Privacy Policy

This Privacy Policy explains how Ember Education Pty Ltd (“Ember Education”, “we”, “us”, “our”) handles personal information when you use Lantern, our report-comment writing tool for Australian schools. We are bound by the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs), and this policy is structured to reflect them.

Lantern is provided to schools and their teachers. In most cases the school is the entity that decides what student information is entered and why; Ember Education handles that information on the school’s behalf under our agreement with the school. This policy describes our practices across both our own collection (for example, teacher accounts) and our handling of information on behalf of schools.

What personal information we collect

We collect two broad categories of personal information.

Teacher account information. When a teacher is enrolled in Lantern, we collect their name, work email address, the school or organisation they belong to, their role, authentication details (including identifiers from single sign-on providers such as Microsoft), and records of their activity in the product such as the comments they author, drafts they save, and settings they choose.

Student information. Lantern is designed to hold the minimum about students. Students do not have accounts and cannot log in. A student exists in Lantern only as a name on a class roster, together with the notes, observations, and report comments a teacher chooses to author about that student. We do not collect student contact details, dates of birth, government identifiers, health information, or login credentials, and we ask schools not to enter such information.

We do not knowingly collect sensitive information (as defined in the Privacy Act) beyond what a teacher may voluntarily include in free-text comments. We ask teachers to record only information that is relevant and proportionate to writing a report.

Why we collect it (purpose)

We collect personal information for the purpose of providing the Lantern service, namely to:

• authenticate teachers and administer their access on behalf of their school;
• help teachers draft report comments in their own voice, check those comments against their school’s reporting rules, and refine them;
• keep an immutable audit trail of how comments were generated, edited, and approved;
• provide support, maintain security, prevent misuse, and meet our legal obligations.

The teacher always remains the author and approver of every comment. Lantern does not finalise or send a report on a teacher’s behalf.

How we store and secure it

All Lantern data is hosted onshore in Australia. Our primary infrastructure is in the AWS Asia Pacific (Sydney) region, with disaster-recovery capacity in Melbourne. Personal information is encrypted in transit (TLS) and at rest, access is restricted on a need-to-know basis, and administrative access is logged.

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure, consistent with APP 11. No system can be guaranteed to be perfectly secure, but we maintain controls proportionate to the sensitivity of the information we hold and review them regularly.

How we use it

We use personal information only for the purposes described above, and for directly related purposes a teacher or school would reasonably expect. We do not sell personal information, and we do not use student information for advertising or marketing.

When we disclose it

We disclose personal information only where necessary to operate Lantern, and only to recipients bound by appropriate confidentiality and security obligations. This includes our infrastructure and sub-processors, listed and described on our sub-processors page. We may also disclose personal information where required or authorised by law.

Cross-border disclosure (APP 8)

Lantern is built to keep your data in Australia. Personal information entered into Lantern — including student names and teacher-authored comments — is stored and processed in Australian data centres (AWS Sydney, with disaster recovery in Melbourne) and is not transferred overseas in the ordinary course of providing the service.

Where any limited operational data (for example, certain account or billing metadata) would be handled by a provider outside Australia, we identify that provider and the country involved on our sub-processors page, and we take reasonable steps under APP 8 to ensure the recipient handles the information consistently with the APPs.

AI processing and training

Lantern uses artificial intelligence to help teachers draft and refine report comments. To do this, the relevant text (such as a teacher’s notes and the draft they are working on) is processed by AI models.

Your data is never used to train AI models. We do not use student information or teacher-authored content to train, fine-tune, or improve any AI model, whether ours or a provider’s. We contractually require our AI providers to refrain from training on, or retaining for their own purposes, any data we send for processing.

AI processing for Lantern runs on Australian-region infrastructure. The specific AI providers that process Lantern data are named and described on our sub-processors page.

Retention and deletion

We retain personal information only for as long as it is needed to provide Lantern to the school, or as required by law. When a school or a teacher deletes content, or when a school’s use of Lantern ends, we purge the associated personal information from our active systems within 30 days, and from backups within the normal backup-rotation period thereafter.

Records that must be kept to demonstrate the integrity of the audit trail are minimised and retained only as necessary.

Accessing and correcting your information

Under APP 12 and APP 13, you may request access to the personal information we hold about you and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading. Because much of the information in Lantern is held on behalf of a school, requests about student information are usually best directed to the relevant school in the first instance; we will assist the school to respond.

To make a request, contact us using the details below. We will respond within a reasonable period and will not charge to make a request, though a reasonable cost may apply to giving access in some circumstances. If we decline a request, we will explain why and how you can complain.

How to make a complaint

If you believe we have mishandled your personal information or breached the Australian Privacy Principles, please contact our Privacy Officer using the details below. We will acknowledge your complaint and aim to respond within a reasonable period.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Data breaches (the NDB scheme)

We are subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). We maintain a data-breach response plan. If we suspect a data breach, we will contain and assess it promptly.

Where a breach is likely to result in serious harm to any affected individual and we cannot prevent that harm through remedial action, we will notify the affected individuals and the OAIC as required by the scheme. Where a breach affects information we hold on behalf of a school, we will also notify the school promptly so that it can meet its own obligations.

Children’s privacy

Lantern is a tool for teachers, not for children. Students do not have accounts and cannot access Lantern. We apply data minimisation to student information — a student is represented only by a name and the comments a teacher authors — and we design the product with the best interests of the child as a primary consideration.

We monitor developments in children’s privacy regulation, including the OAIC’s developing Children’s Online Privacy Code, and will update our practices to align with it as it is finalised.

Related policies

This policy should be read together with our Cookie Policy, our sub-processors list, and our Terms of Service.

Contact us

For any privacy enquiry, request, or complaint, contact our Privacy Officer:

• Email: privacy@embereducation.com.au
• Post: [PLACEHOLDER: registered postal address]
• ABN: [PLACEHOLDER: 11-digit ABN]
• ACN: [PLACEHOLDER: 9-digit ACN]