Writer’s Toolbox Privacy Policy

1. We will only ask you for personal information required for the effective functioning of the Writer’s Toolbox platform and your use of it.
   
   
2. In collecting, holding, using, disclosing and otherwise managing your personal information, Writer’s Toolbox will, amongst other requirements, comply with relevant data protection, privacy legislation and privacy principles.
   
   
3. Use of the Writer’s Toolbox platform or our other products or services by students may require us to collect personal information from the student.
   
   
4. If a student is aged under 13 years, we will only collect personal information from that student where the student’s school has undertaken to us to obtain a consent from a parent or guardian of the student for that student to use Writer’s Toolbox or our other products and services and disclose personal information to us.
   
   
5. The student’s school should only provide class passwords (which enable students to access Writer’s Toolbox) to students aged under 13 years where such a consent has been obtained in relation to that student.
   
   
6. If you are a student aged under 13 years, please do not provide personal information to us or otherwise use Writer’s Toolbox or our other products or services unless such a consent has been provided by your parent or guardian. If you are unsure, speak with your parent or guardian

1. We collect personal information about you from various sources, including:
   Information your school supplies to us;
   Information you supply to us; and
   Information gathered through your use of the site, such as the content you access.
   
   
2. We require the following information to create student and/or teacher accounts:
   Student/ Teacher Name (mandatory);
   School name (mandatory);
   A unique email address (mandatory);
   Year level student is enrolled in (mandatory);
   Classes enrolled in (optional);
   Ethnicity (optional);
   Gender (optional);

Please visit our Cookies page for detailed information on the browser Cookies used throughout this website.

1. We use personal information we collect about you to:
   Create user accounts;
   Provide services to you;
   Send you marketing and promotional communications;
   Reset a user’s password, if required;
   Gather and respond to feedback and reports of technical problems;
   Enforce or apply our terms and conditions;
   Protect our rights or the rights of others; and
   Comply with laws.
   
   
2. We also collect statistics about how you use our site for the purposes of making improvements to the site and our services, and for educational research and marketing. For example, we may record which learning modules are more popular, or the aggregate scores of students undertaking the learning modules. This information will only be used as aggregate (grouped) data and will not contain personally-identifying information.

We only collect and process your personal data where we have a lawful basis for doing so. In our case, we will only process your personal data if:

1. you provided your consent: For example, when you subscribe to our events newsletter, or agree to receive marketing communications. You have the right to withdraw your consent at any time, for example by clicking the unsubscribe link in our emails, managing your communication preferences in your account, or contacting comms@wtbox.com.
   
   
2. you entered a contract with us: for example, when you purchase a product or service from us.
   
   
3. we obtained your contact information from a third-party supplier who assured us they obtained your details lawfully and with a legal basis for transfer. We have conducted a Legitimate Interests Assessment (LIA) and determined that the minimal impact of this communication is outweighed by our legitimate business interest in engaging with relevant contacts. You retain the right to object or opt out at any time.

1. The security of your personal information is important to us. Our company is established and headquartered in New Zealand with operations and offices elsewhere in the world. We store your personal information electronically on our secure servers in Sydney hosted by Amazon. These are full-service backups which give us the ability to quickly restore the service in case of an emergency. From time to time, we may securely transfer your personal information to our offices only where necessary in connection with our operations and providing our services to you.  We will always endeavour to keep your data safe whenever we move it and will handle and transfer your personal information carefully and in accordance with applicable laws.
   
   We follow generally accepted industry standards to protect the personal information submitted to us. However, no data storage or transfer mechanism is 100% secure so we cannot absolutely guarantee the security of your information.  It is your responsibility to ensure that your access details (username and password) are kept private and to inform us if you believe that the security of your account has been breached.  We currently follow the New Zealand Privacy Commissioner plan in the case of a data breach. Website / Privacy Breach Guidelines.
   
   If you believe there has been a breach of privacy involving your personal information, please contact:
   
   Writer's Toolbox Global Privacy Officer
   Calling us at (+64) 9 624 6886
   Emailing us at support@wtbox.com
   
   Writing to us at Postal address: PO Box 24687, Royal Oak, Auckland 1345, New Zealand,
   Please note that we may need to verify your identity or authority before responding to your request. Once verified, we will respond to your request or query as soon as possible, and no later than 20 working days after we receive it.
   
   
2. Personally identifiable data (user name, user ID, and user email address) will be deleted as soon as possible after the relevant transaction has been completed. Writer's Toolbox must not retain customer personally identifiable information longer than necessary for lawful purposes and must delete information in compliance with the Writer's Toolbox Retention & Disposal Schedule Policy. We may retain your personal information for up to three years after you cease using our services, unless you request that your personal information be deleted, and the erasure is in accordance with relevant laws (including the UK and EU GDPR).
   
   One of the reasons we retain your data for this period is to provide continuity in your service experience.  For instance, if you or your school decide not to re-subscribe to our service for a period of time, we retain your account and historical data to ensure that, should you return, your previous work and information remain accessible and associated with your account.  This enables you to track your progress and learning journey over multiple years. If your account remains inactive for a period of three years, we will delete your account and anonymise your learning data (Writing samples, tests, quiz responses, task, and performance indicators) so that it can only be used in a non-identifying manner for analysis by your school or used by us to improve our products. 

Writer’s Toolbox uses third-party entities (“Sub-processors” listed below) to process customer data on behalf of Writer’s Toolbox customers to perform certain services/activities as required by law or our specific contract with those customers. The list below contains all Sub-processors used across the company for different purposes. Not all entries on this list are applicable to every customer. 

1. Our goal is to provide a learning environment that is every bit as safe and secure as being at school. A student’s full name, learning module scores, and written material are only visible to their teachers. Teachers can only access the information and results of students attending their school.
   
   
2. We will not disclose your personal information to third parties except in the following circumstances:
   Where disclosure is necessary to undertake any of the purposes referred to in clause 3;
   If we are required to provide your personal information in relation to any legal proceedings;
   Where disclosure is required by law.
   
   
3. We will not sell or rent your personal information to third parties.

1. In the event of a privacy breach, we have established procedures for notifying the New Zealand Privacy Commissioner, relevant EU and UK Supervisory Authority and the individual affected (where necessary), including setting out the reasonable steps we have taken to mitigate the effects of a privacy breach, should we be required to do so under law.

1. You have the right to access and correct personal information held by us. You can manage your personal information on the site by using your MY ACCOUNT tab.
2. You have the right to request that your personal data is erased or restricted.
3. If you have any queries about your personal information held by us, or if you would like to make a privacy complaint, you can contact us at:
   
   Writer’s Toolbox
   Postal address: PO Box 24687, Royal Oak, Auckland 1345, New Zealand
   Physical address: 395A Manukau Road, Epsom, Auckland 1023, New Zealand
   Phone: (+64) 9 624 6886
   Email: support@wtbox.com
   
   Australia:
   Writer’s Toolbox
   Physical address: 14/481 Logan Road, Greenslopes, QLD, Australia
   
   United Kingdom:
   Writer's Toolbox
   49 Greek Street
   London
   United Kingdom, W1D 4EG
   
   
4. UK users can also complain to the ICO if you are unhappy with how we have used your data.

   
   The ICO’s address:            
   Information Commissioner’s Office
   Wycliffe House
   Water Lane
   Wilmslow
   Cheshire
   SK9 5AF
   Helpline number: 0303 123 1113
   ICO website: https://www.ico.org.uk

1. We may vary this privacy policy from time to time.  We will provide notice of the change by uploading the updated privacy policy on our site and we will also email you a copy of the updated privacy policy (if you have provided us with your email address).  After providing that notice you will be deemed to have accepted the updated privacy policy if you continue to use our site or the services provided by us.

Data Privacy and Use for UK and European Customers

Writer’s Toolbox policies and practices comply with the GDPR requirements regarding personal data. Personal data can only be transferred out of the EU if:

• The data is transferred to a country that has been determined by the European Commission to have an adequate level of protection (commonly referred to as having “adequacy status”).

New Zealand is one of a small number of non-EU countries that enjoys adequacy status so the limited personal data required to operate and use Writer’s Toolbox can be transferred to New Zealand.

1. For more information about your privacy rights see:
   New Zealand: www.privacy.org.nz
   Australia: www.oaic.gov.au
   GDPR: https://gdpr.eu/