Privacy Policy

This Privacy Policy explains how Learn with Hupe ("we", "us", "our") — operated by Hupe and Co Pty Ltd (ABN: 30 682 191 653) — collects, uses, discloses, stores and protects personal information in connection with the Learn with Hupe mobile application ("the App").

We are committed to protecting the privacy of children and their families in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the forthcoming Children's Online Privacy Code (to be registered by December 2026).

We are a children's educational service. We apply heightened privacy protections to all personal information handled through the App, consistent with the principle that children's best interests are our primary consideration.

One way we improve the App is through the collection and analysis of interaction pattern data — studying how children across different age groups engage with learning content, not to profile individuals, but to understand what works and how to make the App better for every child. This is explained in detail in Sections 3 and 4.

This Policy applies to:

• Parents and legal guardians ("Account Holders") who create and manage accounts
• Children aged 2–8 who use the App under a parent or guardian's account
• Any person who accesses our website at learnwithhupe.com.au

Account Holders are responsible for supervising their child's use of the App and ensuring all information provided to us is accurate.

3.1 Information you provide to us. When you create an account, we collect:

• Parent or guardian's name and email address
• Password (stored in encrypted form — we never store plain text passwords)
• Subscription and billing information (processed by our payment provider; we do not store full card details)
• Child profile information: first name or nickname, age or year group, and selected subjects

We collect the minimum information necessary to provide the service. We do not require children's surnames, photographs, school names, or precise date of birth.

3.2 Information generated through use of the App. As your child uses the App, we automatically collect:

• Learning progress data: which topics and skills have been started, completed, or partially completed
• Interaction pattern data: how your child engages with learning activities, including the type of response selected, the sequence of interactions, response timing, number of attempts made, and whether hints were used — collected at the age group level to understand engagement patterns across our user base
• Session data: session start and end times, total time spent in the App per session
• Device information: device type, operating system version, and app version (for technical support purposes)

Interaction pattern data is used in aggregated, de-identified form to understand how children of different ages engage with our content. This allows us to improve the design of learning activities, calibrate difficulty levels, identify content that is not working as intended, and inform future product development. Individual children are never singled out or profiled from this data.

3.3 Information we do not collect. We explicitly do not collect:

• Children's surnames
• School names or locations
• Photographs or video of children
• Voice recordings
• Precise geolocation data
• Behavioural advertising profiles
• Social media identifiers

We use the information we collect only for the following purposes:

• To create and manage your account and child profiles
• To deliver personalised, age-appropriate learning content to your child
• To track and display your child's learning progress
• To enforce the built-in 30-minute screen time limit
• To process subscription payments and send receipts
• To provide customer support when you contact us
• To analyse aggregated, de-identified interaction pattern data across age groups to understand how children engage with our content, improve the App's learning design, and inform the development of future features and products
• To improve the App's technical performance and reliability
• To comply with our legal obligations

Interaction pattern analytics are always conducted on aggregated, de-identified data. We do not use this data to make decisions about individual children, to build individual profiles, or for any advertising or commercial purpose beyond improving our own products.

We do not use children's personal information for targeted advertising, behavioural profiling, or sale to third parties. This is an absolute commitment, not a default setting.

We process personal information on the following grounds:

• Contract performance: processing necessary to provide the subscription service you have signed up for
• Legitimate interests: analysing aggregated, de-identified interaction pattern data to improve the App and develop better learning experiences, where those interests are not overridden by the rights and interests of children and their families
• Legal obligation: where we are required to retain information under Australian law
• Consent: where we seek consent for specific purposes not covered above, you may withdraw consent at any time

In relation to our interaction pattern analytics, we rely on legitimate interests. We have assessed that this processing is proportionate, limited to de-identified and aggregated data, and serves a genuine benefit — namely, a continuously improving learning experience. We rely on parental consent for the creation of child profiles. By creating a child profile, the Account Holder consents to the collection of that child's learning and interaction data as described in this Policy.

We do not sell your personal information or your child's personal information to anyone, under any circumstances. We share information only with:

• Our payment processor (for subscription billing — subject to their own privacy policies)
• Our cloud hosting provider (for secure storage of app data)
• Analytics tools used to understand aggregate app performance (no individual child data is shared in identifiable form)
• Law enforcement or regulators where required by Australian law

Any third-party service providers we engage are contractually required to handle personal information in accordance with the APPs and to use it only for the specific purpose for which it was shared.

Because this App is specifically designed for children aged 2–8, we apply the following additional protections:

• Account creation requires a parent or guardian aged 18 or over — children cannot create their own accounts
• We collect only the minimum information necessary from child profiles
• Interaction pattern data is collected and analysed in aggregated, de-identified form only — individual children are never singled out or profiled
• Interaction pattern analytics are used solely to improve the App and inform future product development — not for advertising, not for sale to third parties, and not to make automated decisions about individual children
• We do not display advertising within the App
• We do not allow children to communicate with other users
• We do not share children's learning or interaction data with schools, teachers, or other third parties without explicit parental consent
• Parents may request deletion of all child profile data at any time (see Section 10)
• Parents may contact us at any time to ask what interaction data has been collected in connection with their child's profile and how it has been used

We are actively monitoring the development of the OAIC's Children's Online Privacy Code (due December 2026) and will update our practices and this Policy as required when the Code comes into force.

Your data is stored on secure servers. We use industry-standard security measures including:

• Encryption of data in transit (TLS) and at rest
• Access controls limiting who within our organisation can access personal information
• Regular security assessments

No method of electronic transmission or storage is 100% secure. While we use commercially reasonable measures to protect your information, we cannot guarantee absolute security. In the event of a data breach likely to result in serious harm, we will notify affected individuals and the OAIC in accordance with the Notifiable Data Breaches scheme under the Privacy Act.

We retain personal information for as long as necessary to provide the service and meet our legal obligations:

• Account and subscription data: retained while your account is active and for 7 years after closure for tax and accounting purposes
• Child learning progress data: retained while your account is active; deleted within 30 days of account closure or upon request
• Support correspondence: retained for 2 years

When data is no longer required, we delete or de-identify it securely.

As an Account Holder, you have the right to:

• Access the personal information we hold about you and your child — contact us and we will respond within 30 days
• Correct inaccurate or incomplete information — you can update most information directly in the App
• Request deletion of your account and all associated data — we will complete this within 30 days
• Request deletion of a specific child's profile while keeping your account active
• Withdraw consent to specific uses of your information
• Lodge a complaint with the OAIC if you believe we have breached the APPs

To exercise any of these rights, contact us at privacy@learnwithhupe.com.au.

The App itself does not use cookies. Our website may use essential cookies for session management and analytics cookies to understand how visitors use the site. You can control cookie preferences through your browser settings. We do not use advertising cookies or cross-site tracking technologies.

Our primary servers are located in Australia. If any data is processed outside Australia, we take steps to ensure it receives equivalent protection, including by using providers that adhere to recognised international privacy frameworks.

We may update this Policy from time to time. If we make material changes that affect how we handle children's data, we will notify Account Holders by email before the changes take effect. Continued use of the App after notification constitutes acceptance of the updated Policy.

For privacy questions or to exercise your rights:

• Email: privacy@learnwithhupe.com.au
• Website: learnwithhupe.com.au/privacy

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 or by calling 1300 363 992.