Score — Privacy Policy

Controller / operator: BellieBub LLC, a Delaware limited liability company registered to do business in Texas ("BellieBub," "we," "us," "our"), operator of the Score platform and the Score Assistant AI feature (together, the "Services").

Contact: contact@schoolmusic.services · BellieBub LLC, 5930 Royal Ln. #154, Dallas, TX 75230 · Ray Everitt, Security Officer

Effective date: October 4, 2026 Last updated: October 18, 2026

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0. Reading this policy — current posture vs. future modes

Score is designed to serve two very different relationships, and this policy is written to the highest common denominator so it does not have to be rewritten as we grow:

• Today (current posture — "Mode A"): Score is offered on a freemium basis to adults only — music teachers, private studios, and their staff. We do not create accounts for children, and children do not use the Services directly. No student rosters, no student accounts, no student recordings. Teachers are instructed and technically prompted not to enter student personal information into the Services (see §6, AI features). Sections of this policy addressing children's data, schools, and parental rights describe how we will operate when those features launch; they are included now for transparency.
• Future (school mode / parent mode — "Mode B"): When we introduce school- authorized features (rosters, practice tracking, performance-assessment assistance) and/or a parent portal, additional terms take effect: our Data Processing Agreement governs school (FERPA) relationships, and verifiable parental consent governs any direct parent relationship (COPPA). Where a school or district signs our DPA, that agreement — not this policy — controls the handling of student data, and this policy yields to it for that data.

We will not silently expand data collection. Material changes are handled under §14.

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1. Who this policy covers

• Account holders and users of the Services (currently adult teachers/studio staff).
• Website visitors and waitlist sign-ups.
• Prospective and future school/district users and, in future modes, students and parents — the children's and schools' sections apply then.

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2. Information we collect

2.1 Information you provide

2.2 Information collected automatically

• Usage & telemetry: pages/tools used, feature events, timestamps, approximate request cost, performance metrics.
• Device & connection: IP address, browser/user-agent, device type, language.
• Cookies & similar technologies: strictly-necessary (auth/session, security), and — only with consent where required — analytics. We do not use advertising cookies or sell/share data for cross-context behavioral advertising. See §9.

2.3 Information we deliberately do not want (no-PII posture)

Score Assistant is engineered so that student personal information is not needed and is discouraged:

• Every input is scanned by an automated PII detector (names-in-context, emails, phone numbers, ID-like strings). Detected PII triggers an inline warning and a one-click "scrub to placeholder" action; the scrubbed text is what reaches the AI model.
• Communication drafts use merge placeholders ([STUDENT], [DATE]) rather than real names by design.
• Prompt content is not persisted by default (see §5).

This is a technical control, not merely a request. It is the foundation of our children's-privacy posture (§7).

2.4 Information from third parties (future modes)

When school features launch, we may receive student roster data from the school (via Clever/ClassLink or the school's upload) strictly to provide the service the school has authorized, under our DPA. We do not buy personal information from data brokers.

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3. How we use information

We use information to:

1. Provide, operate, secure, and improve the Services.
2. Authenticate users and protect against fraud, abuse, and security incidents.
3. Generate AI outputs you request (decision-support drafts for your review).
4. Process payments and manage subscriptions (via Stripe).
5. Send transactional messages (account, security, service notices) and, with any required consent, product/marketing messages you can unsubscribe from at any time.
6. Understand usage, measure cost, and prioritize the roadmap (aggregated/de-identified where feasible).
7. Comply with law and enforce our Terms and Acceptable Use Policy.

We do not:

• Sell personal information, or "share" it for cross-context behavioral advertising.
• Use Score Assistant content, or any student data, for retail/marketing purposes of any affiliated business (a contractual and architectural firewall).
• Allow our AI providers to train their models on your inputs or outputs (§6).
• Use student data for targeted advertising or to build non-educational profiles.

3.1 Legal bases (where applicable, e.g., EEA/UK visitors)

Contract performance (providing the Services), legitimate interests (security, product improvement, limited analytics), consent (marketing, non-essential cookies), and legal obligation. We are US-based and primarily serve US users; see §11.

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4. AI features and how your content is handled

• Purpose: Score Assistant is decision-support only. It drafts; the human educator decides. Outputs may contain errors and are not professional, legal, medical, or accreditation advice (see Terms §AI).
• Provider: prompts are routed through the Portkey LLM gateway to Anthropic's Claude commercial API. Direct Anthropic API access is a fallback path.
• No training on your content: under Anthropic's commercial terms, inputs and outputs are not used to train their models by default. We are pursuing a Zero Data Retention (ZDR) configuration for the student-facing pipeline.
• No student PII in prompts: enforced by the engineered scrub described in §2.3.
• Transparency: every AI output carries an AI-generated notice (TRAIGA-aligned). Our AI Trust and Transparency documentation, which describes these commitments in more detail, is available to schools and customers on request at contact@schoolmusic.services.

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5. Retention

We keep personal information only as long as needed for the purposes above, then delete or de-identify it. We do not retain data indefinitely.

Highlights (our full retention schedule is available to schools and customers on request at contact@schoolmusic.services):

• AI prompt content: not retained by default (processed transiently; not stored server-side unless you explicitly save an output).
• Saved outputs: retained until you delete them or close your account.
• Account data: for the life of the account + a short wind-down window after closure.
• Payment records: as required by tax/accounting law (via Stripe).
• Logs/telemetry: short, rolling windows; security logs longer where required.
• Student records (future modes): per the school's DPA and the retention schedule; deleted/returned on contract termination with a certificate of destruction.

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6. Your rights and choices

Depending on where you live (e.g., Texas TDPSA, California CCPA/CPRA, and similar state laws), you may have the right to:

• Access / know what personal information we hold about you.
• Correct inaccurate information.
• Delete your information.
• Portability — obtain a copy in a portable format.
• Opt out of sale/sharing/targeted advertising — we do none of these, but the right is honored as a no-op confirmation.
• Limit use of sensitive data (we minimize sensitive data by design).
• Non-discrimination for exercising rights.
• Appeal a denied request (we provide an appeal path and respond within the statutory window).

How to exercise: email contact@schoolmusic.services or use in-product controls. We verify requests before acting. Authorized agents may submit requests with proof of authority. We respond within the timeframes required by applicable law (generally 45 days, with an allowed extension).

Marketing opt-out: every marketing email has a working unsubscribe (honored within 10 business days, typically immediately). We send no marketing texts; for text messages, reply STOP to any text to opt out (see §15).

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7. Children's privacy (COPPA-ready — applies when child-facing features launch)

Current posture: the Services are not directed to children and do not knowingly collect personal information from children under 13. We do not create child accounts. Teachers are instructed and technically prompted not to enter student personal information. If we learn we have inadvertently collected a child's personal information without the proper authorization, we will delete it promptly.

When child-facing features launch, we will:

• Provide direct notice and obtain verifiable parental consent (VPC) before collecting personal information from a child under 13 — via the school-consent mechanism (COPPA §312.5(c)(6)) for school tenants, or a VPC method (e.g., card verification, knowledge-based authentication, government-ID match, or video-call) for direct-parent relationships.
• Obtain separate opt-in consent before disclosing a child's information to any third party, and name that party.
• Maintain a written information security program, summarized in §10 and available to schools and customers in full on request.
• Maintain a written, posted data-retention policy with no indefinite retention, summarized in §5 and available to schools and customers in full on request.
• Practice data minimization — collect only what the educational feature requires.
• Honor parental rights to review, delete, and refuse further collection of their child's information.

Parents/guardians and schools may reach us at contact@schoolmusic.services regarding a child's data.

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8. Schools, FERPA, and state student-privacy laws (future modes)

When a school or district uses Score, BellieBub acts as a "school official" performing an institutional service under FERPA (34 CFR §99.31(a)(1)), under the direct control of the school, using student data only for the authorized educational purpose, with no re-disclosure except as permitted. These commitments are papered in our Data Processing Agreement and applicable state riders covering New York Ed Law §2-d, Illinois SOPPA, California AB 1584/SOPIPA, Texas Ed Code §32.151, and others — available to schools on request at contact@schoolmusic.services. For school-provided student data, the DPA controls and this policy is secondary.

We do not sell student data, use it for targeted advertising, or build non-educational profiles of students.

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9. Cookies and tracking

We use strictly-necessary cookies (authentication, session, security) that do not require consent, and — where we use analytics — we honor consent requirements and Global Privacy Control (GPC) signals where applicable. We do not use advertising/tracking cookies. A detailed cookie notice will accompany the live policy.

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10. Security

We maintain administrative, technical, and physical safeguards aligned to the NIST Cybersecurity Framework, including encryption in transit and at rest, tenant isolation, least-privilege and managed-identity access control, audit logging, rate limiting, secret management in Azure Key Vault, and a documented incident-response process. No system is perfectly secure; we work continuously to protect your information. Our full written information security program is available to schools and customers on request at contact@schoolmusic.services.

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11. International users and data transfers

The Services are operated from the United States and hosted on Microsoft Azure (US regions) with subprocessors listed on our Subprocessors page. If you access the Services from outside the US, you understand your information is processed in the US. Where required, we implement appropriate transfer safeguards.

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12. Subprocessors

We use vetted service providers to operate the Services, including Anthropic (AI), Portkey (LLM gateway), Microsoft Azure (hosting), Stripe (payments), SendGrid (email), and Twilio (text messages). The current list, with purpose and location, is maintained on our Subprocessors page. Providers are bound by contract to protect data and use it only to provide their service to us.

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13. Third-party links

The Services may link to third-party sites we do not control; their privacy practices are their own. Review their policies.

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14. Changes to this policy

We will update this policy as the Services evolve (notably when school/parent modes launch). For material changes — especially any that expand data collection or affect children's data — we will provide prominent notice and, where legally required, obtain consent before the change takes effect. The "Last updated" date always reflects the current version, and prior versions are available on request.

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15. Text messages (SMS)

Score can send text messages to parents and guardians on behalf of a music studio. This section explains that program. It applies only to text messages; the rest of this policy applies as well.

What we text. With your opt-in, Score texts the phone number on your family profile about:

• lesson reminders;
• schedule changes and cancellations;
• makeup lessons;
• bills and payment due notices;
• event changes;
• one-time sign-in codes, sent only when you ask for one on the Score sign-in page; and
• your studio's invitation to see your child's lessons on Score. We do not text an invitation until you have opted in to texts. Before then, the studio's invitation goes by email or as a link the teacher gives you.

We do not send marketing or promotional texts.

How you opt in. You opt in yourself, on your Score family page, by agreeing to the text-message consent shown there. Score records the time and the wording you agreed to. Agreeing is not required to use Score or to buy anything.

Message frequency varies. It depends on your studio's lessons, events and billing.

Message and data rates may apply. Your mobile carrier may charge for texts you receive and send.

Stop or get help. Reply STOP to any text to opt out. We will confirm by text, and you will get no more family texts from Score. Reply HELP for help. You can also email contact@schoolmusic.services. You can turn texts back on from your Score family page.

Sharing. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

We use our messaging provider, Twilio, only to deliver your texts (see Subprocessors). We keep your phone number, your consent record and a record of your opt-out so that we can honor your choices.

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16. Contact and complaints

• Email: contact@schoolmusic.services
• Mail: BellieBub LLC, 5930 Royal Ln. #154, Dallas, TX 75230, USA
• Privacy contact: Ray Everitt, Security Officer

You may also have the right to lodge a complaint with your state Attorney General (e.g., the Texas Attorney General for TDPSA matters) or the FTC.

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Approved for publication by Ray Everitt, 2026-10-18.