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 online tools we provide.

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.

Relationship to our Terms and Conditions. This policy forms part of our Terms and Conditions (clause 18.1 of those Terms). Our Terms deal with personal information in several places, including class recordings (clause 10), photography and media (clause 11), and medical and emergency information (clause 19.5), and this policy explains how we handle it. If there is any inconsistency between this policy and our Terms on a privacy matter, this policy applies.

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. Consent to the delivery and recording of classes through Zoom is a condition of enrolment under clause 10.2 of our Terms.
• Website, technical, and advertising information: information collected automatically through cookies, analytics tools, and advertising tracking pixels, such as your device and browser type, IP address, pages visited, referring website, and the actions you take on the site, including submitting an enquiry form. This includes information collected by the Meta Pixel and shared with Meta Platforms (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. Separately from marketing, we do not currently photograph students for internal administrative purposes such as student identification cards or attendance records. If we introduce this we will update this policy and let you know beforehand, and those images would be used only for those internal purposes (clause 11.3 of our Terms).

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.
• 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 advertising tracking technologies when you use our website, including Google Analytics and the Meta Pixel (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;
• send information and marketing about our services, where permitted (see section 7);
• understand and improve how our website is used, through analytics;
• measure how our advertising performs, including which enquiries and enrolments follow from an advertisement;
• show advertising about our services on Facebook, Instagram, and other Meta platforms to people who have visited our website, and to build audiences of people with similar characteristics, as described in section 8;
• 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.
• Our website advertising is directed at parents, guardians, and adults considering our services. Our advertising is targeted to adults only, we do not target advertising at people under 18, and advertising audiences built from website activity are restricted to adults.

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 are introducing Ezidebit as a dedicated direct debit provider, and we will give you at least fourteen (14) days' written notice before recurring instalments are collected through Ezidebit rather than Stripe (clause 6.3 of our Terms).
• Customer relationship and email provider: HubSpot, which receives enquiries and leads from our 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.
• Advertising and social media platforms: Meta Platforms, Inc. (Facebook and Instagram). The Meta Pixel is currently installed on our website and sends Meta information about your website activity, as described in section 8. The pixel is not configured to send Meta the contact details you enter into our website forms.
• 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. Meta uses the information it receives through the Meta Pixel for its own purposes as well as ours, in accordance with its own privacy policy, and we do not control that use.

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. Where you submit an enquiry through our website, we may follow up with you 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. Opting out of email marketing is separate from advertising shown to you on Facebook and Instagram; section 8 explains how to control that.

8. Cookies, analytics, and tracking technologies#

Our website uses cookies and similar technologies to help the site function, to remember your preferences, to understand how the site is used, and to measure and deliver our advertising. Google Analytics and the Meta Pixel are both currently in use on our website. These tools may collect information such as your device and browser type, IP address, the pages you view, and the actions you take on the site.

Google Analytics. We use Google Analytics to understand how visitors find and use our site, so that we can improve it.

Meta Pixel. The Meta Pixel, a tracking tool provided by Meta Platforms, Inc., is currently active on our website. It is installed across all pages of the site and is in use now. The pixel places cookies on your device and sends information about your visit to Meta, including the pages you view, actions such as submitting an enquiry form, your IP address, and device and browser information. We use this information to:

• measure how our Facebook and Instagram advertising performs;
• show advertising about our services to people who have previously visited our website (commonly called retargeting); and
• build audiences of people whose characteristics are similar to our website visitors.

What the pixel does not send. The pixel is not configured to send Meta the name, email address, or phone number you enter into our website forms. Where you have a Facebook or Instagram account, Meta may still be able to associate your visit with that account through its own cookies. Meta handles that information for its own purposes under its own terms, and we do not control what Meta does with it. You can read Meta's privacy policy at https://www.facebook.com/privacy/policy and manage what Meta shows you at https://www.facebook.com/adpreferences.

Your controls. We tell you about our use of cookies through a notice shown on your first visit to our website. You can:

• control or block cookies through your browser settings;
• use Google's analytics opt-out browser add-on;
• adjust ad personalisation and off-Facebook activity settings in your Facebook or Instagram account; and
• contact us using the details in section 14 if you want us to stop using your information for advertising purposes.

Disabling some cookies may affect how the website works. If we introduce further analytics or advertising tools in future, including server-side tracking that would send contact details to an advertising platform, we will update this policy and put appropriate consent controls in place beforehand.

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. Enquiry and lead information collected through our website forms, such as your name, email address, phone number, and the details of your enquiry, 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.

Information collected by analytics and advertising tools is retained by those providers according to their own retention periods. Website advertising audiences built from Meta Pixel activity expire after a maximum of 180 days of inactivity.

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, Meta Platforms, 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. Because this policy forms part of our Terms and Conditions, a material change to it, including a change to how we collect, use, store, or share personal information about a student, is a major change under clause 20.3 of those Terms. For a material change we will give you at least fourteen (14) days' notice before it takes effect. If you do not accept the change you may withdraw before it takes effect, and in that case the early exit fee in clause 5.5 of our Terms does not apply, although the fees for the term in which your withdrawal takes effect remain payable in full. Minor changes, such as correcting a typographical error or updating our contact details, take effect when we publish the updated policy.

14. Contact us#

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