of personal information

For Florida residents, if we experience a data security incident that involves your personal information and meets the definition of a “breach of security” under Florida Statutes § 501.171, we will provide notice as required by Florida law, including the timing and method of notification and any notice to Florida state agencies, when applicable.

However, no system can be guaranteed to be 100% secure. You are responsible for safeguarding any devices or accounts that you use to receive our communications.

8. Data Retention

We retain personal information for as long as reasonably necessary to:

Fulfill the purposes described in this Policy and our educational mission;
Maintain records of consent and communication history required for compliance with TCPA, FTSA, CAN-SPAM, Florida Telemarketing laws, and other applicable laws;
Comply with legal, tax, audit, or school record retention requirements; and
Resolve disputes and enforce our policies.

When we no longer need personal information, we will securely delete, de-identify, or anonymize the data in accordance with our data retention and destruction policies and applicable law.

9. Children’s Privacy and Parental Consent

The Academy serves students, many of whom are under the age of 13. We understand the importance of protecting children's privacy.

For students under 13, parental consent is typically obtained during the enrollment process for the collection and use of personal information necessary for their education, safety, and school operations.
Our email and SMS communications are primarily directed to parents and legal guardians. While students may receive direct communications for academic or school operational purposes (e.g., class reminders), their enrollment in our general SMS or email lists for broader marketing or non-essential communications always requires prior verifiable parental consent.
We do not knowingly collect personal information online from children under 13 for marketing purposes without verifiable parental consent, and we adhere to the spirit of COPPA principles in protecting student data online.
If we learn that we have unintentionally collected personal information from a child under 13 without proper consent, we will take reasonable steps to delete such information promptly.

If you believe a child under 13 has provided us with personal information inappropriately, please contact us using the information in Section 12 (Contact Us).

10. Your Rights and Choices (Including Florida Resident Information)

Depending on your state of residence and our specific data practices, you may have certain rights under applicable state privacy laws (for example, under the California Consumer Privacy Act (CCPA) and similar statutes), such as the right to know, access, correct, or delete certain information, and the right to opt out of certain data uses.

Florida Residents – Additional Information

Florida residents are protected by, among other laws:

The Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Florida Statutes §§ 501.201–501.213, which prohibits unfair or deceptive acts or practices.
The Florida Telephone Solicitation Act (FTSA), Florida Statutes § 501.059, which sets rules for certain telephonic sales calls and automated text messages, including requirements for consent and restrictions on certain dialing technologies.
The Florida Telemarketing Act, Florida Statutes §§ 501.601–501.626, which governs certain telemarketing practices.

We design our email and SMS practices to avoid unfair or deceptive practices, to ensure that we have appropriate consent for marketing and automated text communications to Florida residents, and to honor your opt‑out choices promptly and accurately.

If you believe we have violated your rights under Florida law, you may:

Contact us using the information in Section 12; and
If unresolved, you may have the right to file a complaint with the Florida Attorney General’s Office or seek relief in a court of competent jurisdiction, as permitted by law.

To exercise any rights available to you under applicable state law or to ask questions about your information, please contact us using the information in Section 12. We may need to verify your identity before responding, consistent with applicable law.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Update the “Last updated” date at the top of this Policy; and
Provide additional notice as required by law (for example, via email, text message, or school website notice).

Your continued use of our email or SMS programs after any changes indicates your acceptance of the updated Policy.

12. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact:

The Academy at True Sanctuary of Praise, Inc.
Address:
Email:
Phone:

Florida residents who have concerns about our practices may also contact:

Office of the Attorney General, State of Florida
Consumer Protection Division
Website: https://www.myfloridalegal.com/
Phone: 1‑866‑9‑NO‑SCAM (1‑866‑966‑7226)