Customer resources · Draft

Privacy policy

1 · Who we are

PWE GROUP PTY LTD, ABN 55 606 664 546, ACN 606 664 546, trading as PWE Studio, supplies the PWE Studio software to creative studios — art, music, dance, tutoring and similar teaching businesses.

We operate in Australia and handle personal information with reference to the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Whether and how the Act applies to a particular studio depends on that studio’s own circumstances, which is a question for its own adviser.

• Location: Caulfield North, Melbourne, Victoria, Australia
• Privacy enquiries and complaints: info@pwestudio.site
• Privacy contact: Lee L

2 · Who is responsible for what

This matters more than it sounds, because PWE Studio is sold in two forms and the answer differs.

Separately from either form, we hold a small amount of information about the studio as our customer: contact names, business email and phone, billing details and support correspondence. That is our own record and this policy governs it directly.

3 · What information the product handles

The product asks families for the minimum it needs. It does not ask for identity documents, government identifiers, health information or payment-card numbers, and none of those should be entered into any field. Enquiry forms carry a collection notice at the point of collection, and the consent a family gives is recorded against the version of the notice they were shown.

4 · Children’s information and publication consent

Most students at a creative studio are children, so this is the part of the product designed most conservatively.

Private by default

Every photograph of student work is private when it is uploaded. It is visible to studio staff with the appropriate role, and to the family that holds that student’s access code — nobody else. Original files are never served publicly; public and family views are generated derivatives, and every request is checked against the owning studio.

Who can see one student’s records

A family unlocks the student area with the student’s name, the registered mobile number and a six-digit code the studio issues. That combination reveals that one student’s credit balance, next class, attendance and work — and nothing about any other student. Attempts are rate-limited and locked temporarily after repeated failures. The weekly schedule export excludes student and guardian identities. A separate daily roster export may contain student names because it is an operational attendance file; it is restricted to staff with data-export permission, is marked private before download and never contains guardian names.

Publication requires a separate, recorded decision

Showing a student’s work on a studio’s public website or in promotional material is a distinct decision, never implied by enrolment. The registration form has a separate optional consent; ticking it requires naming the consenting person and their relationship to the student — the student themselves if an adult, a parent, or another authorised guardian. Each consent event is stored with who gave it, the relationship claimed, the method and the time, so a studio can later show what it was authorised to publish.

Withdrawing consent

Consent can be withdrawn at any time, without giving a reason, by contacting the studio. Withdrawal is recorded as its own event beside the original consent, and the work returns to private. Two honest limits: material a studio has already printed, or that a third party has already copied elsewhere, cannot be recalled by us; and withdrawal removes public display, it does not delete the teaching record, which is handled under section 7.

The studio, not us, is responsible for confirming that the person giving consent actually has authority for that child. The product records the claim; it cannot verify a family relationship.

5 · Where information is held

For subscription customers, data is held in Amazon Web Services’ Sydney region (ap-southeast-2), on the instance that runs the service: PostgreSQL beside the application, and media files on an attached volume. Backups are produced daily and are currently stored on the same instance; an off-instance copy is an open item we disclose rather than imply. Transport is encrypted with TLS, HTTP requests are redirected to HTTPS, and the application is not directly reachable from the internet.

We do not transfer personal information overseas for our own purposes. Support correspondence you send us may pass through the email provider you chose to use.

6 · How information is protected, and what is still missing

We list the gaps because a privacy policy that only lists controls is a sales document. The Australian Cyber Security Centre treats multi-factor authentication, patching and tested backups as core measures for a small business; we treat MFA and an off-instance backup copy as work owed, not optional polish.

7 · Retention and deletion

While a studio is a customer, its records are kept for as long as it needs them to run classes and account for credits. The studio decides what to keep and what to remove, and can correct or delete a student record at any time from within the product.

After a subscription ends we make a standard export available for a limited window, then delete or de-identify the data according to the agreed deletion schedule, except where a law requires longer retention. Backup expiry takes longer than live deletion because a backup is a point-in-time copy; the exact figures belong in the production backup schedule and the signed agreement rather than on this page.

8 · Access, correction and complaints

If you are a student or family member, ask your studio first — it holds the relationship and can act on the record directly. If a studio cannot resolve it, or if your question is about information we hold as the software supplier, email info@pwestudio.site. We will acknowledge the request, confirm who you are by a means that does not create a new risk, and respond within a reasonable period.

We do not publish a response deadline here. Support response targets exist only where a signed order form states them, and they are initial-response targets rather than resolution guarantees. A request under privacy law is answered within the period that law requires, which is not something we shorten by writing a number on this page.

We publish a location rather than a street address, so email is currently the channel for written requests. If you need to correspond by post, ask us and we will supply a postal address for that request.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner. We would rather hear from you first, but that path is yours regardless.

9 · If something goes wrong

On a suspected data incident we contain access and preserve evidence; identify which studios, people and data types are affected; rotate exposed credentials and revoke sessions; assess likely harm; notify the affected studio’s contact without unreasonable delay; agree who leads any notification to families and to the regulator; restore only from verified evidence; and write up cause, decisions and follow-up tests.

Australia’s Notifiable Data Breaches scheme requires covered entities to notify affected individuals and the Commissioner where a breach is likely to cause serious harm. Which entity is covered, and who notifies, must be assessed at the time rather than assumed — the studio usually has the direct relationship with the families.

Breach notifications and security reports reach us at info@pwestudio.site, attention Lee L, Privacy Contact. If you believe student information has been exposed, say so in the subject line and do not include the exposed data itself in the message.

10 · Changes to this policy

Collection notices inside the product carry a version, and a family’s consent is recorded against the version they were shown. If we change this policy in a way that materially affects how information is handled, we will tell subscribed studios in writing before the change takes effect.