Privacy Policy

1. Overview

K.S. Innovations (ABN 69 890 596 069) (“we”, “us”, “our”) operates PosiTrack, a behaviour tracking application for educational environments. This Privacy Policy explains how we collect, use, store, and protect personal information in connection with the App and our website.

We are committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in that Act. We handle all personal information with care and in a manner consistent with the APPs, and we expect all schools and users of PosiTrack to do the same.

2. Information We Collect

We collect the following types of information:

• Account information: Name, email address and school name, provided when creating an account using a school-issued access code.
• Behaviour records: Positive behaviour points and related records entered by teachers and administrators within the App. These records are associated with student names or identifiers as entered by school staff.
• Device information: Device type, operating system, and App version, collected for support and performance purposes only.

We do not collect sensitive information (as defined under the Privacy Act) and we do not knowingly collect personal information directly from students.

3. Student Data

PosiTrack is designed to minimise the collection of student personal information. Student names or identifiers are entered into the App solely by authorised school staff. We do not collect, access, or use this information for any purpose other than providing the service to the school.

Schools and teachers bear responsibility for ensuring that their use of the App — including the information they choose to enter — complies with their institution's privacy policies, any applicable state education department guidelines, and the Privacy Act 1988 (Cth). We recommend that schools obtain appropriate authorisation before entering student information into the App.

4. Website Analytics

Our website uses analytics tools to understand how visitors interact with our site. These tools collect aggregate, non-personal data such as page views, session duration, and general traffic patterns. We do not use tracking cookies that identify individual users, and no personal information is collected through our website analytics.

5. How We Use Information

We use the information collected to:

• Provide, maintain, and improve the App and its features
• Manage school accounts and access
• Respond to support requests
• Ensure the security and integrity of the platform
• Meet our legal obligations

We will not use personal information for direct marketing without your consent, and we will not use it for any purpose that is inconsistent with the reason it was collected.

6. Data Storage and Security

All data is stored on Firebase servers located in Australia. We do not transfer personal information to servers or third parties outside of Australia.

We implement appropriate technical and organisational security measures to protect personal information against unauthorised access, loss, misuse, or disclosure. However, no system is completely secure, and we cannot guarantee absolute security of data transmitted over the internet.

7. Data Sharing

We do not sell, rent, or share personal information with third parties for marketing purposes. The App uses Firebase (Google Cloud) solely as its hosting and database infrastructure — this is the equivalent of a server provider and Google does not access or use your data for any other purpose. No personal information is shared with any other third parties.

We may disclose personal information if required to do so by law, or to protect the rights, property, or safety of our users or the public.

8. Data Retention

We retain account information and behaviour records for as long as your school's subscription is active. Upon cancellation or expiry of a subscription, data will be retained for up to 90 days to allow for account reactivation, after which it will be securely deleted. You may request deletion of your school's data at any time before that period by contacting us.

9. Notifiable Data Breaches

We comply with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). In the event of a data breach that is likely to result in serious harm to any individual whose information is involved, we will notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable and within the timeframes required by law.

10. Your Rights and Access

Under the Australian Privacy Principles, you have the right to access personal information we hold about you and to request corrections if it is inaccurate, out of date, or incomplete. To make such a request, please contact us at hello@positrack.app. We will respond within a reasonable time.

11. Complaints

If you believe we have breached the Australian Privacy Principles or mishandled your personal information, you may lodge a complaint with us at hello@positrack.app. We will investigate and respond 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.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will notify users of material changes by updating the date at the top of this page. Continued use of the App after changes are posted constitutes acceptance of the revised policy.

13. Contact

For any privacy-related questions or concerns, please contact us at hello@positrack.app.