BOOST EDUCATION AUSTRALIA
Effective Date:  2016
Last Updated: 2016

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1. ABOUT THIS POLICY

This Privacy Policy explains how 4877LMV Pty Ltd (ACN 672 937 370) as trustee for the
Burns Family Trust, trading as Boost Education Australia (we, us, our), collects, uses,
discloses, stores, and otherwise handles your personal information and the personal
information of your child. We are committed to protecting the privacy of all individuals who
engage with our academic tutoring services, and we recognise the particular importance of
safeguarding information relating to children and young people. This Policy has been
prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles
(APPs), and we take our obligations under this legislation very seriously. We understand that
parents and guardians entrust us with sensitive information about their children, and we are
dedicated to maintaining that trust through transparent privacy practices and robust data
security measures. By using our website, engaging our tutoring services, or otherwise
providing information to us, you acknowledge that you have read and understood this
Privacy Policy and consent to the collection, use, and disclosure of personal information as
described herein.

2. INFORMATION WE COLLECT

We collect various categories of personal information to enable us to provide high-quality,
tailored educational support to your child. The types of information we collect will depend on
the nature of your engagement with our services and the specific educational needs of your
child. The personal information we collect may include:

(a) Student Information: We collect identifying information about your child including full
name, date of birth, age, gender, residential address, contact telephone numbers, email
address where applicable, current school attended, year level, preferred learning style,
educational goals and aspirations, academic strengths and areas requiring improvement,
previous tutoring history, extracurricular activities that may impact scheduling, and any
specific educational needs or learning preferences that will assist our tutors in delivering
effective instruction.

(b) Academic Performance Data: We collect and maintain detailed records regarding your
child's academic performance including current grades and assessment results, school
reports and academic transcripts where provided, standardised test scores, homework
completion rates, participation in class activities, progress notes prepared by our tutors
following each session, assessment results from any diagnostic testing we conduct, subject-
specific strengths and weaknesses, learning pace and comprehension levels, and any other
academic information relevant to monitoring educational progress and tailoring our tutoring
approach.

(c) Sensitive Information: Where relevant to the provision of effective tutoring services and
with your explicit consent, we may collect sensitive information about your child including
information about any diagnosed learning disabilities or difficulties such as dyslexia,
dysgraphia, dyscalculia, or attention deficit disorders, information about autism spectrum
disorders or other developmental conditions that may affect learning, health information that

impacts educational engagement such as hearing or vision impairments, medical conditions
requiring specific accommodations during tutoring sessions, mental health information where
it affects learning capacity or requires specific support approaches, information about any
behavioural challenges or emotional needs that our tutors should be aware of, and details of
any medication that may affect concentration or learning during tutoring sessions.

(d) Parent and Guardian Information: We collect personal information about parents and
guardians including full names, contact telephone numbers, email addresses, residential
addresses, billing information, payment details including credit card or bank account
information for direct debit arrangements, employment information if relevant to scheduling
preferences, preferred methods and times for communication, emergency contact details,
and any specific instructions or preferences regarding your child's tutoring.

(e) Financial Information: We collect payment information necessary to process fees for
our services including credit card numbers and expiry dates, bank account details for direct
debit arrangements, billing addresses, payment history, outstanding balances, and
information about any payment plans or special fee arrangements.

(f) Technical and Usage Information: When you visit our website or use our online
platforms, we automatically collect certain technical information including IP addresses,
browser types and versions, operating systems, device identifiers, pages visited on our
website, time and date of visits, referring websites, clickstream data showing how you
navigate through our site, and information collected through cookies and similar tracking
technologies.
We collect this information directly from you when you complete our enrolment forms,
register on our website, correspond with us via email or telephone, attend initial consultation
meetings, complete student intake questionnaires, or otherwise provide information during
the course of engaging our services. We may also collect information about your child's
academic performance directly from your child during tutoring sessions, through
assessments we administer, and through ongoing progress monitoring by our tutors. In
some circumstances, with your written consent, we may collect information from your child's
school including school reports, teacher feedback, individual education plans, or other
relevant academic records. We will only seek such information from third-party sources with
your express authorisation, and we will inform you of the information we have obtained.

3. COLLECTION OF CHILDREN'S INFORMATION

We recognise that children require special privacy protections, and we are committed to
complying with all applicable laws concerning the collection and handling of children's
personal information. We primarily collect information about children from their parents or
legal guardians rather than directly from the children themselves. When we do collect
information directly from children during tutoring sessions, such as through verbal
communication, written work, or educational assessments, we ensure that appropriate
safeguards are in place. Our tutors are trained to collect only information that is necessary
for delivering effective educational support and to handle all information about children with
the utmost care and confidentiality. We do not encourage children to provide personal
information through our website or digital platforms without parental involvement, and we
implement age-appropriate privacy protections in all our interactions with students. Where
we become aware that we have collected personal information directly from a child under the
age of eighteen without obtaining parental consent where such consent was required, we will
take immediate steps to contact the parent or guardian and will delete the information if
appropriate consent cannot be obtained.

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4. PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

We collect, hold, use, and disclose personal information for purposes that are directly related
to our function of providing academic tutoring services and for purposes that you would
reasonably expect. The primary purposes for which we use personal information include:

(a) Educational Service Delivery: We use student information and academic performance
data to deliver personalised tutoring services tailored to your child's individual learning
needs, to match students with appropriate tutors based on subject expertise and teaching
style, to develop customised learning plans and set achievable educational goals, to monitor
academic progress and adjust teaching strategies accordingly, to prepare lesson materials
and resources suited to your child's learning level, to conduct diagnostic assessments to
identify knowledge gaps and learning difficulties, to provide feedback to parents regarding
their child's progress and achievement, and to maintain continuity of educational support
across multiple tutoring sessions;

(b) Administrative and Operational Management: We use personal information to
manage student enrolments and maintain accurate student records, to schedule tutoring
sessions and coordinate tutor assignments, to communicate with parents regarding session
arrangements, progress updates, and any concerns about their child's learning, to process
payments and maintain financial records, to issue invoices and receipts, to manage any
payment disputes or outstanding balances, to respond to enquiries and provide customer
support, to maintain our student database and internal record-keeping systems, and to
ensure smooth day-to-day operation of our tutoring services;

(c) Safety and Wellbeing: We use sensitive information about health conditions, learning
disabilities, and behavioural needs to ensure the safety and wellbeing of students during
tutoring sessions, to provide appropriate accommodations and support for students with
special educational needs, to inform tutors of any medical conditions or medications that
may affect student participation or require emergency response, to implement any specific
care plans or safety protocols required for individual students, to maintain a safe learning
environment for all students, and to respond appropriately in emergency situations;

(d) Quality Assurance and Service Improvement: We use information about student
progress and academic outcomes to evaluate the effectiveness of our tutoring programs, to
identify areas where our services can be improved, to train and develop our tutors, to assess
tutor performance and student satisfaction, to develop new educational resources and
teaching methodologies, and to maintain high standards of educational delivery;

(e) Legal Compliance and Risk Management: We use and retain personal information to
comply with our legal obligations under privacy law, consumer protection law, taxation law,
corporations law, and other applicable legislation, to respond to lawful requests from
government authorities or law enforcement agencies, to establish, exercise, or defend legal
claims, to investigate and resolve complaints, to maintain appropriate business records for
audit and compliance purposes, to manage risks associated with our business operations,
and to protect our legal rights and interests;

(f) Marketing and Communications: With appropriate consent where required, we may use
your contact information to send you information about our services, educational resources,
special offers, upcoming programs, and other communications that we believe may be of
interest to you. You may opt out of receiving marketing communications at any time by
following the unsubscribe instructions in our communications or by contacting us directly.

We will only use personal information for purposes that are reasonably necessary for our
functions and activities, and we will not use information for secondary purposes without
obtaining your consent unless such use is required or authorised by law.

5. DISCLOSURE OF PERSONAL INFORMATION

In order to provide our tutoring services effectively and to operate our business, we may
disclose personal information to various third parties. We only disclose personal information
where it is necessary for the purposes outlined in this Policy or where you have consented to
such disclosure. The categories of third parties to whom we may disclose personal
information include:

(a) Tutors and Educational Staff: We disclose relevant student information and academic
performance data to our tutors and educational staff who work directly with your child. This
disclosure is essential to enable our tutors to provide effective, personalised instruction and
to ensure continuity of educational support. We provide tutors with information about your
child's learning needs, academic goals, progress to date, any learning disabilities or health
conditions that may affect tutoring, and specific instructions or preferences you have
communicated to us. All tutors are required to comply with strict confidentiality obligations
and are contractually bound to use student information only for the purpose of delivering
tutoring services. We carefully vet all tutors and educational staff before engagement, and
we provide training on privacy obligations and the importance of maintaining student
confidentiality;

(b) Service Providers and Contractors: We engage third-party service providers and
contractors to assist with various aspects of our business operations, and we may disclose
personal information to these providers where necessary for them to perform their services.
These service providers may include cloud storage providers, payment
processing services and financial institutions that process credit card and direct debit
transactions, accounting and bookkeeping services that assist with financial management, IT
service providers who maintain and support our technology systems and website, marketing
and communications providers who assist with email campaigns and customer
communications, scheduling and calendar management platforms, customer relationship
management systems, and professional advisors including lawyers, accountants, and
business consultants who provide advice to our business. We require all service providers to
comply with the Australian Privacy Principles and to implement appropriate security
measures to protect personal information. We use contractual arrangements to ensure that
service providers only use personal information for the specific purposes for which it has
been disclosed and do not use or disclose it for any other purpose;

(c) Overseas Recipients: Some of the third-party service providers we use to store data or
provide services may be located overseas or may store data on servers located outside
Australia. Where we disclose personal information to overseas recipients, the information
may be stored or processed in Australian Privacy Policy (Privacy Act 1988 (Cth), APP 8.
Before disclosing personal information to overseas recipients, we take reasonable steps to
ensure that the overseas recipient does not breach the Australian Privacy Principles in
relation to the information. This may include entering into contractual arrangements that
require the overseas recipient to protect personal information in accordance with Australian
privacy standards, conducting due diligence on the privacy practices of overseas recipients,
and ensuring that data is encrypted during transmission to overseas locations. We will not
disclose personal information to overseas recipients without your consent where such
consent is required under the Privacy Act;

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(d) Schools and Educational Institutions: With your written consent, we may disclose
information about your child's progress in tutoring to their school teachers or educational
support coordinators. This disclosure may assist in ensuring a coordinated approach to your
child's education and may help school staff better support your child's learning needs. We
will only make such disclosures with your specific authorisation and will limit the information
shared to what is relevant and necessary for supporting your child's education;

(e) Parents and Legal Guardians: We regularly disclose information about student
progress, attendance, and academic performance to parents and legal guardians. This is an
essential part of keeping you informed about your child's educational development and
ensuring transparency in our service delivery. Where parents are separated or divorced, we
may disclose information to each parent who has parental responsibility for the child unless
there is a court order or other legal restriction preventing such disclosure. If there are any
restrictions on who may access information about your child, you must inform us in writing
and provide appropriate documentation;

(f) Government Agencies and Legal Obligations: We may disclose personal information
to government agencies, regulatory authorities, or law enforcement bodies where we are
required or authorised to do so by law. This may include disclosures to the Australian
Taxation Office for taxation purposes, to state revenue authorities for payroll tax or other
obligations, to courts or tribunals in response to subpoenas or court orders, to police or law
enforcement agencies where we have a reasonable belief that disclosure is necessary to
prevent a serious threat to life, health, or safety, to child protection authorities where we
become aware of circumstances that raise child safety concerns, or to other agencies as
required under mandatory reporting obligations or other legal requirements. We will only
make such disclosures to the extent required by law and will ensure that any disclosures are
handled in accordance with our legal obligations;

(g) Business Transactions: In the event that we sell, transfer, or merge our business or
any part thereof, or restructure our business operations, we may disclose personal
information to prospective purchasers, investors, or merger partners as part of the due
diligence process. We will require any such parties to agree to confidentiality obligations and
to handle personal information in accordance with this Privacy Policy and applicable privacy
laws. If our business is acquired or merged with another entity, personal information may be
transferred to the new business entity, and you will be notified of such transfer and any
changes to privacy practices.
We do not sell, rent, or trade personal information to third parties for their marketing
purposes. Any disclosure of personal information is made solely for the purposes described
in this Policy or as required by law.

6. DATA SECURITY

We are committed to protecting personal information from misuse, interference, loss,
unauthorised access, modification, or disclosure. We implement comprehensive physical,
technical, and administrative security measures designed to safeguard personal information
in our possession. These security measures include storing physical records containing
personal information in locked filing cabinets within secure premises with restricted access,
maintaining electronic records on secure servers with firewall protection, encryption, and
access controls, implementing password protection and multi-factor authentication for
systems containing personal information, restricting access to personal information to
employees, tutors, and service providers who require access to perform their duties,
providing regular training to staff on privacy obligations and data security practices,
conducting background checks on tutors and staff who will have access to children's

information, implementing secure data transmission protocols for electronic communications,
regularly backing up electronic data to prevent loss, maintaining up-to-date antivirus and
anti-malware software on all systems, regularly reviewing and updating our security
measures to address emerging threats, implementing data breach response procedures to
ensure rapid response in the event of any security incident, and securely destroying or

de-identifying personal information when it is no longer required for any purpose.
We require all tutors to maintain the confidentiality of student information and to return or
securely destroy any physical materials containing student information when tutoring
relationships end. We use contractual provisions to ensure that third-party service providers
implement appropriate security measures and protect personal information from
unauthorised access or disclosure. Despite our commitment to security, we acknowledge
that no data transmission over the internet or electronic storage system can be guaranteed
to be completely secure. While we implement industry-standard security measures, we
cannot provide absolute assurance that personal information will never be accessed, used,
or disclosed in an unauthorised manner. If you have any concerns about the security of
personal information you have provided to us, please contact us immediately using the
contact details provided in this Policy.

7. DATA RETENTION

We retain personal information for as long as it is necessary to fulfil the purposes for which it
was collected, to comply with our legal obligations, to resolve disputes, to maintain business
records, and to enforce our agreements. The specific retention periods vary depending on
the nature of the information and the purposes for which it is held. Generally, we retain
student records including enrolment information, academic progress data, attendance
records, and communications with parents for a minimum of seven years from the date of
the student's last tutoring session with us. This retention period enables us to respond to any
enquiries or disputes that may arise, to comply with taxation and business record-keeping
obligations, and to maintain appropriate documentation of our service delivery. We retain
financial records including invoices, receipts, and payment information for at least seven
years to comply with taxation law requirements. We retain sensitive information about health
conditions and learning disabilities only for as long as it is relevant to the provision of tutoring
services or as required by law, and we implement enhanced security measures for such
information throughout its retention period.
When personal information is no longer required for any purpose and we are not required by
law to retain it, we take reasonable steps to destroy or de-identify the information.
Destruction of physical records is conducted through secure shredding or other methods that
prevent reconstruction of the information. Electronic records are permanently deleted using
methods that prevent recovery of the data. If you request deletion of your personal
information or your child's personal information, we will comply with your request unless we
are required by law to retain the information or unless the information is necessary for
establishing, exercising, or defending legal claims. Even after you request deletion, we may
retain certain information in de-identified form for statistical analysis, quality assurance, or
service improvement purposes.

8. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

You have the right to access personal information we hold about you and your child, and you
have the right to request correction of any information that is inaccurate, out of date,
incomplete, irrelevant, or misleading. We are committed to ensuring that the personal
information we hold is accurate, complete, and up to date, as this is essential for providing
effective tutoring services. If you wish to access personal information we hold about you or

your child, you may submit a written request to us using the contact details provided in this
Policy. We will respond to your access request within thirty days and will provide you with
access to the information unless there is a lawful reason for refusing access. In most cases,
we will provide access free of charge, however, we reserve the right to charge a reasonable
fee to cover the administrative costs of providing access where the request requires
significant time or resources to fulfil. Before providing access, we may require you to verify
your identity and confirm your relationship to any child whose information is subject to the
access request.
There are limited circumstances in which we may refuse to provide access to personal
information, including where providing access would pose a serious threat to the life, health,
or safety of any individual, where providing access would have an unreasonable impact on
the privacy of other individuals, where the request is frivolous or vexatious, where providing
access would reveal evaluative information generated within our business in connection with
a commercially sensitive decision-making process, where providing access would be
unlawful, where denying access is required or authorised by law, where providing access
would prejudice the investigation of possible unlawful activity or enforcement of law, or
where providing access would prejudice legal proceedings. If we refuse to provide access to
personal information, we will provide you with written notice explaining the reasons for
refusal and the mechanisms available to you to make a complaint about the refusal.
If you believe that personal information we hold about you or your child is inaccurate, out of
date, incomplete, irrelevant, or misleading, you may request that we correct the information.
You can make a correction request by contacting us using the details provided in this Policy
and explaining the nature of the correction required. We will respond to correction requests
within thirty days and will take reasonable steps to correct the information if we are satisfied
that the information requires correction. If we correct personal information, we will take
reasonable steps to notify any third parties to whom we have disclosed the information about
the correction, unless it is impracticable or unlawful to do so. If we refuse to correct personal
information, we will provide you with written notice explaining the reasons for refusing the
correction. In such cases, you may request that we associate with the information a
statement that you believe the information is inaccurate, out of date, incomplete, irrelevant,
or misleading, and we will take reasonable steps to associate the statement with the
information in such a way that it will be apparent to users of the information.
We encourage you to regularly review and update the personal information you have
provided to us to ensure it remains accurate and current. You can update your contact
information, preferences, or other details by logging into your online account if applicable, or
by contacting us directly.

9. COOKIES AND ONLINE TRACKING

Our website uses cookies and similar tracking technologies to enhance user experience,
analyse website usage, and deliver relevant content. Cookies are small text files that are
stored on your device when you visit our website, and they allow us to recognise your device
and remember certain information about your preferences and browsing behaviour. We use
both session cookies that expire when you close your browser and persistent cookies that
remain on your device until they expire or you delete them. The types of cookies we use
include essential cookies that are necessary for the website to function properly and enable
you to navigate the site and use its features, performance cookies that collect information
about how visitors use our website including which pages are visited most often and whether
visitors receive error messages, functionality cookies that allow our website to remember
choices you make such as your language preference or region, and analytics cookies that

help us understand how visitors interact with our website by collecting information
anonymously and reporting website usage statistics.
We may also use third-party analytics services such as Google Analytics to help us analyse
website traffic and user behaviour. These third-party services may use cookies and similar
technologies to collect information about your use of our website and other websites. The
information generated by these cookies about your use of our website is typically transmitted
to and stored by third-party analytics providers on servers that may be located outside
Australia. You can control and manage cookies through your browser settings, and most
browsers allow you to refuse cookies, delete cookies, or alert you when cookies are being
sent. However, if you disable or refuse cookies, some features of our website may not
function properly or may not be available to you. 

10. LINKS TO THIRD-PARTY WEBSITES

Our website may contain links to third-party websites, resources, or services that are not
operated or controlled by us. These links are provided for your convenience and information
only. We are not responsible for the privacy practices or content of any third-party websites,
and we do not endorse or make any representations about third-party websites or their
privacy practices. When you click on a link to a third-party website, you leave our website
and are subject to the privacy policies and practices of that third-party website. We
encourage you to read the privacy policies of any third-party websites you visit to understand
how those websites collect, use, and disclose personal information. This Privacy Policy
applies only to information collected by us through our website and in the course of providing
our tutoring services, and it does not apply to information collected by third parties.

11. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify, update, or replace this Privacy Policy at any time to reflect
changes in our practices, changes in applicable law, changes in technology, or for other
operational, legal, or regulatory reasons. Any changes to this Privacy Policy will be effective
immediately upon posting the updated policy on our website. The date of the most recent
update will be indicated at the top of this Policy. We encourage you to review this Privacy
Policy periodically to stay informed about how we are protecting personal information. If we
make material changes to this Privacy Policy that significantly affect how we collect, use, or
disclose personal information, we will provide notice of the changes by posting a prominent
notice on our website or by sending you an email notification if we have your email address
on file. Your continued use of our services or our website after changes to this Privacy Policy
have been posted constitutes your acceptance of the revised Policy. If you do not agree with
any changes to this Privacy Policy, you should discontinue use of our services and contact
us to discuss your concerns.

12. MAKING A PRIVACY ENQUIRY OR COMPLAINT

We take privacy concerns seriously and are committed to resolving any complaints or
enquiries about our privacy practices promptly and fairly. If you have any questions about
this Privacy Policy, if you wish to make an enquiry about our privacy practices, if you believe
that we have breached your privacy rights or the privacy rights of your child, or if you wish to
make a complaint about how we have handled personal information, please contact us using
the details provided below. We request that you submit all privacy complaints in writing and
provide as much detail as possible about the nature of your complaint including the date or

approximate date of the incident giving rise to the complaint, the specific information
involved, the individuals involved if known, and the outcome you are seeking.
Upon receipt of a privacy complaint, we will acknowledge your complaint within five business
days and will provide you with information about our complaint-handling process. We will
investigate your complaint thoroughly and objectively, and we will endeavour to resolve the
complaint within thirty days of receipt. During the investigation, we may contact you to
request additional information or clarification about your complaint. We will keep you
informed about the progress of the investigation and will provide you with a written response
explaining the outcome of our investigation and any steps we will take to address the
complaint. If you are not satisfied with our response to your complaint, we will provide you
with information about your right to make a complaint to the Office of the Australian
Information Commissioner.
You have the right to make a complaint to the Office of the Australian Information
Commissioner if you are dissatisfied with how we have handled your privacy complaint or if
you believe that we have breached the Australian Privacy Principles. The Office of the
Australian Information Commissioner can be contacted at GPO Box 5218, Sydney NSW
2001, telephone 1300 363 992, or through their website at www.oaic.gov.au. There is no
charge for making a complaint to the Office of the Australian Information Commissioner. We
encourage you to contact us first so that we have the opportunity to address your concerns
and resolve any issues directly with you.

13. CONTACT INFORMATION

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy
practices, or if you wish to make an access or correction request, please contact us using
the following details:
Privacy Officer
Boost Education Australia
4877LMV Pty Ltd as trustee for the Burns Family Trust

Email: admin@boost-ed.com.au
Mobile: 0422 679 758
Website: www.boost-ed.com.au

We are committed to working with you to resolve any privacy concerns and to ensuring that
personal information is handled in accordance with the Australian Privacy Principles and this
Privacy Policy. Your trust is important to us, and we appreciate the opportunity to serve your
family's educational needs.