NZGrader Privacy Policy

1. Introduction

WordFrame, a Young Enterprise Scheme virtual company, operates NZGrader ("the Service"). We are committed to protecting your privacy and handling your personal information responsibly in accordance with the Privacy Act 2020 (NZ).

This Privacy Policy explains what information we collect, why we collect it, how we use and store it, who we share it with, and what rights you have over your data. It should be read alongside our Terms and Conditions.

If you have any questions about this policy, contact us at support@nzgrader.com.

2. Who This Policy Applies To

This policy applies to all users of NZGrader, including:

• Teachers and educators using the Service to assist with marking
• Students using the Service to receive feedback on draft work
• Visitors to the NZGrader website who have not created an account

3. What Information We Collect

3.1 Account Information

When you register, we collect your name, email address, and role (teacher or student). Teachers may also provide their school name.

3.2 Submitted Content

When you use the Service, we collect the content you submit — including student work, assessment tasks, and achievement criteria. This content is stored in your submission history for as long as your account is active.

3.3 Generated Feedback

The grade suggestions and feedback generated by NZGrader in response to your submissions are stored alongside your submitted content as part of your submission history.

3.4 Usage Data

We collect data about how you interact with the platform, including pages visited, features used, credits consumed, and actions taken within your account.

3.5 Technical Data

We automatically collect technical information when you access the Service, including your IP address, browser type, device type, and operating system.

3.6 Communications

If you contact us by email or through the platform, we retain records of that correspondence.

4. How We Collect Information

We collect information directly from you when you register, submit content, or contact us. We also collect usage and technical data automatically through your use of the platform, including through analytics tools (see clause 8).

5. Why We Collect and Use Your Information

We use your information for the following purposes:

• To create and manage your account
• To deliver the core Service — processing submitted content through our assessment algorithm and returning grade suggestions and feedback
• To store your submission history so you can review past work and feedback
• To manage your subscription and process billing
• To send you service-related communications (account notices, billing, updates to these policies)
• To monitor and improve the performance and reliability of the platform
• To understand how users interact with the Service through analytics
• Where you have given consent, to use de-identified content to improve our AI models (see clause 9)
• To comply with our legal obligations

We do not use your information for advertising purposes and we do not sell your personal information to any third party.

6. How Our Assessment Algorithm Works

NZGrader's assessment engine is a multi-step, multi-layered algorithm. The grade suggestions and feedback it produces are the output of this algorithm as a whole — no single component, including any language model, solely determines a suggested grade.

Certain steps within this algorithm make use of large language models as one input among many. The third-party AI providers whose models are involved at these steps are:

• Anthropic (Claude) — based in the United States
• OpenAI (GPT models) — based in the United States
• Google (Gemini models) — based in the United States

When submitted content passes through any of these models as part of the algorithm, it is processed on servers operated by those providers, which are located outside New Zealand. This constitutes an offshore disclosure of personal information under the Privacy Act 2020. By using the Service, you acknowledge and consent to this transfer.

We take reasonable steps to ensure each of these providers maintains appropriate data protection and security standards. Links to their respective privacy policies are provided below:

• Anthropic: anthropic.com/privacy
• OpenAI: openai.com/privacy
• Google: policies.google.com/privacy

7. Data Storage and Retention

Your account information, submitted content, and generated feedback are stored on secure cloud infrastructure for as long as your account remains active. This data powers your submission history feature.

You may delete individual history entries at any time through your account settings. You may request deletion of all your stored content by emailing support@nzgrader.com and we will complete this within 10 business days.

When your account is closed, all stored content and personal information is permanently deleted within 90 days, unless you request earlier deletion.

We do not retain your data for longer than is necessary for the purposes described in this policy.

8. Analytics and Tracking

We use Google Analytics to help us understand how users interact with NZGrader. Google Analytics collects data such as pages visited, session duration, device type, and general location (derived from IP address). This data is aggregated and used solely to improve the platform.

Google Analytics data is processed by Google LLC, which is based in the United States. Google's privacy policy is available at policies.google.com/privacy.

You may opt out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

We do not use cookies for advertising or cross-site tracking purposes.

9. AI Training and Model Improvement

We will only use submitted content to train or improve AI models with your explicit, opt-in consent. This option is presented during onboarding and can be changed at any time through your account settings.

Where consent is given, we use only anonymised and de-identified versions of submitted content. We do not use personally identifiable information for AI training purposes.

Withdrawing your consent does not affect any use of de-identified content that occurred before withdrawal.

If you have not given consent, your submitted content will never be used for AI training or model improvement purposes.

10. Sharing Your Information

We do not sell, rent, or trade your personal information. We share your information only in the following circumstances:

• AI providers — as described in clause 6, to deliver the assessment algorithm
• Analytics providers — as described in clause 8, to understand platform usage
• Hosting and infrastructure providers — to store and serve the platform securely
• Legal requirements — if required to disclose information by law, court order, or regulatory authority
• Business transfer — in the unlikely event that WordFrame's operations are transferred or wound up, users will be notified and their data handled in accordance with this policy

All third-party providers we engage are required to handle your information securely and only for the purposes we specify.

11. Security

We take reasonable technical and organisational measures to protect your personal information from unauthorised access, loss, misuse, or disclosure. These include encrypted data transmission (HTTPS), secure cloud infrastructure, and access controls limiting who within WordFrame can access user data.

However, no system is completely secure. We cannot guarantee the absolute security of information transmitted over the internet. If you believe your account has been compromised, contact us immediately at support@nzgrader.com.

12. Your Rights Under the Privacy Act 2020

Under the Privacy Act 2020, you have the right to:

• Access the personal information we hold about you
• Correct any personal information that is inaccurate or incomplete
• Request deletion of your personal information, subject to any legal obligations we have to retain it
• Withdraw consent to AI training use at any time
• Make a complaint if you believe we have breached the Privacy Act 2020

To exercise any of these rights, contact us at support@nzgrader.com. We will respond within 20 working days as required by the Privacy Act 2020.

13. Children and Young People

Users aged 13–17 may use the Service with the consent of a parent or legal guardian. We do not knowingly collect personal information from children under 13. If we become aware that a user is under 13, we will delete their account and associated data promptly.

Parents or guardians who have concerns about their child's use of NZGrader should contact us at support@nzgrader.com.

14. Complaints

If you have a concern about how we have handled your personal information, please contact us first at support@nzgrader.com. We will acknowledge your complaint within 5 working days and aim to resolve it within 20 working days.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Privacy Commissioner at privacy.org.nz or by calling 0800 803 909.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the Service, legal requirements, or our data practices. For material changes, we will notify you by email or through a prominent notice on the platform at least 30 days before the changes take effect.

The date at the top of this policy indicates when it was last updated. Continued use of the Service after changes take effect constitutes acceptance of the updated policy.

16. Contact

WordFrame (Young Enterprise Scheme Virtual Company)
support@nzgrader.com