Privacy Policy

1. Introduction

90 Ninety 90 Ninety Pty Ltd (ABN 52 625 708 821) ("ScoreMentor", "we", "us", "our") operates the ScoreMentor platform and mobile application (the "Platform"), a white-label Learning Management System (LMS) enabling coaching centres, education institutes, teachers, and migration agents to offer branded English test preparation services to their students and clients.

This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and, where applicable, the General Data Protection Regulation (GDPR) and India's Digital Personal Data Protection Act 2023 (DPDPA).

By accessing or using the Platform, you agree to the collection and use of information as described in this Privacy Policy.

2. Who This Policy Applies To

This Privacy Policy applies to:

• Institute Partners — coaching centres, education institutes, language schools, teachers, tutors, and migration agents who enter into a white-label licensing agreement with ScoreMentor ("Institute Partner" or "Partner").
• Student Users — individuals who access the Platform through a branded portal operated by an Institute Partner to practise for English proficiency tests.
• Website Visitors — individuals who visit scorementor.com.au or any ScoreMentor web property.

Where an Institute Partner has white-labelled the ScoreMentor Platform under their own brand, their students may not be aware that the underlying technology is provided by ScoreMentor. ScoreMentor acts as a data processor in relation to Student User data collected through white-label portals, with the Institute Partner acting as the data controller.

3. Information We Collect

Information Collected From Institute Partners (B2B)

• Full name and contact details of the account holder and authorised administrators.
• Business or organisation name, ABN, and registered address.
• Billing information (processed securely via our payment provider — we do not store full card details).
• Branding assets (logo, colours, domain name) provided for white-label configuration.
• Communications and support correspondence.
• Platform usage data including login activity, features accessed, and students managed.

Information Collected From Student Users

• Full name and email address (provided by the Institute Partner on enrolment or by the student on registration).
• Country and city of residence.
• Target test type (PTE, IELTS, NAATI CCL, OET, CELPIP, TOEFL, etc.) and target score or visa pathway.
• Practice test responses — including audio recordings of speaking responses, written essay submissions, and answers to reading and listening questions.
• Scores, performance data, section-level analytics, and progress trends generated by ScoreMentor's AI scoring system.
• Device type, operating system, browser type, and IP address.
• Session activity including time spent, pages visited, and features used.
• Communications with the Institute Partner through the Platform's messaging features.

Information We Collect Automatically

• Cookies and similar tracking technologies (see Section 11).
• Log data including access times, pages viewed, and referring URLs.
• Crash reports and performance diagnostics.
• Aggregated and de-identified analytics used to improve the Platform.

Information We Do Not Collect

ScoreMentor does not intentionally collect sensitive information including racial or ethnic origin, political opinions, religious beliefs, sexual orientation, or health information, unless specifically required and consented to for OET healthcare test preparation purposes (in which case collection is limited to professional healthcare specialisation only).

4. How We Use Personal Information

For Institute Partners

• To create and manage your account and white-label configuration.
• To process payments and issue invoices.
• To provide technical support and customer service.
• To communicate about platform updates, new features, and service changes.
• To comply with our legal obligations.
• To enforce our Terms and Conditions.

For Student Users

• To provide AI-scored English test practice across all supported test types.
• To generate individual score reports and progress dashboards visible to the student and their Institute Partner.
• To track score trends and identify section-level weaknesses to personalise the practice experience.
• To deliver homework, mock tests, and assignments set by their Institute Partner.
• To send system notifications about assigned tasks, score reports, and account activity.
• To improve the AI scoring models on an aggregated, anonymised basis.
• To comply with our legal obligations.

Marketing

We do not use Student User data for marketing purposes. We may contact Institute Partners about ScoreMentor products and services, with the right to opt out at any time. We comply with the Spam Act 2003 (Cth) in all commercial electronic messaging.

5. White-Label Data Responsibilities

When Institute Partners deploy the ScoreMentor Platform under their own brand:

• The Institute Partner is the data controller for their students' personal information within the meaning of applicable privacy laws.
• ScoreMentor acts as the data processor, processing Student User data solely on the instructions of the Institute Partner and in accordance with this Privacy Policy and the Data Processing Agreement incorporated into the Partner Terms.
• Institute Partners are responsible for obtaining all necessary consents from their students before enrolling them on the Platform, and for maintaining their own privacy policy that discloses the use of third-party technology providers.
• Institute Partners must not enrol individuals under the age of 13 without verifiable parental or guardian consent.
• Upon termination of the Institute Partner's agreement, Student User data associated with that Partner's account will be retained for 30 days and then permanently deleted, unless export is requested within that period.

6. Disclosure of Personal Information

To Institute Partners

Student User data — including scores, progress reports, practice history, and section analytics — is disclosed to the Institute Partner through whose branded portal the student is enrolled. Students should be aware that their Institute Partner can see their full practice activity on the Platform.

To Service Providers

We share personal information with trusted third-party service providers who assist in operating the Platform, including:

• Cloud infrastructure providers (data hosting and storage).
• Payment processors (billing and subscription management — PCI-DSS compliant).
• Email and communication service providers (system notifications).
• Analytics providers (aggregated, anonymised platform performance data only).

All service providers are contractually bound to protect personal information and may not use it for any purpose other than providing services to ScoreMentor.

Legal Requirements

We may disclose personal information where required by law, court order, or government authority, or where we believe disclosure is necessary to protect the rights, property, or safety of ScoreMentor, its partners, users, or the public.

Business Transfers

In the event of a merger, acquisition, or sale of all or part of ScoreMentor's assets, personal information may be transferred to the acquiring entity, subject to equivalent privacy protections.

We Do Not Sell Personal Information

ScoreMentor does not sell, rent, or trade personal information to third parties for their own marketing or commercial purposes.

7. International Data Transfers

ScoreMentor is based in Australia. The Platform serves users in India, Nepal, Sri Lanka, Pakistan, Bangladesh, and Australia. Personal information may be stored on servers located in Australia and/or in cloud infrastructure regions that may include the United States, Singapore, or other jurisdictions.

Where personal information is transferred outside Australia, we take reasonable steps to ensure the recipient provides a level of protection substantially similar to the Australian Privacy Principles, including through contractual data protection agreements.

Users in the European Economic Area have additional rights under the GDPR including the right to request that transfers be subject to appropriate safeguards such as Standard Contractual Clauses. Please contact us to exercise these rights.

8. Data Security

ScoreMentor implements industry-standard technical and organisational measures to protect personal information against unauthorised access, loss, misuse, or disclosure, including:

• Encryption of data in transit using TLS/SSL protocols.
• Encryption of sensitive data at rest.
• Role-based access controls limiting staff access to personal information.
• Regular security assessments and vulnerability testing.
• Incident response procedures for data breach detection and notification.

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme under the Privacy Act 1988.

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.

9. Data Retention

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

• Institute Partner account data — retained for the duration of the agreement and for 7 years thereafter for tax and legal compliance purposes.
• Student User practice data (scores, responses, progress reports) — retained for the duration of the Partner's active agreement plus 30 days after termination, after which it is permanently deleted unless export has been requested.
• Audio recordings of speaking practice responses — retained for 90 days after the session date, then automatically deleted.
• Aggregated and de-identified analytics data — may be retained indefinitely.
• Communication and support records — retained for 3 years.

10. Your Privacy Rights

Under Australian Law (Privacy Act 1988)

Under the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate, incomplete, or out-of-date personal information.
• Make a complaint about our handling of your personal information.
• Request that we do not use your personal information for direct marketing.

Under GDPR (EU/UK Users)

If you are located in the European Economic Area or United Kingdom, you have additional rights including:

• The right to erasure ("right to be forgotten").
• The right to restriction of processing.
• The right to data portability.
• The right to object to processing.
• Rights related to automated decision-making (see Section 12 regarding AI Scoring).

Under India's DPDPA 2023

If you are located in India, you have the right to access, correct, and erase your personal data, and to nominate a person to exercise your rights in the event of death or incapacity. You may also withdraw consent at any time.

How to Exercise Your Rights

To exercise any of the above rights, contact us at support@scorementor.ai. We will respond within 30 days. We may require identity verification before processing requests. Where requests relate to Student User data held through an Institute Partner's portal, we may direct you to the Institute Partner as the data controller.

11. Children's Privacy

The Platform is not intended for use by children under the age of 13 without the verified consent of a parent or guardian. Institute Partners must not enrol students under 13 without such consent.

Where ScoreMentor becomes aware that personal information has been collected from a child under 13 without appropriate consent, we will take steps to delete that information promptly.

Students aged 13 to 17 may use the Platform where the Institute Partner has confirmed parental or guardian consent has been obtained in accordance with applicable law.

12. Cookies and Tracking Technologies

The Platform uses cookies and similar technologies to:

• Maintain your login session and Platform preferences.
• Measure Platform performance and usage patterns.
• Improve functionality and user experience.

We use essential cookies (required for the Platform to function) and analytics cookies (used to understand usage patterns on an aggregated basis). We do not use advertising or third-party tracking cookies.

You may configure your browser to refuse cookies, but this may affect Platform functionality. By continuing to use the Platform, you consent to our use of essential cookies.

13. Automated Decision-Making and AI Scoring

ScoreMentor uses artificial intelligence and machine learning models to score student practice test responses. These AI scores are used to:

• Provide instant feedback on speaking, writing, reading, and listening performance.
• Generate section-level analytics and progress reports.
• Suggest areas for improvement.

AI scores are predictions and approximations — they are not official test scores and should not be relied upon as guarantees of performance in official examinations. Significant decisions (such as visa applications) should not be based solely on ScoreMentor AI scores.

Institute Partners and students may request human review of AI-generated scores by contacting support@scorementor.ai within 14 days of the score being generated.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify Institute Partners of material changes by email at least 30 days before the changes take effect. Continued use of the Platform after the effective date constitutes acceptance of the updated policy.

The current version of this Privacy Policy is always available at scorementor.com.au/privacy.

15. Complaints and Contact

If you have a complaint about our handling of your personal information, please contact our Privacy Officer:

ScoreMentor Privacy Officer Email: support@scorementor.ai Mailing address: Blossom Drive, Melbourne VIC 3000, Australia

If you are not satisfied with our response, you may lodge a complaint with:

• Office of the Australian Information Commissioner (OAIC) — oaic.gov.au
• For EU/UK residents: your local data protection authority.
• For Indian residents: Data Protection Board of India (once operational).