Privacy Policy

1. About This Policy

1.1       'The Business' means Daniel Agnew, trading under the registered business name Master Spiralling Upwards (ABN 46 218 839 945).

1.2       This Privacy Policy explains how the Business collects, uses, discloses, and protects personal information in connection with its English tutoring services and its website material service (videos, worksheets, and applications), together with general use of the Business's website.

1.3       This Policy applies together with the Terms and Conditions of English Lessons, the English Lesson Policy, and the Website Material Terms and Conditions.

2. Information Collected

2.1       The Business collects personal information such as a Client's, Student's, or Customer's name, contact details (such as an email address), age, primary language, and interests, to provide and personalise its services.

2.2       Payment-related information is collected by the Business's payment providers when a payment is made. Some payment methods may require more information than others — for example, some methods may require a name and address and some may not. The Business recommends choosing whichever payment method best matches your preference for how much information to provide.

2.3       A Customer's writing or other content submitted to an application for feedback, analysis, or another output (such as the Business's native-speaker or business-English tools) is collected and processed to generate that output, in accordance with the Website Material Terms and Conditions.

2.4       Where a Lesson is recorded, the Business may collect an audio, video, or audiovisual recording of the Lesson, which may include the image, voice, words, and other personal information of the Client, Student, or Tutor. Lessons are not ordinarily recorded, and recording will only occur where the applicable lesson arrangements permit it and the relevant participants have agreed in advance, in accordance with the English Lesson Policy and, where applicable, the Child Tutoring Agreement.

2.5       Where a Lesson is recorded, the recording is collected and processed for the purposes for which the recording was agreed, such as allowing participants to review the Lesson, supporting tutoring or progress discussions, or providing the agreed recording to participants.

2.6       The Business collect general information about how visitors use its website, such as page views and interactions with website elements, generally in aggregate form with limited or no personal information.

2.7       Where possible, the Business configures its systems to store de-identified information, or information with personal details reduced — for example, using a Student's first name and the initial of their last name, rather than their full name, where this is sufficient for the Business's purposes.

3. Children's Personal Information

3.1       A Client may access, correct, or request the deletion of personal information of a child under their care by contacting us, as set out in clause 11 (Your Rights) and clause 13 (Contact Options and Complaints).

4. How Your Information Is Used

4.1       The Business uses personal information to provide, personalise, and improve its English tutoring services and website material service, including scheduling Lessons, generating Automated Output, and responding to enquiries.

4.2       Where Lesson recordings are made, the Business uses them for the agreed tutoring-related purposes described in clause 2, and does not use them for unrelated purposes unless permitted or required by law or separately agreed.

4.3       The Business use payment-related information, collected by its payment providers, to process payments for Lessons, lesson packages, lesson credit, subscriptions, and website material purchases.

4.4       The Business uses website usage information, in aggregate and de-identified form where possible, to understand how visitors use its website and to inform its marketing.

4.5       The Business may use personal information to comply with its legal obligations, resolve disputes, and protect the safety of a Client, Student, Customer, Tutor, or itself.

5. Cookies and Website Analytics

5.1       The Business's website uses cookies and similar technologies, including through third-party tools such as Google Analytics, Google Ads, Google Tag Manager, Meta Pixel, Reddit Pixel, and the LinkedIn Insight Tag, for purposes such as understanding site usage, remembering preferences, and measuring the effectiveness of marketing.

5.2       When you first visit the Business's website, a cookie banner allows you to indicate your preference regarding cookies. Continuing to use the website after making that choice, or after the banner is dismissed, reflects that preference. You can change your cookie preferences at any time through your browser settings.

5.3       If you prefer not to be tracked by a specific tool listed in clause 5.1, many of these tools offer their own opt-out mechanisms — such as browser extensions or account-level settings provided by Google or Meta — in addition to your browser and cookie-banner settings.

5.4       The Business is not always able to remove every trace of a prior interaction with its website, such as data already sent to a third-party tool before a preference was changed. If you have a specific concern about data collected in this way, contact the Business as set out in clause 13.

6. Who Your Information Is Shared With

6.1       The Business shares personal information with third parties only as reasonably necessary to provide its services, process payments, operate its website, and support its marketing. The main third parties the Business currently uses are:

(a)    Squarespace, the Business's website, membership, and website material hosting platform;

(b)   Acuity, the Business's lesson booking and scheduling platform;

(c)    Stripe and PayPal, the Business's payment processors;

(d)   Zoom and, at the Business's discretion, Microsoft Teams and Google Meet, the Business's video-conferencing platforms for online Lessons, including, where applicable, the recording and storage of Lesson recordings described in clause 2;

(e)    Google Analytics, Google Ads, Google Tag Manager, Meta, Reddit, and LinkedIn, for analytics and advertising, generally in aggregate and de-identified form; and

(f)    A third-party AI service provider, where an application uses one to generate Automated Output from content a Customer submits to it.

6.2       The Business may also disclose personal information where required or authorised by law, or to protect the safety of a Client, Student, Customer, Tutor, or itself.

7. Overseas Disclosure

7.1       Many of the third parties listed in clause 6.1 are based overseas, including in the United States, or store and process information on servers located overseas. This means personal information may be transferred to, and handled in, a country other than Australia.

7.2       The Business takes reasonable steps to use reputable third parties with their own privacy and security safeguards, but the Business does not control, and cannot guarantee, the privacy practices of an overseas recipient. By using the Business's services or website, you acknowledge that your information may be handled overseas as described in this clause.

8. How Long Your Information Is Kept

8.1       The Business retains personal information collected for the provision of its services for the duration of that service, and then generally for a further period of up to seven (7) years, to meet accounting, legal, and record-keeping obligations. Deletion may occur in batches rather than individually, meaning information may be retained for up to eight (8) years in practice.

8.2       The Business retains de-identified or aggregate website usage information indefinitely.

8.3       A Client, Student, or Customer may request earlier deletion of their personal information once the Business's services to them have ended, subject to clause 8.1 and any information the Business is required by law to retain.

8.4       Where the Business makes a Lesson recording, the Business generally retains the recording only for as long as reasonably necessary for the purpose for which it was made or for the period agreed with the relevant participants, subject to any longer period the Business is required by law to retain it. When the retention period ends, the recording will be deleted or otherwise disposed of securely where reasonably practicable.

9. How Your Information Is Protected

9.1       The Business takes reasonable steps to protect personal information, having regard to the nature of its services and information generally available to a business of its size — including limiting access to personal information on a need-to-know basis, minimising the personal information the Business extracts or links between systems, and preferring de-identified or reduced identifiers (such as a first name and last-initial, or a de-identified reference number) where practical.

9.2       The Business does not guarantee that its systems, or a third party described in clause 6, are immune from unauthorised access or another security incident.

10. Data Breaches

10.1    If the Business becomes aware of a data breach affecting your personal information, the Business will take reasonable steps to notify affected individuals as soon as practicable, and to comply with its obligations under applicable law.

11. Your Rights

11.1    You may request access to, correction of, or deletion of personal information the Business holds about you by contacting the Business as set out in clause 13. The Business will generally respond within a reasonable time, typically within a few days.

11.2    Deleting some personal information may make it difficult or impossible for the Business to continue providing services to you.

11.3    It is generally not possible to remove an individual's contribution to de-identified, aggregate website statistics. If you would like your information excluded from future aggregate statistics, contact the Business as set out in clause 13.

12. Changes to This Policy

12.1    The Business may update this Privacy Policy from time to time to reflect changes in its practices or in applicable law. The current version is available on its website here.

13. Contact Options and Complaints

13.1    You can contact the Business about this Policy, or about a privacy concern, through any of the contact forms on its website, or by email if you already have its business email address.

13.2    If you are not satisfied with the Business's response to a privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.