Privacy Policy

1. Who We Are

Lee Thomas IT Operations, LLC and Lee Thomas IT Financial, LLC (collectively, “Lee Thomas IT,” “we,” “our,” or “us”) operate the website and education platform accessible at leethomas.dev and school.leethomas.dev. We provide AI education services and retail installment financing under our Credit Path program.

2. Information We Collect

We collect personal information that you provide to us directly, which may include:

• Full legal name and email address
• Social Security Number (SSN) — collected for credit reporting and Metro 2 tradeline establishment
• Date of birth
• Phone number
• Residential address (street, city, state, ZIP)
• Employment status and monthly income range
• Payment information (processed through Stripe — we do not store full card numbers)
• Course progress, module completions, and platform activity

We also collect standard server-side analytics (pages visited, device type, referral source) to improve our platform.

3. How We Use Your Information

• To process your credit application and originate your retail installment agreement
• To submit Metro 2-formatted tradeline data to credit bureaus through CHASE, our processing agent
• To process payments through Stripe
• To provision and manage your school access on school.leethomas.dev
• To send enrollment confirmations, billing notices, and material account updates
• To provide grants identification assistance inside your student portal
• To comply with applicable federal and state law, including the Fair Credit Reporting Act (FCRA) and Regulation B

4. Credit Bureau Reporting

If you enroll in the Credit Path program, your retail installment account will be reported monthly to Equifax, Experian, and TransUnion via Metro 2 credit reporting format. CHASE serves as our processing agent for Metro 2 submission. We report positive payment history and will never report a negative tradeline upon non-renewal of the Deferred Balance provision, as specified in your Retail Installment Agreement and Deferred Balance Addendum.

5. Information Sharing

We do not sell your personal information. We share your information only to the extent necessary to operate our services:

• Stripe — payment processing (subject to Stripe’s own Privacy Policy)
• Supabase — database hosting for account and application data
• CHASE — Metro 2 processing agent for credit bureau reporting
• Credit bureaus — Equifax, Experian, and TransUnion, as described above
• Legal process — as required by law, court order, or regulatory authority

We do not share your information with any other third party without your explicit consent.

6. Data Retention

• Credit application data — retained for a minimum of 25 months from the date of application, as required by Regulation B (Equal Credit Opportunity Act).
• Payment and financial records — retained for 7 years to comply with IRS recordkeeping requirements.
• School access and account data — retained while your account is active, plus 2 years following account closure.

Retention periods may be extended where required by applicable law or pending legal proceedings.

7. Data Security

We use industry-standard security practices to protect your personal information, including:

• Encrypted connections (TLS) for all data in transit
• Encryption of sensitive data at rest
• Access controls limiting who within our organization can access personal data
• No storage of full payment card numbers on our servers

No method of transmission or storage is completely secure. If you have reason to believe your data has been compromised, contact us immediately at oliver@leethomas.dev.

8. California Residents — CCPA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to Know — you may request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete — you may request deletion of your personal information, subject to exceptions required by law (including financial recordkeeping and credit reporting obligations).
• Right to Opt Out of Sale — we do not sell your personal information. If this policy changes, we will provide a prominent opt-out mechanism.
• Right to Non-Discrimination — we will not discriminate against you for exercising your CCPA rights.

To exercise your CCPA rights, contact us at oliver@leethomas.dev. We will respond within 45 days.

9. Your FCRA Rights

If we have reported information about you to a credit bureau, you have rights under the Fair Credit Reporting Act (FCRA), including:

• The right to know what information we reported to credit bureaus.
• The right to dispute inaccurate or incomplete information. To initiate a dispute, contact us at oliver@leethomas.dev with the specific information you believe is inaccurate. We will investigate and respond within 30 days.
• The right to have inaccurate information corrected or deleted.

You also have the right to contact the credit bureaus directly: Equifax (equifax.com), Experian (experian.com), and TransUnion (transunion.com).

10. Your Other Privacy Rights

You may request access to, correction of, or deletion of your personal data by contacting us at oliver@leethomas.dev. Note that some information must be retained for legal, regulatory, and financial recordkeeping purposes as described in Section 6 above. Credit bureau reporting obligations may also survive account closure.

11. Cookies

We use session cookies to maintain your logged-in state on our platform. We do not use third-party advertising cookies or behavioral tracking cookies across other websites.

12. Children

Our services are not directed to anyone under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has submitted information to us, contact us immediately so we can delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by email to the address associated with your account. Continued use of our services after the effective date of a material change constitutes acceptance of the updated policy.

14. Contact

Lee Thomas IT Operations, LLC
[LT_IT_OPERATIONS_ADDRESS]
Email: oliver@leethomas.dev
Governing law: Wyoming