Mark My Words | AI Writing Assessment & Feedback Platform for Teachers

Mark My Words Australia Pty Ltd (ABN 93 662 681 450) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

Identity Data including your name, date of birth, age, photographic identification, pronouns and gender.
Contact Data including your telephone number, address and email.
Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website
Profile Data including your username and password for the Mark My Words platform, profile picture, purchases or orders you have made with us, content you post, send receive and share through our platform, information you have shared with our social media platforms, and support requests you have made.
Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

when you interact directly with us, including face-to-face, over the phone, over email, or online;
when you complete a form, such as registering for any events or newsletters, or responding to surveys;
when you apply for a job with us; or
from third parties, such as details of your use of any website we operate (from our analytics and cookie providers and marketing providers. See the "Cookies" section below for more detail on the use of cookies).

Why we collect, hold, use and disclose personal information

Personal information: We collect, hold, use and disclose your personal information for the following purposes:

to enable you to access and use our platform, including to provide you with a login;
to do business with you, including to provide our services and platform to you;
to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;
to contact and communicate with you about any enquiries you make with us via any website we operate;
for internal record keeping, administrative, invoicing and billing purposes;
for analytics (including profiling on our website and to monitor usage), market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
to enable age-based benchmarking, performance comparison across year groups, and to support admissions testing purposes;
for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;
to run promotions, competitions and/or offer additional benefits to you;
if you have applied for employment with us, to consider your employment application; and
to comply with our legal obligations or if otherwise required or authorised by law.

Our disclosures of personal information to third parties

Personal information: We may disclose personal information to:

our employees, contractors and/or related entities;
IT service providers, data storage, web-hosting and server providers;
third party service providers in the form of artificial intelligence generative language models and chatbots;
marketing or advertising providers;
professional advisors, bankers, auditors, our insurers and insurance brokers;
payment systems operators or processors;
our existing or potential agents or business partners;
with your consent, our educational partners, including Seven Steps to Writing Success, for the purpose of facilitating integrated educational services, coordinating training and support, and sharing teacher and school information to improve educational outcomes (you opt in to this data sharing when you sign up to use the Seven Steps portal);
sponsors or promoters of any promotions or competition we run;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties to collect and process data, such as analytics providers, including Microsoft Clarity, and third parties that assist us with collecting cookies; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Microsoft Analytics: We partner with Microsoft Clarity to capture how you use and interact with us through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Sub-processors and Service Providers

We engage various sub-processors and service providers to assist in delivering our platform and services. These include cloud hosting providers, payment processors, analytics services, and educational partners.

A detailed register of our sub-processors, including the types of data they process and their locations, is available upon request by contacting hello@markmywords.au. Schools may also request this information as part of their own privacy impact assessment or procurement processes.

We review our sub-processor arrangements regularly and will notify schools of any material changes to sub-processors that handle student data.

Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the optout facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (if you are an Australian resident).

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Data Retention

We retain personal information for as long as necessary for the purposes for which it was collected, or as required by law.

Our standard retention periods are:

Active account data (teacher profiles, student records, writing submissions): retained for the duration of the school's active subscription, plus 12 months
Assessment and feedback data (AI-processed outputs, skill tracking data): retained for the duration of the subscription, plus 12 months
De-identified and aggregated data: may be retained indefinitely for platform analytics and improvement purposes
Usage and technical data (logs, IP addresses): retained for up to 24 months
Marketing and communications data: retained until you unsubscribe

Once personal information is no longer needed for the purpose for which it was collected, we will take reasonable steps to destroy or de-identify it in accordance with the Australian Privacy Principles.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party's websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies as a core part of our platform. Our AI models are developed and hosted entirely by us on servers located in Australia. We do not send your data to any third-party AI provider. We only use these technologies when legally permitted and necessary for our business.

What data is processed by AI

When you use our platform, the following information may be processed by our AI and machine learning systems:

Student writing samples and assessments (including any names or identifying information written on handwritten submissions)
Teacher annotations, feedback, and rubric selections
Student name, date of birth, and year level
Usage and interaction data
Aggregated and de-identified performance data

How we use AI

We use AI technologies to:

Analyse and assess student writing against curriculum rubrics and criteria
Generate automated feedback and annotation suggestions for teachers
Recognise handwritten text submitted through our handwriting recognition feature
Match student names on submitted documents to class records to enable efficient document management
Track student skill development over time and surface insights for teachers
Enable age-based benchmarking and comparison of student performance across year levels
Improve the accuracy and relevance of our AI models and platform features
Detect misuse, fraud or security incidents

AI model training and improvement

We use de-identified data to train, evaluate and improve our AI models. This includes:

De-identified student writing samples that have been transcribed to text
Assessment scores and rubric outcomes in aggregated form
Age-related performance data (in such a way that the data does not identify individuals)

Data protection and security

All AI processing occurs within Australia on infrastructure we own and control. We use appropriate technical and organisational measures to maintain the security and integrity of your personal information when processed by AI systems.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

We'll inform you when AI is used to make decisions that may significantly affect you
We maintain human oversight and review of significant AI-generated decisions
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

Contact our Privacy Officer

For any questions or notices, please contact our Privacy Officer at:

Mark My Words Australia Pty Ltd (ABN 93 662 681 450)
Email: hello@markmywords.au
Phone: (+61) 403 651 221
Address: 700 Connect, University of Melbourne, Victoria