Privacy Policy

Pocketnote is a trading name of Solstice Endeavours Pty Limited (ABN 91693195836) (“Pocketnote”, “we”, “us”, “our”). We are committed to protecting the privacy of our clients, students, and tutors in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, and how you can access or correct your information. It applies to all personal information collected by Pocketnote in connection with our tutoring services.

By using our services or providing your personal information to us, you consent to the collection, use, and disclosure of your information as described in this policy.

1. About This Policy

This policy covers personal information collected from:

  • Parents and guardians who engage Pocketnote for tutoring services (“Clients”);
  • Students who receive tutoring services, including adult students who engage Pocketnote directly; and
  • Tutors engaged by Pocketnote as independent subcontractors.

Separate provisions may apply to tutor information where noted. This policy primarily addresses Client and student information.

If you have any questions about this policy or how we handle your personal information, please contact us at [email protected].

2. What Personal Information We Collect

2.1 Client and Student Information

We collect the following categories of personal information from Clients and about Students:

  • Identity information: full name of the Client and Student.
  • Contact information: email address, phone number, and residential address.
  • Student details: year level, school name, and subjects requiring tutoring.
  • Learning information: learning needs, diagnosed or disclosed learning disabilities or difficulties, and general learning requirements or personality characteristics relevant to tutoring delivery. This information is collected verbally during onboarding and, where appropriate, recorded in writing in the Pocketnote parent portal.
  • Payment information: credit or debit card details, collected and processed via Stripe (our third-party payment processor). Pocketnote does not store card details directly.
  • Account information: login credentials and account activity on the Pocketnote parent portal.
  • Communications: records of communications between you and Pocketnote, including email and any written notes or instructions provided in the portal.

2.2 Sensitive Information

Some information we collect may constitute sensitive information under the Privacy Act 1988 (Cth), including information about a Student’s learning disabilities or health-related learning needs. We collect this information only with your consent, and only to the extent necessary to deliver appropriate tutoring services to the Student. You are not required to provide sensitive information, but doing so helps us match the Student with the most suitable tutor and tailor the learning experience accordingly.

2.3 Adult Students

Where an adult student (aged 18 or over) engages Pocketnote directly rather than through a parent or guardian, we collect the same categories of information directly from that student. References to “Client” in this policy apply equally to adult students engaging Pocketnote on their own behalf.

2.4 Tutor Information

We also collect personal information from tutors, including identity, contact, ABN, tax, and qualification information. This information is used to manage the subcontractor relationship and is not covered in detail in this policy. Tutors should refer to their Subcontractor Agreement for further detail.

2.5 Information We Do Not Collect

We do not collect personal information directly from students who are under 18. All information relating to minor students is provided by their parent or guardian.

We do not record telephone calls at this time.

3. How We Collect Personal Information

We collect personal information in the following ways:

  • Directly from you during the onboarding process, including verbally over the phone and in writing via the Pocketnote parent portal.
  • Via the Stripe-hosted payment setup flow, through which you provide your payment method details directly to Stripe.
  • Through your ongoing use of the Pocketnote parent portal, including session notes, communications, and account activity.
  • Via email and other written communications you send to us.

We collect personal information only by lawful and fair means, and not in an unreasonably intrusive manner.

4. Why We Collect Personal Information

We collect and use personal information for the following purposes:

  • To provide tutoring services, including matching Students with suitable tutors and scheduling sessions.
  • To process payments and manage billing for sessions.
  • To communicate with you about your bookings, account, and our services.
  • To send transactional and service-related emails, such as booking confirmations, payment receipts, and session reminders, via our email and CRM platform (Brevo).
  • To maintain records of tutoring sessions, learning progress notes, and session outcomes.
  • To comply with our legal obligations, including tax and record-keeping obligations under Australian law.
  • To improve our services and platform.

We will not use your personal information for a purpose other than those listed above without your consent, unless otherwise permitted or required by law.

5. Disclosure of Personal Information

5.1 Disclosure to Tutors

We disclose relevant personal information to the tutor assigned to your Student to enable them to deliver tutoring services. This includes:

  • Parent name and phone number;
  • Student name and year level;
  • Residential address (for in-home sessions);
  • Subjects and learning requirements; and
  • Any other information reasonably necessary for the tutor to deliver the session effectively.

Tutors are required to handle this information confidentially and in accordance with their Subcontractor Agreement with Pocketnote. They are not authorised to use this information for any purpose other than delivering tutoring services.

5.2 Disclosure to Third-Party Service Providers

We disclose personal information to the following third-party service providers to operate our business:

  • Stripe: payment processing. Card details are entered directly into Stripe’s platform and are not accessible to Pocketnote. Stripe may store payment data on servers located outside Australia, including in the United States.
  • Brevo: email communications and CRM. We share name, email address, phone number, and other contact or account attributes with Brevo to manage transactional and service communications. Brevo may store data on servers located outside Australia.
  • Pocketnote web application and database infrastructure: our parent and tutor portals and scheduling software are built and hosted using third-party cloud infrastructure, which may include providers such as Amazon Web Services (AWS) or Heroku. Personal information stored in our platform database may therefore be held on servers located outside Australia, including in the United States.

We take reasonable steps to ensure that these service providers handle personal information in accordance with the Australian Privacy Principles or equivalent standards.

5.3 Disclosure Required by Law

We may disclose personal information if required to do so by law, court order, or at the request of a regulatory or law enforcement authority. We may also disclose information where we reasonably believe disclosure is necessary to protect the safety of any person, including in connection with our child safety obligations.

5.4 No Sale of Personal Information

We do not sell, rent, or trade personal information to third parties for marketing or any other commercial purposes.

6. Overseas Disclosure

As noted in clause 5.2, some of your personal information may be disclosed to, or stored by, third-party service providers whose servers are located outside Australia, including in the United States and the European Union.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the Australian Privacy Principles. However, you acknowledge that by consenting to such disclosure, the overseas recipient may not be subject to Australian privacy law, and you may not be able to seek redress under the Privacy Act 1988 (Cth) in relation to the handling of that information by the overseas recipient.

7. Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include:

  • Password protection and access controls on our platform and internal systems.
  • Use of Stripe’s PCI DSS-compliant infrastructure for all payment data.
  • Restricting access to personal information to staff and contractors who need it to perform their role.
  • Use of secure, reputable third-party hosting infrastructure.

However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

8. Data Retention

We retain personal information only for as long as necessary for the purposes for which it was collected, or as required by law.

  • Financial and transaction records (including payment records, invoices, and billing history) are retained for 7 years from the date of the last relevant transaction, in accordance with our obligations under the Corporations Act 2001 (Cth) and the requirements of the Australian Taxation Office.
  • All other personal information (including Student details, learning notes, contact information, and session records) is retained for 5 years from the end of the Client relationship, after which it will be securely destroyed or de-identified.

Where you request deletion of your personal information before the expiry of the applicable retention period, we will delete what we are not legally required to retain and de-identify or quarantine the remainder until the retention period expires.

9. Access and Correction

You have the right to request access to the personal information we hold about you or your Student, and to request correction of any information that is inaccurate, out of date, incomplete, or misleading.

To make an access or correction request, please contact us at [email protected]. We will respond to your request within a reasonable time, and in any event within 30 days. We may ask you to verify your identity before providing access.

We will not charge a fee for making an access request, but we may charge a reasonable fee for the cost of providing access (for example, photocopying or compiling records) where the request is complex or involves a large volume of information.

If we are unable to provide access to certain information (for example, because doing so would reveal the personal information of another individual, or because we are required by law to refuse access), we will explain our reasons in writing.

10. Complaints

If you have a complaint about the way we have handled your personal information, please contact us in the first instance at [email protected]. We will acknowledge your complaint within 5 business days and endeavour to resolve it within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

11. Cookies and Online Tracking

Our parent portal and website may use cookies and similar tracking technologies to improve functionality and user experience. Cookies are small files stored on your device that help us recognise returning users and understand how our platform is used.

You may disable cookies through your browser settings, though doing so may affect the functionality of the Pocketnote portal. We do not use cookies to collect sensitive personal information or to track your activity across third-party websites.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or operational requirements. Where we make a material change, we will notify you by email at least 14 days before the change takes effect.

The current version of this policy is always available at www.pocketnote.com.au. The effective date at the top of this document indicates when it was last updated.

13. Contact Us

For any questions, requests, or complaints relating to this Privacy Policy or our handling of personal information, please contact:

 

Pocketnote Tutors

Privacy Enquiries: [email protected]

Website: www.pocketnote.com.au/contact

Pocketnote is committed to handling your personal information with care, transparency, and in accordance with Australian privacy law.