Privacy policy

The short version

• We collect what we need to teach, and little else. We ask for a student’s year level, not their date of birth.
• We never sell personal information, show ads, use advertising trackers or market to children.
• Students’ questions, answers and conversations are not used to train AI models, by us or by our AI providers.
• Names, email addresses and school names are not sent to AI models.
• Children under 15 need a parent’s consent before they can use the tutor or upload photos. Schools consent for class accounts.
• From launch, our data is stored in Australia.
• You can see, download, correct or delete your information. We act on deletion requests within 30 days.

For students: the short version

Who we are and how to contact us

“Pencilwick”, “we” and “us” means [legal entity name and ABN to be confirmed], the operator of Pencilwick.

Our Privacy Officer can be contacted at privacy@pencilwick.com or [postal address to be confirmed].

Laws and codes we follow

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). [Legal review: confirm whether we are covered by turnover, or opt in under section 6EA. We intend to comply with the APPs either way.]
• The Children’s Online Privacy Code being developed by the Office of the Australian Information Commissioner (OAIC). The Code is in draft; we are designing to the exposure draft now and will update this policy when the final Code is registered.
• The Notifiable Data Breaches scheme.
• The Spam Act 2003 (Cth) for any emails we send.
• For class accounts, the privacy requirements in our agreement with the school or education system.

What we collect

Account details

• A display name and email address. Students in class accounts may use a school email.
• A password, which we store only as a one-way scrypt hash. We can’t read it.
• Role (student, parent, teacher), year level, state or territory, preferred language and, optionally, school name.
• An age band (under 15, 15 to 17, or adult). We do not ask for a date of birth.
• For students under 15, a parent’s email address, and a record of the parent’s consent.

Learning records

• Lessons started and finished, practice attempts and answers, hints used, time spent, flashcards and reviews.
• Mastery levels for each content description, worked out from those attempts.
• For class accounts: class membership, assigned tasks and progress on them.

What students give us

• Messages to the tutor.
• Photos taken for Snap & Solve. We delete the photo once the question has been read and keep only the text of the question.
• Files uploaded to make notes and flashcards, such as PDFs, photos of notes and typed text, and essays sent for feedback.

Teachers and parents

• Teachers: classes, the resources they create and save, and assignment settings.
• Parents: the children linked to their account, consent decisions and notification preferences.

Payments

Payments are handled by our payment provider, [Stripe Payments Australia, to be confirmed]. We receive the plan, billing status, renewal date and a payment reference. We never see or store full card numbers.

Technical information

• A session cookie that keeps you signed in, and the browser type for that session.
• IP addresses and request logs, used for security, rate limiting and fixing faults.

What we don’t collect

Date of birth, precise location, contacts, advertising identifiers, biometric information, or audio. If we ever add features that need any of these, we’ll ask first and update this policy.

How we collect it

Mostly directly from you as you use Pencilwick. Some comes from a parent (consent, linked children) or a school (class lists for class accounts). Technical information is collected automatically when your browser talks to our servers.

How we use it

• To provide Pencilwick: lessons, practice, the tutor, Snap & Solve, notes and flashcards, and teacher tools.
• To adapt learning: choosing practice and reviews based on what a student has mastered.
• To show progress to the student, their linked parent and, for class accounts, their teacher.
• To keep students safe: screening messages for signs of harm, removing personal details before messages reach an AI model, and alerting a parent or teacher when needed.
• To run accounts and subscriptions, send service emails (such as renewal reminders and consent requests), and answer support requests.
• To protect Pencilwick from misuse, and to find and fix faults.
• To improve Pencilwick, using de-identified and aggregated information wherever we can.
• To meet legal obligations.

We never sell personal information, use it for advertising, build marketing profiles of children, send direct marketing to anyone under 18, or use students’ content to train AI models. Marketing emails to parents and teachers are opt-in.

AI and automated decisions

Some Pencilwick features use large language models provided by [AI provider(s) to be listed with locations]. When a student uses the tutor or Snap & Solve, we send the model the question or message, the year level, state and preferred language. We remove names, email addresses, phone numbers and street addresses first. We do not send account names, emails or school names.

Our contracts with AI providers will require that our data is not used to train their models and is not kept longer than needed to answer the request. [Legal review: confirm provider terms and retention.]

Pencilwick makes some decisions automatically:

• Mastery levels, worked out from a student’s answers over time.
• Recommendations for which lesson, practice or review to do next.
• Safety screening of messages, which can pause the tutor and alert a parent or teacher.

These decisions use learning records and the content of messages. You can ask us to explain a decision or have a person review it by emailing our Privacy Officer.

Children and consent

• Under 15: a parent or carer must consent before the student can use the tutor or upload files. We email the parent a consent link and ask them to confirm they have parental responsibility. Until then, lessons and practice still work. When a parent consents, we tell the student, in words they can understand.
• 15 to 17: students can consent for themselves. We give them short, plain notices. Linking a parent is optional, and the student can see that it has happened.
• Class accounts: the school is responsible for consent, following its own state or sector process.
• Monitoring: students are always shown who can see their tutor conversations.
• Age: we ask for year level and age band at sign-up and apply child protections to every student account, rather than using intrusive age checks.

Who we share it with

• Parents and teachers, as described above and on our safety page.
• Service providers who help us run Pencilwick: hosting, AI models, email delivery and payments. They may only use information to provide their service to us. We will publish a list of these providers and where they process data.
• Schools, for class accounts under their agreement with us.
• Authorities, where the law requires it, or where we reasonably believe it is needed to lessen a serious threat to someone’s life, health or safety. This can include child protection services or police.
• A buyer of our business, only if this policy continues to apply, and after we tell you.

Where it’s stored

From launch, Pencilwick’s application, databases, backups and logs will be hosted in Australian data centres.

We intend to use Australian processing regions for AI models wherever they are available. Where any personal information is processed outside Australia, for example by an AI or payment provider, we will name the country in our provider list, take reasonable steps under APP 8 to make sure it is protected, and remain accountable for it. [Legal review: confirm each provider’s processing location.]

How long we keep it

Security

We protect information with technical and organisational measures, including hashed passwords, secure session cookies, encryption in transit and at rest, access limited to staff who need it, multi-factor sign-in for staff, and audit logs.

If a data breach is likely to cause serious harm, we will notify affected people and the OAIC as the Notifiable Data Breaches scheme requires, and tell you what we are doing about it.

Your rights

You, or a parent on behalf of a child, can:

• see and download the information we hold;
• correct information that is wrong;
• ask us to delete it, which we do within 30 days unless the law requires us to keep something;
• withdraw consent, which turns off the features that depend on it.

Most of this can be done from account settings. Otherwise, email privacy@pencilwick.com. We may need to confirm your identity first. There is no charge.

Cookies and browser storage

Pencilwick uses one essential cookie to keep you signed in. It also saves small preferences in your browser, such as light or dark theme. We do not use advertising or cross-site tracking cookies. If we add analytics, it will be privacy-preserving and we will update this policy first.

Complaints

If you’re unhappy with how we’ve handled personal information, contact our Privacy Officer. We’ll acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you’re not satisfied, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

Changes to this policy

We’ll email account holders at least 30 days before a material change takes effect, with a plain-language summary and a version for students. We complete a privacy impact assessment before launch and before any material change to how we handle personal information.