Privacy Policy

We collect information you provide directly to us, such as when you create an account, subscribe to our service, or contact us for support.

**Personal Information:** - Parent/guardian name and email address - Student first name, grade level, and target exam year - School information (optional) - Payment information (only after the beta ends — we do not collect or store any payment details from beta members)

**Usage Information:** - Learning progress and assessment results - Time spent on activities - Feature usage patterns - Device and browser information

SmartPrepAI is operated by Axient AI Pty Ltd, an Australian company. We are bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and the Notifiable Data Breaches (NDB) scheme administered by the Office of the Australian Information Commissioner (OAIC).

**Our APP Commitments:** - **APP 1 – Open and transparent management:** This policy describes how we manage personal information and how you can make a complaint. - **APP 2 – Anonymity and pseudonymity:** Where practicable, you may interact with us without identifying yourself. Student profiles use first names only. - **APP 3 – Collection of solicited personal information:** We only collect personal information that is reasonably necessary for our educational services. - **APP 5 – Notification of collection:** We notify you at or before the time of collection about what we collect and why. - **APP 6 – Use and disclosure:** We only use or disclose personal information for the primary purpose for which it was collected, or a directly related secondary purpose you would reasonably expect. - **APP 8 – Cross-border disclosure:** Where data is processed overseas (e.g. cloud hosting, AI providers), we take reasonable steps to ensure the overseas recipient complies with the APPs. - **APP 11 – Security of personal information:** We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access. - **APP 12 – Access to personal information:** You may request access to the personal information we hold about you at any time. - **APP 13 – Correction:** You may request correction of inaccurate or out-of-date information.

**Regulator:** The OAIC is the independent regulator responsible for privacy in Australia. If you are unsatisfied with our handling of your complaint, you may lodge a complaint with the OAIC at www.oaic.gov.au.

**Notifiable Data Breaches:** In the event of an eligible data breach likely to result in serious harm, we will notify affected individuals and the OAIC as required under the NDB scheme.

SmartPrepAI is committed to protecting the privacy of children. Our service is designed for use by students aged 8–17 under parent/guardian supervision.

**Our Commitments:** - We require verifiable parental consent before collecting any personal information from children - Parents can review, modify, or delete their child's information at any time - We do not condition participation on disclosure of more personal information than reasonably necessary - We use children's information only for the educational purposes described in this policy - Student accounts are linked to and controlled by parent accounts

**Data Minimisation:** We only collect the minimum information necessary to provide our educational services. Student profiles use first names only and do not require sensitive personal information.

**International Users:** For users in the United States, we also comply with the Children's Online Privacy Protection Act (COPPA) for children under 13. For users in the European Economic Area, we adhere to applicable GDPR requirements regarding children's data. These frameworks supplement our primary obligations under the Australian Privacy Act.

We use the information we collect to:

- Provide, maintain, and improve our educational services - Personalise learning experiences based on student performance - Generate progress reports for parents and students - Send transactional communications (account updates, subscription notices) - Respond to your questions and requests - Monitor and analyse trends and usage - Detect, investigate, and prevent fraudulent transactions and abuse - Comply with legal obligations under Australian law

We do not sell, trade, or rent your personal information to third parties.

**We may share information:** - With service providers who perform services on our behalf (payment processing, analytics, hosting) - To comply with legal obligations or respond to lawful requests from Australian courts or regulators - To protect our rights, privacy, safety, or property - In connection with a merger, acquisition, or sale of assets (with notice to you)

**Cross-Border Disclosure (APP 8):** Some of our service providers operate outside Australia (e.g. cloud infrastructure, AI model providers). Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs.

**We never share:** - Student learning data with advertisers - Personal information for marketing purposes without consent - Information with other users unless you explicitly choose to share

We implement appropriate technical and organisational measures to protect your information (APP 11):

- Encryption of data in transit (TLS/SSL) and at rest - Secure authentication mechanisms including leaked-password detection - Regular security assessments and audits - Employee training on data protection - Access controls limiting who can view personal information - Incident response procedures aligned with the Notifiable Data Breaches scheme

While we strive to protect your information, no method of transmission or storage is 100% secure. Please contact us immediately if you believe your account has been compromised.

We retain your information for as long as your account is active or as needed to provide you services (APP 11.2).

**Retention Periods:** - Account information: Duration of subscription plus 12 months - Learning progress data: Duration of subscription plus 6 months - Payment records: As required by Australian tax and accounting laws - Support communications: 24 months after resolution

**After Account Deletion:** - Personal information is deleted or anonymised within 30 days - Aggregated, anonymised data may be retained for research and improvement - Backup copies are purged within 90 days

Under the Australian Privacy Principles, you have the following rights regarding your information:

**Access (APP 12):** Request a copy of the personal information we hold about you **Correction (APP 13):** Update or correct inaccurate information **Deletion:** Request deletion of your personal information **Complaints:** Lodge a complaint with us or directly with the OAIC if you believe your privacy has been breached **Withdraw Consent:** Withdraw previously given consent at any time

To exercise these rights, contact us via our contact form (/contact?topic=privacy) or through your account settings.

**For international users:** If you are located in the EU/EEA, you may also have rights under the GDPR including data portability, restriction of processing, and the right to object. If you are located in the US, you may have additional rights under applicable state privacy laws.

We use cookies and similar technologies to:

- Remember your preferences and settings - Authenticate users and prevent fraud - Analyse how our service is used - Improve our platform

**Types of Cookies:** - Essential: Required for the service to function - Functional: Remember your preferences - Analytics: Help us understand usage patterns

You can control cookies through your browser settings, though some features may not function properly if cookies are disabled.

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

- Posting the new policy on our website - Sending an email notification to registered users - Displaying a prominent notice within the service

Your continued use of SmartPrepAI after changes become effective constitutes acceptance of the revised policy.

If you have questions about this Privacy Policy or our privacy practices, please contact us:

**Contact:** Use our contact form at /contact?topic=privacy **Mail:** Axient AI Pty Ltd (ABN 21 688 793 151) trading as SmartPrepAI, Sydney, NSW, Australia

**Privacy Officer:** For privacy-related inquiries, our Privacy Officer can be reached via /contact?topic=privacy&subject=Privacy%20Officer%20enquiry

**External Complaints:** Office of the Australian Information Commissioner (OAIC) Website: www.oaic.gov.au | Phone: 1300 363 992

We aim to respond to all inquiries within 10 business days.