Enhance Education Privacy Policy

1. Introduction and scope

Enhance Education Tuition Pty Ltd (ABN 35 690 982 622), trading as Enhance Education ("we", "us", "our"), is a specialist HSC Biology tutoring centre. We are committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This policy explains what personal information we collect, how we collect and use it, who we may share it with, and how you can access, correct, or complain about our handling of it. It applies to our website at https://enhanceeducation.com.au to enquiries and enrolments, to the classes and resources we provide, and to any tools on our website, including the ATAR calculator.

By using our website or services, or by providing personal information to us, you agree to the handling of that information as described in this policy.

2. What personal information we collect

Depending on how you interact with us, we may collect:

• Identity and contact details: name of the student and of the parent or guardian, email address, phone number, and postal or home suburb.
• Student details: year level, school, subjects studied, and information relevant to providing tutoring and personalised support.
• Health and emergency information: limited health information provided at enrolment, such as allergies and any underlying medical conditions (for example asthma), and emergency contact details.
• Enquiry and enrolment content: the information you provide when you make an enquiry, book a class, or enrol, including any messages you send us.
• Payment information: details necessary to process fees. Card and bank details are handled by our payment processor (see section 6); we do not store full card numbers ourselves.
• Class recordings: our classes are delivered both in person and online at the same time, and the online session is delivered and recorded through Zoom. These recordings may capture a student's voice, including an in-person student whose question or contribution is picked up by the Zoom session, as well as an online student's voice and their image if they turn their camera on. Recordings may be made available to enrolled students afterwards as a learning resource, which means a student's contribution captured in a recording may be seen or heard by others in the class. Recordings are personal information and are handled under this policy.
• ATAR calculator information: the ATAR estimate is shown for free without collecting personal information. If you choose to opt in to receive a detailed breakdown, analysis, or recommendations, we collect your name and email address, and we store the subjects you selected and the estimated marks you entered so that we can prepare and send that breakdown. Nothing from the calculator is stored unless you opt in. The calculator produces an estimate from the information you enter. It is a self-service study guide and is not used to make any decision about you, your enrolment, or your access to our services.
• Website and technical information: information collected automatically through cookies and analytics tools, such as your device and browser type, IP address, pages visited, and how you use the site (see section 8).
• Photographs and images: where you give express, opt-in consent, a student's photograph, image, or likeness, which we may use in our marketing or media as described in section 4. This consent is voluntary and separate from enrolment, and you can withdraw it at any time.

Health and sensitive information. At enrolment we collect limited health information about the student, such as allergies and any underlying medical conditions we should be aware of (for example asthma), together with emergency contact details. We collect this with the consent of the parent or guardian and use it only to support the student's safety and welfare and to respond appropriately in an emergency. Health information is sensitive information under the Privacy Act, and we handle it accordingly. Apart from this, we do not generally seek sensitive information; if you choose to share other sensitive information, such as an accessibility need or learning requirement so that we can support a student, we treat it as sensitive information, collect it only with consent, and use it only for that purpose.

3. How we collect personal information

We collect personal information:

• Directly from you: through website enquiry and enrolment forms (including the health and emergency information described in section 2), by phone, by email, and in person at our centre.
• Through the ATAR calculator: only where you opt in to receive a detailed breakdown, as described in section 2.
• During classes: through Zoom recordings of lessons, which are delivered in person and online at the same time, as described in section 2.
• Automatically: through cookies, analytics, and similar technologies when you use our website (see section 8).
• From a parent or guardian, or from a student: where a parent or guardian provides information about a student, or a student provides information about a parent or guardian, in the course of an enquiry or enrolment.

Where it is reasonable and practicable, we collect personal information directly from the individual it concerns or, for a student under 18, from their parent or guardian.

4. Purposes for which we collect and use personal information

We collect, hold, and use personal information to:

• provide, administer, and improve our tutoring services, classes, and resources;
• respond to enquiries and provide personalised support;
• process enrolments, fees, and payments;
• record online classes for teaching, review, and to make lessons available to enrolled students as a learning resource;
• prepare and send the ATAR breakdown, analysis, or recommendations that a user has opted in to receive, and to follow up with that user about our services;
• send information and marketing about our services, where permitted (see section 7);
• understand and improve how our website is used, through analytics;
• use a student's photograph, image, or likeness in our marketing or media, only where express, opt-in consent has been given and not withdrawn;
• look after the health, safety, and welfare of students, including responding appropriately in a medical emergency;
• maintain the safety, conduct, and proper operation of our classes and website; and
• meet our legal and regulatory obligations.

We only use personal information for the purposes for which it was collected, for a directly related purpose you would reasonably expect, or as otherwise permitted by law or with your consent.

5. Children and minors

Our students are commonly under 18 years of age. We take particular care with their personal information.

• Where a student is under 18, we expect that a parent or guardian consents to the collection of the student's personal information and provides much of that information on the student's behalf.
• A parent or guardian may exercise the rights in this policy (including access, correction, and withdrawal of consent) on behalf of a student under 18.
• We collect only the personal information reasonably necessary to provide our services to the student, and we do not knowingly collect more than that from a child.
• If a student under 18 uses the ATAR calculator and opts in to receive a detailed breakdown, the parental consent expectations above apply.

If you believe we have collected personal information from a child without appropriate parental or guardian consent, please contact us using the details in section 14 and we will take reasonable steps to address it.

6. Disclosure of personal information

We may disclose personal information to third parties who help us run our business and deliver our services, including:

• Payment processor: Stripe, to process fees and payments. We may add Ezidebit as an additional payment processor in future.
• Customer relationship and email provider: HubSpot, which receives leads from the ATAR calculator opt-in and from general website forms, and which we use to manage communications.
• Learning management system: Canvas, operated by Instructure, used to deliver classes and resources.
• Video conferencing and recording: Zoom, used to deliver and record online classes.
• Analytics providers: Google (Google Analytics), which is used on our website. We may add further analytics or advertising tools, such as Meta Pixel, in future (see section 8).
• IT, hosting, and website providers: including our website host and other IT and website service providers.
• Professional advisers: such as accountants and lawyers, where reasonably necessary.
• Government, regulatory, or law enforcement bodies: where required or authorised by law.

We do not sell your personal information. Where we disclose information to a third party, we take reasonable steps to ensure it is handled consistently with this policy and the APPs.

7. Direct marketing and how to opt out

We may use your contact details to send you information and marketing about our services, classes, resources, and offers, where the law permits and, where required, with your consent. Users who opt in through the ATAR calculator may receive follow-up communications about how we can help.

You can opt out of marketing at any time by using the unsubscribe link in any marketing email, or by contacting us using the details in section 14. We will action your request within a reasonable time. Opting out of marketing does not affect communications we need to send you about a current enrolment or service.

8. Cookies, analytics, and tracking technologies

Our website uses cookies and similar technologies to help the site function, to remember your preferences, and to understand how the site is used. We currently use Google Analytics to understand how visitors use our site. We may add further analytics or advertising tools, such as Meta Pixel, in future; if we do, we will update this policy and put appropriate consent controls in place beforehand. These tools may collect information such as your device and browser type, IP address, and the pages you view.

You can control cookies through your browser settings, and through any cookie or consent banner presented on our website. You can also opt out of certain analytics tracking through the tools the provider makes available, for example Google's analytics opt-out. Disabling some cookies may affect how the website works.

9. Storage, security, and retention

We take reasonable steps to protect personal information from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. These steps include appropriate technical and organisational measures and limiting access to those who need it to do their work. Where personal information is held by a third-party provider (see section 6), that provider maintains its own security measures.

We keep personal information for as long as it is needed for the purposes described in this policy, or as required by law. Information captured through the ATAR calculator opt-in (name, email, selected subjects, and estimated marks) is held in our CRM, HubSpot, and may be used to contact you about our services. We retain it for up to 24 months from your last interaction with us, after which we delete or de-identify it, unless you have enrolled with us or asked to keep hearing from us. You can request deletion at any time using the details in section 14. Zoom class recordings are retained for up to 24 months and are then deleted.

If a data breach occurs that is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

10. Overseas disclosure

Some of the third-party providers we use (see section 6) may store or process personal information outside Australia, including in the United States. This may apply to providers such as HubSpot, Stripe, Google, Instructure (Canvas), and Zoom. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure it is handled consistently with the APPs.

At the time of writing we are not able to confirm precisely which providers store data in Australia and which store it overseas.

11. Access and correction

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading. For a student under 18, a parent or guardian may make this request on the student's behalf.

To make a request, contact us using the details in section 14. We may need to verify your identity before responding. We will respond within a reasonable time. If we decline a request for access or correction, we will explain our reasons, except where the law provides otherwise.

12. Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us first using the details in section 14. We will investigate and respond within a reasonable time.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). You can find the OAIC's contact details and complaint process at oaic.gov.au.

13. Changes to this policy

We may update this policy from time to time. The current version will always be available on our website, with the "last updated" date shown at the top. Where changes are significant, we will take reasonable steps to notify you.

14. Contact us

For any privacy question, request, or complaint, please contact:

• Entity: Enhance Education Tuition Pty Ltd, trading as Enhance Education
• ABN: 35 690 982 622
• ACN: 690 982 622
• Registered address: 103/8 French Avenue, Bankstown NSW 2200
• Privacy contact email: admin@enhanceeducation.com.au
• Phone: 0433 577 525
• Website: https://enhanceeducation.com.au