Ticket Coach

Privacy policy

Draft, pending legal review

Effective the date you first use the service

1. About this policy

Ticket Coach is run by Tovelly Pty Ltd (ABN 11 685 168 334) ("we", "us"). We handle your personal information in line with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). This policy explains what we collect, why, who we share it with (including overseas), how long we keep it, and your rights.

2. What we collect

• Account details: your name and email address.
• Your practice work:
  • text transcripts of your spoken mock-oral answers
  • your written answers
  • quiz answers
  • your scores and the AI feedback on them
  • any feedback you send us
• Usage information:
  • how often you use each feature
  • session times
  • basic technical data (browser type, IP address, error logs)
• Payment records: what you bought, when, and the amount. We never receive your card details; Stripe handles them.
• Your exam date or access period, if you give it to us.

We do not store recordings of your voice. Your browser converts your speech to text (see section 5) and we receive only the text.

We do not ask for sensitive information such as health details. Please do not include sensitive information, or other people's personal details, in your answers.

3. How we collect it

We collect information directly from you when you sign up, pay, use the service or contact us. Our sign-in, hosting and payment providers collect some technical information automatically when you use the site.

4. Why we use it

We use your information to:

• create and secure your account;
• run the mock oral, papers and quiz, and mark your answers using AI;
• show your progress and history;
• process payments and keep financial records;
• send service emails (sign-in codes, receipts, important changes);
• answer questions, fix problems and prevent misuse such as shared logins;
• improve our questions and marking, using de-identified data where we can;
• meet our legal obligations.

Marketing: we send marketing emails only if you opt in. Every marketing email has an unsubscribe link, and we act on it within 5 business days.

We do not sell your personal information.

5. AI and automated marking

Your answer transcripts and written answers are sent to our AI provider, which generates the examiner's follow-up questions and marks your answers against key points. The marks and feedback are produced automatically by a computer program, without a person reviewing each one.

These marks are for practice only. They do not affect your real exam, your certificate or any legal right, and we do not share them with your employer, RSHQ or WorkSafe WA. If you think a mark is wrong, tell us and a person will look at it.

Speech recognition. Voice-to-text conversion is done by your web browser's built-in speech service, not by us:

• In Google Chrome, your voice audio is sent to Google's servers for conversion.
• In Safari, it is processed by Apple, either on your device or on Apple's servers.

This processing is governed by your browser provider's own privacy terms. If you would rather not use voice, you can type your answers instead.

Examiner voice. To create the examiner's spoken questions, we send the question text (not your answers) to Microsoft Azure Speech in Australia.

6. Who we share it with

We share personal information only with service providers that help us run Ticket Coach, and only as much as each one needs:

Our providers process data under their own security and data processing terms. Our AI provider's commercial terms do not allow it to use our customers' inputs to train its models.

We may also disclose information:

• where the law requires it;
• to protect someone's safety;
• to professional advisers;
• to a buyer if our business is sold (they must keep handling it under this policy).

7. Overseas disclosure

Your information is likely to be stored or processed in the United States, and payment data may also go to Stripe's facilities outside Australia. Before using an overseas provider, we take reasonable steps to make sure it protects your information to a standard consistent with the APPs.

8. How we keep it secure

• Information is stored in encrypted, access-controlled cloud systems.
• Data is encrypted in transit (HTTPS).
• Only people who need access to run the service have it.

No online system is completely secure. If a data breach is likely to cause you serious harm, we will tell you and, where required, the OAIC.

9. How long we keep it

• Transcripts, written answers, scores and quiz answers: until you delete your account, or 24 months after your access ends, whichever comes first.
• Account details: until you delete your account, or 24 months after your access ends.
• Payment and tax records: 7 years, as required by law.
• De-identified data: we may keep it to improve the service; it cannot identify you.

After these periods, we delete or de-identify your information.

10. Access, correction and deletion

You can ask for a copy of the personal information we hold about you, or ask us to correct it, at any time. Email ben@tovelly.com.au. We will respond within 30 days and will not charge you. If we refuse a request, we will explain why in writing.

You can ask us to delete your account by emailing us. We will then delete your practice records and account details within 30 days, except records we must keep by law.

11. Complaints

If you are concerned about how we have handled your personal information:

1. Email us at ben@tovelly.com.au with the details.
2. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days.
3. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au, phone 1300 363 992.

12. Changes to this policy

We will post any update on this page with a new effective date. If a change is significant, we will email you before it takes effect.

13. Contact

Privacy Officer, Tovelly Pty Ltd
Email: ben@tovelly.com.au