This Privacy Statement is written in plain language. It explains your privacy rights and how Elevate handles your personal information.

It is written to comply with the New Zealand Privacy Act 2020, including the Information Privacy Principles (IPPs 1–13) and IPP 3A.

 

1.  Who We Are

 

1.1   This Privacy Statement is issued by Elevate Learning Hub NZ Limited ('Elevate', 'we', 'us', or 'our'). Elevate operates the myelevatetutor™ AI-powered learning platform. The intellectual property underlying the platform is owned by Elevate Learning Technologies Limited, our parent company.

1.2   This statement applies to all personal information collected in connection with your use of the myelevatetutor™ platform, whether you are a student, a parent or guardian, or an educational institution.

1.3   Elevate is committed to protecting your personal information in accordance with the New Zealand Privacy Act 2020. Privacy responsibilities are managed by a designated member of the Elevate team. If you have any questions about this Privacy Statement or how your personal information is handled, please contact us at info@elevatetutor.com. We will acknowledge your request promptly and respond within 20 working days as required by the Privacy Act 2020.

 

2.  What Personal Information We Collect

 

2.1   Students and learners: When a student account is created, we collect first and last name, birth month and year, the name of the student's educational institution (if provided), and login credentials (stored in encrypted form — we never store passwords in readable form). When the platform is used, we also collect learning interaction data, learning progress data, and platform usage data. This data is used to personalise the AI tutor to each student's individual learning style.

2.2   Parents and guardians: When a parent or guardian creates or manages a student account, we collect their name, email address, phone number, and their relationship to the student. Payment information is processed securely by Stripe, our third-party payment processor, and is not stored by Elevate.

2.3   Educational institutions: When a school or other educational institution creates an account, we collect the institution name, type, and address, Ministry of Education number (if applicable), and named administrator and billing contact details.

2.4   What we do not collect: Elevate does not collect students' full dates of birth, government-issued identification numbers, sensitive health or medical information, or precise location data.

 

3.  How We Collect Your Information

 

3.1   Most information we collect comes directly from you — or, for student accounts, from a parent, guardian, or educational institution — when you create or update an account, use the platform, make a payment, or contact us.

3.2   In some cases, we receive personal information about you from a third party — for example, when a parent creates an account for a child, or when a school imports a student into a virtual classroom. Where this happens, we will take reasonable steps to make you aware of this Privacy Statement and your rights under it. For students under 13, this notification will be directed to their parent or guardian.

 

4.  How We Use Your Personal Information

 

4.1   We use personal information only for the purpose for which it was collected, or a directly related purpose. We will not use your information for unrelated purposes without first telling you.

4.2   Primary uses: We use personal information to deliver and personalise the myelevatetutor™ platform; personalise the AI tutor to your individual learning style; track and display learning progress; process subscription payments and manage accounts; communicate with you about your account and the platform; support educational institutions to manage their virtual classrooms; and comply with legal obligations.

4.3   AI improvement using anonymised data: To improve the platform for all users, Elevate uses fully anonymised interaction data for platform improvement purposes. Anonymisation means all personal identifiers are removed before any data is used — it cannot be linked back to any individual student. Your individual learning profile remains private to you and is never shared with other users. Because this anonymised use is fundamental to how the platform functions and improves, it is a condition of use rather than a separate opt-in choice. Our AI infrastructure providers may also process conversation data for safety and service monitoring purposes as a standard condition of enterprise API usage. This does not involve your data being used to train AI models. Further details of the third-party providers we use are set out in our Sub-Processor List, available on request.

4.4   What we will never do: Elevate will never sell, rent, or share your personal information with third parties for marketing purposes; use student information for advertising or commercial profiling; use personal (identifiable) student data for AI training; or share the content of a student's individual tutoring conversations with their school or anyone else, except as described in clause 4.4 (system performance, safety, and acceptable use monitoring) or where required by law.

4.4   System performance, safety, and acceptable use monitoring: Elevate may review conversation data, including where it relates to an identifiable individual, where necessary to maintain platform safety, respond to wellbeing concerns, or investigate a suspected breach of our Acceptable Use Policy. Access for these purposes is limited to authorised Elevate personnel on a need-to-know basis, and is separate from the anonymised data use described in clause 4.3.

 

5.  Automated Processing and AI Personalisation

 

5.1   The myelevatetutor™ platform uses automated processing to personalise the learning experience. This includes adapting the difficulty and style of content to each student’s individual responses, tracking learning progress over time, and identifying subject areas of strength or difficulty. This automated processing is fundamental to how the platform operates and is a condition of using the service.

5.2   This section is provided in compliance with Information Privacy Principle 3A of the New Zealand Privacy Act 2020, which requires us to inform you when personal information may be used in decisions made by automated means. While the platform’s AI adapts the learning experience, it does not make significant decisions about a student’s educational outcomes in isolation — a parent, guardian, or educator always retains the ability to review and act on progress information.

5.3   If you have concerns about how automated processing has affected a student’s learning profile or progress data, you may contact us at info@elevatetutor.com to request a review.

 

6.  Who We Share Your Information With

 

6.1   Payment processing: Elevate uses Stripe as its payment processor. When you make a payment, your card details are collected and processed directly by Stripe — Elevate does not store your credit card or bank details. Stripe receives only the information necessary to process your payment and is bound by its own privacy and security obligations. Stripe's privacy policy, which governs how your payment information is handled, is available at stripe.com/privacy. If Elevate changes its payment processor in future, this section will be updated accordingly.

6.2   Cloud infrastructure: Your data is stored on secure cloud infrastructure, processed on our behalf under contractual obligations that require our cloud provider to maintain security standards consistent with the New Zealand Privacy Act 2020. Data is hosted in the Asia Pacific region. Details of our cloud infrastructure provider are set out in our Sub-Processor List, available on request.

6.3   AI infrastructure: myelevatetutor™ is built on enterprise-grade AI infrastructure. We use a small number of carefully selected AI technology providers, chosen for their capability, safety design, and enterprise data protection standards. These providers operate under contractual obligations with Elevate and are bound by their own privacy frameworks. Student conversation data processed through the AI is subject to contractual data retention settings agreed with each provider. This is separate from Elevate's own review of conversation data for safety and acceptable use purposes, described in clause 4.4. Details of our AI sub-processors are set out in our Sub-Processor List, available on request.

6.4   Transactional email: Elevate uses SendGrid to deliver transactional emails — including account confirmations, subscription notifications, and parent or guardian communications. SendGrid receives email addresses and the content of system-generated messages only. It does not have access to learning data or account history. SendGrid’s privacy policy is available at sendgrid.com/policies/privacy.

6.5   Educational institutions: With appropriate permission, Elevate may share limited engagement information with a student’s school — for example, whether a student is actively using the platform, subject areas of strength or difficulty, and assignment submission status where available. We do not share the content of a student’s tutoring conversations with their school.

6.6   Legal requirements: Elevate may disclose personal information if required to do so by law, court order, or a lawful request from a regulatory authority. We will notify you of any such disclosure where we are legally permitted to do so.

 

7.  Cross-Border Transfers of Personal Information

 

7.1   Some of Elevate’s third-party sub-processors are located outside New Zealand, including in the United States. When personal information is transferred overseas, Elevate takes reasonable steps to ensure that the recipient protects that information in a manner consistent with the New Zealand Privacy Act 2020, as required by Information Privacy Principle 12.

7.2   We achieve this through contractual protections — including Data Processing Agreements (DPAs) and, where applicable, Standard Contractual Clauses (SCCs) — that require overseas sub-processors to maintain security and privacy standards equivalent to those required under New Zealand law. The processing location of each sub-processor is listed in our Sub-Processor List, available on request.

 

8.  Storage and Security

 

8.1   Elevate takes the security of your personal information seriously. We store all personal data on secure, encrypted servers; store login credentials in encrypted form; restrict access to personal data to authorised Elevate personnel on a need-to-know basis; and use enterprise-grade cloud infrastructure maintained to industry-leading security certifications.

8.2   No internet-based system is completely secure. If you have concerns about the security of your account, please contact us immediately at info@elevatetutor.com.

 

9.  Children's Privacy

 

myelevatetutor™ is designed for learners from age 7 upwards. Children's personal information carries the highest level of privacy protection, and Elevate takes this responsibility seriously.

 

9.1   Students aged 7 and over may use the platform. Students under 18 are 'Minors' for the purposes of this Privacy Statement. All Minors require parental or guardian consent before using the platform.

9.2   Age verification: Elevate uses an age-gate mechanism at sign-up to determine whether parental consent is required. Students under 13 must have their account created by a parent or guardian, who provides their own contact details and accepts this Privacy Statement and the Terms and Conditions on the student's behalf.

9.3   Where parental consent is provided, a record of that consent — including the date and the parent's email address — is retained by Elevate for the life of the account.

9.4   We collect only the minimum personal information necessary to deliver the service to a Minor student. Information about Minors is used only to deliver and personalise the learning service, share appropriate progress updates with the parent or guardian, and share limited engagement information with the student's school where parental permission has been given.

9.5   Information about Minors is never used for advertising, marketing profiling, or any purpose unrelated to the learning service. Anonymised interaction data from Minor students may be used for platform improvement in the same way as all users — with all personal identifiers removed before any such use.

9.6   A parent or guardian may at any time request access to, correction of, or deletion of the personal information Elevate holds about their child. Contact us at info@elevatetutor.com.

9.7   Age misrepresentation: If Elevate becomes aware that a Minor has created an account by misrepresenting their age — bypassing the age-gate without parental or guardian consent — we will promptly notify the parent or guardian where contact details are available, and delete the account and associated personal information unless parental consent is subsequently provided.

 

10.  Your Privacy Rights

 

10.1   Right to access: You have the right to ask Elevate for a copy of the personal information we hold about you. Email info@elevatetutor.com with your name, account email address, and a description of the information you are requesting. We will respond within 20 working days as required by the Privacy Act 2020.

10.2   Right to correct: If you believe personal information Elevate holds about you is inaccurate, incomplete, or misleading, you have the right to request that we correct it. Contact info@elevatetutor.com with details of the correction needed.

10.3   Right to complain: If you are not satisfied with how Elevate has handled your personal information, we encourage you to contact us first. If you remain unsatisfied, you may lodge a complaint with the Office of the Privacy Commissioner at www.privacy.org.nz or 0800 803 909.

10.4   Limitations: The Privacy Act 2020 does not include a general right to be forgotten or right to data portability. We may decline an access or correction request in limited circumstances permitted by the Act — for example, where providing the information would prejudice another individual's privacy. We will explain any refusal in writing.

 

11.  Data Retention

 

11.1   Elevate keeps personal information only for as long as it is needed for the purpose for which it was collected, or as required by law. Personal information associated with an active account is retained for as long as the account remains active.

11.2   When a subscription ends or an account closes, we retain account data for 90 days to allow you to request an export or reactivate, after which it is permanently deleted. For dormant accounts, we will notify you before taking any deletion action. Full details of the account lifecycle — including inactive account handling and grace periods — are set out in our Terms and Conditions.

11.3   Payment records are retained for a minimum of 7 years as required by New Zealand tax law, after which they are securely deleted.

 

12.  Privacy Breaches — What Happens If Something Goes Wrong

 

12.1   Despite our security measures, a privacy breach can occur — for example, if personal information is accidentally lost, accessed by an unauthorised person, or disclosed incorrectly. Elevate maintains an internal breach response process to manage these situations promptly.

12.2   If a privacy breach occurs that is likely to cause serious harm to affected individuals, Elevate will notify the Office of the Privacy Commissioner as required by the Privacy Act 2020, and notify affected individuals as soon as reasonably practicable — including a description of what happened, what information was affected, what steps Elevate has taken to address it, and what steps you can take to protect yourself.

12.3   If you suspect your account has been accessed without your authority, or that your personal information may have been compromised, please contact us immediately at info@elevatetutor.com.

 

13.  Cookies and Platform Tracking

 

13.1   The myelevatetutor™ platform uses cookies and similar tracking technologies to operate and improve the service. We use essential cookies required for the platform to function, performance cookies to understand how the platform is being used, and learning analytics cookies to support AI personalisation.

13.2   We do not use cookies for advertising or to track your activity outside the myelevatetutor™ platform.

13.3   You can control or disable non-essential cookies through your browser settings. Please note that disabling cookies may affect the functionality of some parts of the platform. Essential cookies cannot be disabled as they are required for the platform to operate.

 

14.  Changes to This Privacy Statement

 

14.1   Elevate may update this Privacy Statement from time to time to reflect changes to our practices, the law, or our platform. When we make material changes, we will update the version number and date, notify you by email at least 30 days before the change takes effect, and display a notice on the platform. Your continued use of the platform after the notice period constitutes acceptance of the updated statement.

 

15.  Contact Us

 

15.1   For any privacy-related queries, requests, or complaints, please contact us:

 

Privacy queries and requests: info@elevatetutor.com

General support: info@elevatetutor.com

Office of the Privacy Commissioner: www.privacy.org.nz  |  0800 803 909

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