Privacy Policy (draft)

1. Who we are

Astry is run by [Legal entity name], ABN [ABN], of [Registered address], Sydney, New South Wales (“Astry”, “we”, “us”). This policy explains how we handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles. It also serves as our collection notice.

Questions, requests and complaints go to hello@astry.com.au. Please put “Privacy” in the subject line.

2. The short version

• We collect what we need to run accounts, keep children safe, arrange lessons and handle payments.
• We don’t sell personal information, we don’t show ads, and there are no advertising or social-media trackers on Astry.
• Our database, file storage and servers are in Singapore. Some of our providers are in the United States and Japan. We plan to move our servers to other providers, still in Singapore.
• Some decisions, such as which tutors you can see and whether a message is sent, are made automatically by our software.
• A parent linked to a child’s account can read the child’s conversations with tutors, and both sides are told.
• Astry staff can open a private conversation only after recording why, and every time is logged.
• You can see, correct and delete your information, and complain to the OAIC if we don’t sort out a problem.

3. What we collect

Your account

• your name, email address, mobile number (optional) and whether you are a student, parent or tutor;
• your date of birth. We need it because our child-safety rules depend on it: it decides whether a parent has to link to the account and who you can deal with;
• your password, which is held by our sign-in provider Clerk, not by us. Your email is checked with a code. Your mobile number is not checked yet;
• a profile photo, if you add one, and the subjects a student says they want to learn.

Tutor profiles

Subjects and rates, a bio, suburb and postcode, university, ATAR, experience, whether you teach online or in person, your weekly hours, time off (with any private note), and credentials with any images you upload. For the map and distance search we keep your suburb’s centre point, rounded to about 1 km, never your actual location.

Checks

• ID checks (once switched on): our provider Persona collects your ID document and anything else its check asks for. We keep the result, the check’s reference number, the name and date of birth read from your ID (to match a Working With Children Check to you and to check a parent is old enough to be one), and, if it failed, the reason.
• Selfie age checks, for 13 to 17-year-olds who choose one instead of a school email (once switched on): Persona takes a selfie and estimates from it whether you are under 18. We keep only the result and the check’s reference number, never the photo.
• Working With Children Checks: the check number, the name on it, its expiry date, an optional photo of the card, and our review of it.
• School email (13 to 17-year-olds who choose one instead of the selfie age check): the address you verify. The code we send is stored scrambled (hashed), never as written.
• Parent links: who is linked to whom, when the parent confirmed they are the legal guardian, and a parent’s email address if a child asks us to email them a link.

Messages, lessons and learning

Messages and files you send, booking cards, Quick Help questions and group chats. When you edit a message we keep the earlier wording, and when you delete one we keep it but hide it. We also keep lessons (subject, date, time, length, place and price), lesson and progress reports, homework and hand-ins, goals, shared files, and the lesson whiteboard, which is saved with a replay once the lesson ends.

Payments and the marketplace

Once card payments are on: amounts, fees, refunds, payment status and Stripe’s reference numbers, and for tutors and sellers the ID of their Stripe account and whether it can receive payouts. Card details go to Stripe, and we never see your full card number. For resources: listings, files, purchases, reviews, saves and the sellers you follow. Referral codes, who referred whom and rewards used.

Support, reports and settings

Support tickets and replies, reports you make and reports made about you, and “Report this problem” reports (the page, what you saw, the error behind it and your browser type). Your notification settings, and for each device you turn push notifications on for, the address your browser gave us to reach it and the browser type. Your appearance settings (theme and layout). If you connect a calendar, its private address, which we keep secret and only use to fetch your busy times for the next 15 weeks.

Sensitive information

Some of what we collect is “sensitive information” under the Privacy Act, which has extra protection. We only collect it with your consent, which you give by starting the check concerned, or where the law allows:

• an ID check (once switched on) compares a photo of your face with your ID document, and a selfie age check estimates a 13 to 17-year-old’s age from a photo of their face. That is biometric information. Persona does both and we don’t receive the photo;
• a Working With Children Check is a check of criminal history. We keep only the details listed above and its outcome, never the history itself;
• a credential, a bio or a message may mention your health, religion or background if you choose to include it. Please don’t share more than you need to.

A Working With Children Check number is a government identifier. We use it only to check the card, and never as our own way of identifying you.

Collected automatically

• when you were last active, used only to show whether a tutor is online now;
• your IP address, used briefly to limit how many requests or reports one address can send;
• resource page views, counted once per viewer per day for the seller’s statistics. For a visitor who isn’t signed in we store a scrambled code made from the IP address, browser and date, never the IP address itself;
• our hosting provider’s standard request logs and our error logs, which can include IP addresses and browser type;
• if you allow it in the cookie banner, page-view counts with no cookies, no IP address and no account attached (see our Cookie Policy).

4. Where it comes from

Mostly from you. Some comes from other people: a parent who links to your account, a tutor who writes a lesson report or a student who writes a review, someone who messages or reports you. Some comes from our providers: Clerk (that you signed in), Persona (the result of an ID check) and Stripe (whether a payment or payout went through).

5. Why we use it

• to create and run your account, and sign you in;
• to apply our age and safety rules: who needs a parent, which tutors you can see, and who you can message or book;
• to keep Astry safe: blocking phone numbers and email addresses in chat, filtering swearing, screening images for explicit content, reviewing reports, Working With Children Checks and credentials, and banning accounts;
• to arrange lessons, run the lesson room and whiteboard, and take and pay out payments;
• to show tutor profiles, ratings, how quickly a tutor usually replies, and seller statistics;
• to send you the emails and notifications you have chosen, and emails we must send (receipts, sign-in codes, ban notices);
• to answer support tickets and fix problems;
• if you allow it, to count which pages are used so we can improve them;
• to meet our legal obligations and deal with legal claims.

We don’t send marketing emails today. If we start, we will only send them to people who have agreed to them, in line with the Spam Act 2003 and the Privacy Act, and every one will have a way to unsubscribe. We won’t send marketing to children.

Staying anonymous

You can browse Astry without telling us who you are. Once you deal with other people on Astry, our child-safety rules need your real name and date of birth, so using Astry anonymously or under a made-up name isn’t possible from that point.

If you don’t give us information

You can browse Astry without an account. Without a date of birth we can’t apply our age rules, so an account can’t be used until it has one. Without a passed ID check (or, for a child, a linked parent) an account can browse but can’t message, book, pay, review, or buy or sell resources.

6. Decisions made by our software

Some decisions on Astry are made by our software using your personal information, without a person looking at each one first. These can significantly affect what you can do on Astry:

• Age rules. From your date of birth, whether a parent is linked and whether checks have passed, we work out whether your account can be used, which tutors the directory shows you, and who you can message, book or pay.
• Messages and text. A message, review or listing containing a phone number, an email address or swearing is refused, and social media handles are always hidden.
• Images. Images you upload are checked for explicit content by Google Cloud Vision, and an image flagged as explicit is refused.
• Fees. Once card payments are on, a tutor’s share of each lesson is worked out from how many lessons they finished in the last 7 days.
• Profile figures. A tutor’s reply time and reply rate are worked out from when they answered first messages, and shown on their profile.
• Limits. Too many requests or reports from one account or address are slowed down or refused for a while.

Reports, bans, Working With Children Checks and credentials are decided by a person, not by software. If you think one of the decisions above was wrong, open a ticket from Support or email hello@astry.com.au and a person will look at it.

7. What other people can see

• Tutor profiles are public: name, photo, suburb, bio, university, ATAR, subjects and rates, credentials, ratings and reviews, lesson and resource counts, reply speed, and whether they are online now. A tutor can choose to stay out of the directory, but their profile link still works.
• Tutors under 18 are hidden from signed-out visitors and from adults other than parents and tutors with a verified Working With Children Check.
• A student’s profile shows only their name, photo and the written reviews they have left tutors. Resource reviews and Quick Help questions show a first name and initial.
• Your date of birth, email address, mobile number and ID and check details are never shown to other users.
• Messages are seen by the people in the conversation, any linked parent of a child in it (see Children and parents) and, in limited cases, our staff.

Our staff

Astry staff can see account details to review checks, credentials, reports, payments and support tickets. To open a private conversation they aren’t part of, a staff member must first record a reason (a report, a payment dispute, a safety investigation, a support request or another stated reason). Each opening is logged, and the log is kept even if the staff account is later deleted. Staff can see edited and deleted messages; nobody else can.

8. Children and parents

Many people on Astry are under 18, so we collect as little as we can about them and add extra protection:

• no one under 18 can use Astry until a parent who has passed an ID check links to the account and confirms they are the legal guardian;
• someone aged 13 to 17 also verifies a school email or passes a selfie age check, whichever they choose, on top of the parent link;
• a linked parent can see their child’s lessons and lesson reports and read, but not write in, the child’s conversations with tutors. Parents can’t read a child’s conversations with Astry support, and reading never marks a message as read for the child;
• either side can remove a parent link at any time, and the other is told.

A parent or guardian can ask us for access to, correction of or deletion of their child’s information by emailing hello@astry.com.au.

9. Who we share it with

We use the companies below to run Astry. They only get what they need for their part, and we don’t let them use it for their own marketing. Services marked “not on yet” are built into Astry but don’t receive anything until we switch them on.

We may also share personal information:

• with other users, as described in What other people can see;
• with the police, child protection authorities or other government bodies where the law requires or allows it, including where we believe it is needed to protect someone’s life, health or safety;
• with our professional advisers, such as lawyers and accountants;
• with a buyer of our business, who would have to keep following this policy.

The Australian Taxation Office

Once card payments are switched on, the law may require us to report what tutors and sellers earn through Astry to the Australian Taxation Office, under the sharing economy reporting regime. That report includes a tutor’s or seller’s name, ABN if they have one, contact details, date of birth, bank account details and the amounts paid to them. Students and buyers aren’t reported. [Whether the regime applies to Astry is to be confirmed]

If you connect a calendar, our servers fetch it from your calendar provider (Google, Microsoft or Apple). We send them nothing about you beyond that request.

10. Information stored or sent overseas

Australian Privacy Principle 8 covers personal information sent outside Australia. Our database, file storage and servers are in Singapore (Neon, on Amazon Web Services, and Google Cloud). We plan to move our servers from Google Cloud to Render and Vercel, also in Singapore, and will update this policy when we do. Our encrypted backups are kept with GitHub in the United States. Email is sent through Resend, whose account for Astry is in Japan. Clerk, Cloudflare and Google, and once they are switched on Persona, Stripe, Daily.co, Twilio and Sentry, may process information in the United States and other countries where they operate. Map lookups go to OpenStreetMap and OpenFreeMap, which are run from Europe.

We choose providers with published security and privacy commitments and use their standard data-processing terms. We remain responsible under the Privacy Act for how they handle your information on our behalf.

11. How we protect it

• All traffic to Astry is encrypted. Passwords are held by Clerk, never by us.
• Paid resource files, Working With Children Check documents, shared files and whiteboard pictures are in private storage and can only be opened through short-lived links we create for the right person.
• Profile photos, credential images, listing images and chat attachments are stored at long, random web addresses. Anyone who has one of those addresses can open the file, so only send files in chat that you’re comfortable with the other person keeping.
• Verification codes and calendar links are stored scrambled (hashed). Your calendar’s private address is never shown back to anyone.
• Staff access to private conversations is logged with a reason.

Only staff who need it can see personal information, and we use the security settings our providers offer, such as two-step sign-in for our own staff accounts. [Staff security measures to be confirmed]

No system is perfectly secure. If a data breach is likely to cause serious harm, we will tell the people affected and the Office of the Australian Information Commissioner (OAIC), as the Notifiable Data Breaches scheme requires.

12. How long we keep it

We keep your information while your account is open.

You can delete your account at any time from Settings, under Delete account. We then delete your Clerk sign-in, your account and what belongs to it, including your profile, the messages you sent, your checks, settings and devices, and the files you uploaded. A few records are kept without your account attached, because they are evidence or a financial record:

• payment records (for tax and accounting law);
• reports you made about someone else, and reports made about you;
• the log of staff opening conversations.

Messages other people sent you stay with them. Some things made with another person, such as lesson reports, homework and whiteboard drawings, can stay in their account without your name attached, and notifications they received keep the name shown at the time.

Copies stay in our backups for a limited time before they are overwritten: up to 6 hours in our database provider’s restore history, and up to 30 days in our encrypted nightly backups. We only open a backup to recover from a fault, and if we do, we delete again anything that was deleted after the backup was made.

If we ban an account, we keep its records so that we can deal with the reason for the ban.

13. Seeing and correcting your information

You can see and change most of your information yourself, on your profile and in Settings. Your date of birth can only be set once, so to correct it, email us.

You can ask for a copy of the personal information we hold about you, or ask us to correct it, by emailing hello@astry.com.au. We may need to confirm who you are first. We will reply within 30 days and won’t charge you for making a request. If we refuse, we will tell you why and how to complain.

14. Your choices

• Choose which notifications reach you by email, push or text in Settings, under Notifications. Emails such as receipts, sign-in codes and ban notices always go. The unread-message digest says who has written and how many messages are waiting, never what they say.
• Turn push notifications on or off for each device.
• Choose “Essential only” or allow analytics in the cookie banner, and change it any time from our Cookie Policy.
• As a tutor, stay out of the tutor directory (Settings, under Account).
• Browse without an account, or delete your account.

15. Complaints

If you think we have mishandled your personal information, email hello@astry.com.au and tell us what happened. We will reply within 30 days.

If you are not happy with our answer, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

16. Changes to this policy

We will update this policy when what we collect or who we share it with changes, including when we switch on the services marked “not on yet” above and when we move to the providers marked “planned”. If a change matters to you, we will tell you by email or on the site before it takes effect. The date at the top of this page shows when it was last changed.

17. Contact us

[Legal entity name], ABN [ABN], [Registered address]. Email hello@astry.com.au.