DRAFT: not yet reviewed by a lawyer
This document is a working draft for the trial version of Focus Academic Coaching. It has not had legal review and may change before the site is launched. Words in [square brackets] still need to be filled in.
Privacy Policy
Version: 2026-11-02-draft
1. About this policy
Focus Academic Coaching ("we", "us") is an online practice-test service for students in Years 4 to 10, run by [business name] (ABN [number]). This policy explains what personal information we collect, why we collect it, and how we look after it. We aim to handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
Because our users include children, we collect as little information about children as we can, and we only collect it with the consent of a parent or legal guardian.
2. What we collect
About parents and guardians:
- your email address;
- your password, stored only as a one-way scrambled form (a "hash") that nobody can read;
- the date and time you agreed to this policy, the Terms of Use and the consent for your children;
- your subscription status (for example, free trial) and, once paid plans start, payment records from our payment provider. We will not store your full card number.
About children (added by their parent or guardian, or by their tutor):
- a first name or nickname (we ask you not to give a surname);
- their school year;
- a PIN, stored only as a one-way hash;
- their answers, scores, time taken and writing responses, and any marks and feedback from a tutor.
We do not ask children for their email address, full name, date of birth, school, address, photos or location.
Technical information: to keep accounts safe, we briefly keep the internet (IP) address used for log ins so we can block repeated wrong passwords or PINs. We do not use it to track you.
3. Why we collect it
- to create and run your account and your children's accounts;
- to mark practice tests and show results, progress over time and topics to practise;
- to send you emails about your account (for example, confirming your email or resetting your password);
- to protect accounts from misuse;
- once paid plans start, to manage your subscription.
We do not sell personal information. We do not show advertising, and we do not use children's information for marketing or to build advertising profiles.
4. Consent for children
When you create a parent account, you confirm that you are 18 or older and the parent or legal guardian of each child you add, and you consent to us handling your children's information as set out in this policy. You can change or delete a child's details, or delete a child's account, at any time from your parent dashboard.
5. Who we share it with
We only share personal information with service providers who help us run Focus Academic Coaching, and only as much as they need. These may include:
- website hosting: Vercel Inc. (a United States company), which runs our website on servers in Sydney, Australia;
- database and file storage: Supabase Inc. (a United States company), which stores our database, pictures and backups in Sydney, Australia;
- account emails: Amazon Web Services (Amazon SES), which sends our emails from Sydney, Australia. Emails contain your email address and links, never your children's results;
- a payment provider (planned: Stripe), once paid plans start: [country].
We chose the Sydney region of each provider so that your information is stored in Australia. Because these companies are based overseas, their staff may be able to access it to provide support. If any of these providers store information outside Australia, we will name the countries here and take reasonable steps to make sure they protect it (APP 8). We may also share information if the law requires it.
6. Cookies
We only use cookies that the site needs to work: log in cookies for parents, students and the tutor (they last up to 7 days).
We do not use advertising or tracking cookies.
7. How we keep it safe
Passwords and PINs are stored as one-way hashes. Log in cookies are protected so they can't be changed. Wrong passwords and PINs are limited. Links in account emails work only once and end after a short time. No system is perfectly secure, but if a data breach is likely to cause serious harm, we will tell you and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme.
8. How long we keep it
We keep your information while your account is open. If you ask us to delete your account, we delete your account, your children's accounts and all of their results 14 days later (you can cancel during that time). We keep a short record that a deletion was requested and completed, without your email or any names. We make a backup copy of the site's data every night and keep each copy for 30 days, so deleted information is also gone from every backup within 30 days of being deleted. [Add how long payment records must be kept for tax purposes, once paid plans start.]
9. Seeing, correcting and deleting your information
You can see and correct your children's details and results in your parent dashboard, and ask for your whole account to be deleted under Account and privacy. You can also contact us to ask for a copy of the information we hold about you or your children, or to correct it (APPs 12 and 13).
10. Questions and complaints
Contact us at 학부모 문의용 이메일 (예: Gmail). We will reply within 30 days. If you are not happy with our reply, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
11. Changes to this policy
If we make important changes, we will tell parents by email or on the site before the changes start, and ask for your agreement again where needed.