Spellcaster Education - Privacy Policy

Last updated: 10 March 2026

This privacy policy sets out how we, Spellcaster Education Limited (Spellcaster), collect, store, use and disclose your personal information when you use or interact with our website (https://spellcaster.education/) or any other websites that we operate from time to time (Website) or any services (Services) we make available in person or via the Website and where we otherwise obtain or collect information about you. Personal information is information that relates to an identified or identifiable individual (Personal Information).

Spellcaster Education Limited is a company incorporated in New Zealand, with its registered office in Dunedin.

This Privacy Policy is governed by New Zealand law. When handling Personal Information, we will comply with the New Zealand Privacy Act 2020 and any other applicable privacy laws that we are legally obliged to comply with, including (if applicable) the Australian Privacy Act 1988 (Cth) (Applicable Privacy Laws).

This Privacy Policy uses the same definitions as those used in our terms and conditions of service, found at https://spellcaster.education/terms (Terms of Service).

References in this Privacy Policy to Account Holder mean any school, private educational provider or parent that has registered for an Account via the Website, and references to Authorised User mean the personnel of an Account Holder authorised by the Account Holder to access or use the Account on its behalf.

Information We Collect

We collect Personal Information (including names, IP address, email addresses, location information, credit card information, browser information and interactions an individual has with our Website and Services). In respect of Learners, we also collect information about a Learner's progress through the Service (including game scores, learning items the Learner has found difficult, login times, and duration of use).

We collect this information from:

• you, when you provide that Personal Information to us, through use of our Website or Services, or through any other interactions with us (e.g. telephone call, email or web chat);
• Account Holders and Authorised Users when they provide information relating to their Learners via the Service;
• use of the Website or Services, any action an individual takes while using our Website or Services. We use this information to provide the Services, understand what content and features are effective and improve our Website and/or Service.

Personal Information of students and learners (Learners) is collected and processed by us as a consequence of our provision of the Service to the relevant Account Holder. In respect of such Learner Personal Information, the relevant Account Holder is responsible for obtaining the appropriate consents and approvals for us to lawfully process such Personal Information in the manner anticipated by the Website, Service and the Terms of Service (including this Privacy Policy). We act solely as the data processor of the Account Holder in respect of Learner Personal Information and the Account Holder is the data controller.

How We Use Your Personal Information

We will not process Personal Information, other than as outlined in this Privacy Policy, without having a lawful basis to do so.

We process Personal Information:

1. to activate Accounts within the Website and complete user profiles;
2. to provide our Service and otherwise carry out our obligations under our contracts with our Account Holders, including in respect of Learners, to build a profile of educational requirements, direct learning, maximize the effectiveness of the program, and generate progress reports; and
3. to invoice fees and to collect money that is owed, including authorising and processing credit card transactions.

We also process Personal Information:

1. to verify an individual's identity;
2. to communicate with third parties, as necessary to provide the Website and Services;
3. to communicate with Account Holders and Authorised Users, and other customers, users, licensors and suppliers relating to the Website and Services, including for administration purposes, such as Account management, customer service or system maintenance;
4. to comply with our obligations to our third-party data and service providers, suppliers and other users of our Website and Services;
5. to identify Authorised Users when they sign-in to an Account and verify that the Account is not being used by unauthorised persons;
6. to send our Account Holders (and their Authorised Users) marketing and promotional messages and other information that may be of interest where they have consented to receiving such material. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link) or by emailing us at rupert@spellcaster.education;
7. to improve our Website and Services;
8. to analyse usage of the Website and Service, or carry out research and analysis, so we can improve the Website and Service;
9. to enforce compliance with our Account Holder contracts;
10. to respond to due diligence requests and/or transfer Personal Information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition of our business;
11. to protect and/or enforce our legal rights and interests, including defending any claim; and
12. to comply with our legal obligations, including any notification and reporting obligations and any access directions imposed on us by a Government agency or regulatory authority.

We may also use Personal Information collected for such other purposes that are compatible with the original purpose described above, or that the relevant individual has otherwise consented to from time to time.

We may anonymise and aggregate information such that no person could be re-identified from the information. This aggregated and anonymised data is not Personal Information and this privacy policy does not apply to it.

Disclosing Personal Information

We may disclose Personal Information to:

• service providers who provide necessary data, goods and/or services to us or help us market and sell the Service (including Google Firestore, for hosting services);
• third parties, as necessary to provide the Website and Service;
• any business that supports us, including hosting or maintaining any underlying IT system that we use to provide our Website and/or Service;
• other third parties to anonymise and aggregate statistical information;
• a person who can require us to supply Personal Information (e.g. a regulatory authority or law enforcement agency); and
• any other person or entity that we have been validly authorised to disclose information to.

Overseas Transfers

We utilise the services of entities in New Zealand. If we do transfer Personal Information to service providers located in other countries, although we will endeavour to ensure that Personal Information is treated securely and in accordance with this Privacy Policy as well as Applicable Privacy Laws, we advise that some of these countries may not have an equivalent level of data protection laws as those in New Zealand.

Third Party Services

We use third party services for providing the Website and Services, to ensure a better experience for users and for improving the Website and Services. In the process of doing so, the third party service provider may have access to Personal Information. However, these third parties do not have the right to use the Personal Information for their own use.

Internet Use

While we take reasonable steps to maintain secure internet connections, if you provide us with Personal Information over the internet, the provision of that information is at your own risk.

If you follow a link on our Website to another website, the owner of that website will have its own privacy policy relating to your Personal Information. We suggest you review that website's privacy policy before you provide access to your Personal Information.

How Long We Keep Personal Information

We will keep Personal Information:

• until we no longer have a valid reason for keeping it;
• until the relevant individual requests us to stop using it; or
• for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations.

You should be aware that we do keep backups and logs for a period before they are automatically deleted.

Cookies and Tracking

We may use various technologies to collect and store information about individuals when they use the Website, and/or the Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons.

Cookies

A cookie is a piece of information that our web server may send to your machine when you visit our Website. The cookie is stored on your device, but does not identify you or give us any information about your device.

The types of cookies we use may include:

• Strictly necessary cookies: These cookies are essential for the full functionality of our Website. They enable you to navigate around our Website and use its features. Without these cookies, you may not be able to access all the functions of our Website.
• Performance cookies: These cookies collect information about how you use our Website. All information these cookies collect is anonymous and only used to improve how our Website works.
• Functionality cookies: These cookies allow our Website to remember the choices you make (for example, your user name, language or your region). Although these cookies are used to enhance the performance of our Website, they are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

The length of time a cookie will stay on your browsing device depends on whether it is a persistent or session cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies will stay on your browsing device until they expire or are deleted.

With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our Website but please note that some of its functions may not work as well as if cookies were enabled. To learn more about how to enable, edit, or disable cookies on your computer, please visit the aboutcookies.org website.

Web Analytics

We use third party analytics services to collect information about use of our Website, with the goal of improving our Website. These services collect information such as how often users visit the Website, what pages they visit when they do so, and what other sites they used prior to coming to the site. For more information on the specific analytics services we use from time to time, please email us at rupert@spellcaster.education.

Web Beacons

Web beacons are tiny graphics with a unique identifier that may be included on the Website for several purposes. For example, we may use web beacons to deliver or communicate with cookies, to track and measure the performance of the Website, to monitor how many visitors view our Website, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on an individual's hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email). We use these web beacons to customise content and advertising and to analyse traffic to our Website.

Protecting Personal Information

We take the protection of Personal Information seriously and we will take reasonable steps to keep Personal Information in our possession safe from loss, unauthorised activity, or other misuse.

Your Rights

You have the right to access your readily retrievable Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong.

You may also request deletion of your Personal Information by contacting us directly at rupert@spellcaster.education. We will use our reasonable endeavours to complete any deletion request within 14 days of the relevant request.

If you wish to exercise your rights under this Privacy Policy, you can do this by emailing our Privacy Officer at rupert@spellcaster.education. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

Changes to This Privacy Policy

From time to time we may make changes to this Privacy Policy (for example, to reflect any changes in our Service or any applicable laws). Where a change is significant, we'll make sure we let you know – usually by displaying a notice on our Website or by sending you an email.