Privacy Policy
1. Who we are
This Privacy Policy explains how the proprietor trading as Summit Learning (we, us, our), ABN 32 691 358 880, collects, uses, discloses and protects personal information in connection with the Summit Learning platform (the Service). We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and, as it applies, the Privacy (Children's Online Privacy) Code.
2. Our commitment to children
The Service is designed to be used by school-aged children under parental supervision. We recognise that children's personal information deserves extra protection. In particular we aim to:
- Act in the best interests of the child when we decide whether and how to collect, use or disclose their information;
- Collect only what is reasonably necessary to provide the Service (data minimisation);
- Obtain parental consent for children under 15, and take reasonable steps to confirm that the person giving consent has parental responsibility;
- Not use children's personal information for direct marketing or targeted advertising, and not sell it;
- Set privacy-protective defaults and explain our practices in clear, age-appropriate language where we communicate with children.
3. Information we collect
| Category | Examples | Why |
|---|---|---|
| Account holder (parent) details | Name, email address, login credentials, billing information processed by our payment provider | To create and manage the account, communicate with you, and process payments |
| Student details | First name or display name, year level, username and PIN, the parent it is linked to | To set up the student's learning space and show the right activities |
| Learning activity | Activities attempted, scores, progress, streaks, time of use | To track progress, adapt difficulty, and report progress to the parent/tutor |
| Technical data | Device/browser type, general log and usage data | To operate, secure and improve the Service |
We do not ask children to provide more personal information than is needed to use the Service, and we ask account holders not to enter sensitive information (such as health information) into free-text fields.
4. How we collect it
We collect information directly from the account holder when they register, set up a student, and use the Service; automatically as the Service is used (for example progress and basic technical data); and occasionally from you when you contact us for support.
5. How we use it
- To provide, personalise, maintain and improve the Service;
- To track and report a student's learning progress to their parent or tutor;
- To process payments and manage subscriptions;
- To communicate with the account holder about the Service (for example service and account messages);
- To keep the Service safe and secure and to comply with our legal obligations.
We do not use children's personal information for behavioural advertising, and we do not sell personal information.
6. When we disclose it
We disclose personal information only as needed to run the Service, including to: the parent/guardian and any tutor linked to a student (so they can see progress); our service providers (such as hosting, database and payment providers) who are bound to protect it; and government or law-enforcement bodies where required or authorised by law. We take reasonable steps to ensure any provider located overseas handles personal information consistently with the APPs.
7. Parental rights & control
A parent or guardian may, at any time, ask us to: access the personal information we hold about them or their child; correct it if it is inaccurate; delete a student profile and its associated data; or withdraw consent and close the account. To make a request, contact us using the details below. We will respond within a reasonable time and may need to verify your identity and parental responsibility first.
8. Security & retention
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including access controls and use of reputable hosting and database providers. No system is completely secure, so we cannot guarantee absolute security. We keep personal information only for as long as it is needed to provide the Service or as required by law, and then take reasonable steps to delete or de-identify it.
9. Cookies & similar technologies
The Service uses cookies and similar technologies (such as browser storage) that are necessary to keep you logged in and to operate the Service. We do not use third-party advertising or cross-site tracking cookies.
10. Changes to this policy
We may update this Privacy Policy from time to time. If we make a material change we will take reasonable steps to notify the account holder (for example by email or an in-Service notice). The "last updated" date above shows when it was last revised.
11. Complaints & contact
If you have a question or wish to make a privacy complaint, contact us at summittutoring@outlook.com. We will acknowledge and investigate your complaint and respond within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.