Privacy - Wushka New Zealand - Cloud-based Levelled Reading Program

Modern Teaching Aids Limited CN 305 775 and each of its subsidiaries (MTA,
we, us and our) is committed to managing personal
information in accordance with the Privacy Principles under the Privacy Act 1993 (NZ), the Australian
Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information provided to us through or in
connection with our digital platforms and products, and is referred to as our Digital Privacy
Policy
.

In this Digital Privacy Policy, you refers to any individual about whom we collect
personal information.

The purpose of this Digital Privacy Policy is to explain:

i. the kinds of information that we may collect about you, how we collect that information and how that information is held;

ii. the purposes for which we collect, hold, use and disclose personal information;

iii. how you can access the personal information we hold about you and seek to correct such information;

iv. the way in which you can complain about a breach of your privacy and how we will handle that complaint; and

v. the countries in which your personal information may be stored.

This Digital Privacy Policy applies to all personal information collected by us, or submitted to us, in
connection with our digital, online and/or electronic resources, products, services and platforms, including
personal information collected or submitted through our websites and those of our related bodies corporate,
including (without limitation) teaching.co.nz, lessonzone.com.au and wushka.co.nz (Websites),
through our official social media channel pages which we control (such as our Facebook, Twitter, Pinterest,
Instagram and LinkedIn pages), as well as through email and other messages that we send to you or receive from you.

Other terms and conditions may apply to you such as Website terms and conditions, and any specific privacy collection
notice we provide to you.

MTA carries the largest range of teaching resources and education supplies available in Australia and New Zealand
for primary schools, high schools, secondary schools, childcare centres, daycare centres, preschools and OOSH.
The MTA range includes robotics, digital technologies, art & craft, mathematics, literacy resources, developmental
products, school consumables, STEAM, classroom stationery, science equipment, STEM, sporting gear, school furniture,
books, play and educational toys. Several of these resources, products and services are provided through digital
channels, such as Websites or other online portals. This Digital Privacy Policy applies in connection with personal
information collected through those resources, products and services (amongst other matters).

We value our customers. We value your privacy. We will not sell your data. We only retain your data to
serve you better.

1. What information does MTA collect and hold about you?

The kinds of personal information that we collect and hold about you will depend on the circumstances in which it
is being collected. Some of our main relationships and dealings are described below.

a) Students

We collect information about students from their teachers. We only collect student information which is necessary
to provide students with access to the resources, products and services that we supply. This includes collecting
personal information such as their name, year level, class number and teacher name. If you choose to use pseudonyms
for student names or only give student first names, you will still have full access to each Website and all its
features.

b) Educators and educational institutions

We collect information from educators and educational institutions which is necessary to provide you with goods
and services that we supply (including but not limited to online training platforms, electronic delivery of levelled
reader programs through wushka.co.nz, over 800 pages of curriculum-aligned lesson plans through lessonzone.com.au).
This includes collecting personal information such as your name, address, email address, contact telephone number,
credit card details, bank account details, and any other information which is necessary to assist us in providing
you with our resources, products and services.

c) Attendees at conferences, workshops and professional development sessions

We collect information (which may be used for purposes relating to our digital platforms or Websites) from educators
and educational institutions when you participate in conferences or attend professional development days organised or
facilitated by us or our related bodies corporate. This includes collecting personal information such as your name,
address, email address, contact telephone number and any other information which is necessary to assist us in developing
conferences and professional development to best meet your needs.

d) Competition participants

We collect information from competition or trade promotion participants when you enter competitions either through
our Websites, digital accounts (for example, our Facebook accounts) or through competition forms at conferences,
workshops and professional development sessions. This includes collecting personal information such as your name,
address, email address, contact telephone number and any other information which is necessary to assist us in administering
the competition or trade promotion and awarding prizes to winners.

e) Third party providers and business partners

When we do business with you (because you work for one of our third party providers, suppliers, or other business partners),
a record is made which may include your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the purpose
for which we are dealing with you, but will typically include personal details such as your name, title, email address,
postal address and other business contact details (such as your LinkedIn profile), information about your employer or an
organisation you represent, any additional personal information you provide to us, or authorise us to collect, as part of
your interaction with MTA and other contact details regarding our interactions and transactions with you and the organisation
you represent.

f) Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, title, date of birth, gender, contact details,
qualifications and work history (including references and other information included in a resume or cover letter as part of the
application process). Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment
agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax
file number and superannuation information, and other information necessary to conduct background checks to determine your suitability
for certain positions.

We may also collect relevant information from third party sources such as LinkedIn and other professional websites.

2. What happens if you do not provide your personal information?

You can always decline to give MTA any personal information we request, but that may mean we cannot provide you with some or
all of the resources, products or services you have requested. If you have any concerns about personal information we have requested,
please let us know.

The way in which we handle the personal information of visitors to our Websites is discussed below.

3. How MTA collects personal information

We collect your personal information directly from you when you sign up for a free trial, register an account with us, use our
Websites using a registered account, or use any other of our digital platforms, resources, products or services.

For in-classroom digital products such as wushka.co.nz or ST Math we collect personal information about the students in your
class directly from you in order to be able to set up your virtual classroom.

We may also collect personal information from you when you participate in conferences or attend professional development days
organised or facilitated by us or enter into a competition or trade promotion through our website or through forms at our workshops,
conferences or professional development days.

Sometimes we may need to collect information about you from third parties, such as credit reporting agencies and past employers and
referees. We may be provided with contact lists containing your personal information from a third party such as your company head office,
industry associations, industry consultants or State/Territory-based education departments, provided that we have obtained express consent
from that third party to use your personal information.

We will only collect your personal information from third parties where:

i. you have consented to such collection;

ii. such collection is necessary to enable us to provide you with our teaching resources and education supplies; or

iii. it is legally permissible for us to do.

We will only collect information which is necessary to provide you with our resources, products and services, or to appropriately manage and conduct our business.

4. How MTA uses your personal information, and how it may be disclosed

a) Students

We only use personal information of students to generate a unique identifier by which class teachers can monitor a child’s use of, or
progress with, each of our Websites, resources, products and services.

Student education records are only accessible to users who are logged-in to the relevant platform or Website and have been successfully
authenticated by entering a valid username and password. Teachers can only view students from within their school.

Student data can only be accessed by MTA staff and the third-party software developers who built the platform (for the purposes of
maintenance, system improvement and trouble-shooting). Each third-party software developer is subject to non-disclosure obligations.

b) Educators and educational institutions

We only use personal information from educators and educational institutions to facilitate use of our Websites, resources, products and
services (the primary purpose), unless:

i. you have given your consent for your personal information to be used for a secondary purpose; or

ii. we are required or authorised by law to use your personal information for a secondary purpose, including for research and quality
improvement with our Websites, resources, products and services, for user-support and trouble-shooting, and to comply with our statutory
and other obligations.

For example, we may use and/or disclose your personal information to:

i. make our Websites available to you and provide you with our resources, products and services (including but not limited to teaching
resources and education supplies);

ii. notify you of any of our services and goods of which we consider you may be reasonably interested;

iii. undertake credit checks as part of our credit application process;

iv. appropriately manage our business, including assessing insurance requirements and business processes, quality assurance programs,
billing (in some cases, letting you know that an invoice or account is due for payment or renewal, and to arrange for it to be paid or
renewed), improving our services, implementing appropriate security measures and training personnel;

v. develop our conferences and professional development programs;

vi. administer trade promotions and competitions, and award prizes;

vii. assess your suitability to work within MTA;

viii. effectively communicate with third parties, such as courier companies engaged to deliver any ordered products;

ix. manage any enquiries or complaints you have after you have used our Websites, resources, products or services;

x. research, develop and expand our Websites, resources, products and services, including to develop insights from our interactions
with you to enhance our offerings;

xi. analyse your interactions and use of our Websites, resources, products and services to understand the effectiveness of our
marketing initiatives;

xii. maintain and improve our customer service by monitoring our service for quality control, quality and training purposes;

xiii. manage our relationships with our participating providers, suppliers and other business partners; and

xiv. meet our regulatory and legal obligations.

We generally collect personal information directly from you. We may collect and update your personal information through our Websites,
otherwise online, over the phone, by email, through social media, or in-person.

We may use and disclose your personal information for other purposes explained at the time of collection (such as in a specific privacy
collection statement or notice) or otherwise as set out in this Digital Privacy Policy.

5. Use of personal information for direct marketing

MTA does not directly market to students.

At times, MTA and its agents (including marketing and advertising agencies) may send information to educators and educational institutions
to market our Websites, resources, products and services, and those of our related bodies corporate, associates and business partners (including
without limitation ST Math products provided by the MIND Research Institute), which may be of interest to you and may be based on your
purchasing history with us. You can opt-out of receiving such marketing materials at any time, by clicking the ‘unsubscribe’ button in
any promotional email sent to you, or (in the case of mail, telephone, SMS or social media marketing, by opting out in the manner
specified in the communication (if applicable) or by contacting the Privacy Officer on the details set out below.

If we refer you to a third-party product or service provider (through our Websites, resources, products or services) and you register
with or purchase products from that third-party, you agree that limited personal information about you may be shared between us and that
third-party to facilitate any commissions or fees payable by that third-party to us.

If you opt-out of receiving marketing material from us, MTA may still contact you in relation to any ongoing relationship with you
covered by this Digital Privacy Policy.

6. Data storage, quality and security

a) Data quality

We will take reasonable steps to ensure that all personal information which is collected, used or disclosed is accurate, complete and up to date.

b) Storage

All personal information is stored by us securely in physical or electronic form.

MTA’s ‘Wushka’ and ‘Lessonzone’ Websites, resources and platforms use third-party Amazon Web Services data storage facilities that are
located in Sydney, Australia. MTA’s data storage facilities for its other Websites are its own, and are located in Sydney, Australia.

c) Data security

Your data is stored either in a secure database on Amazon Web Services or in-house by MTA. Access to the servers is either internal or
via vpn and is strictly limited to authorised personnel.

Passwords for users of Websites are encrypted using salt and hash technologies (except for MTA’s NetStore, where passwords are stored in
plain text but access is restricted to authorised personnel).

All data transferred within MTA is protected by SSL. SSL is a technology that makes your data illegible in transit. If anyone were to
intercept communication between our servers and your computer, they would not be able to easily decipher what was being passed back and forth.

When a subscription to the application expires, we only retain the data in our database for as long as is reasonably necessary for the
purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. You can
contact our customer service team and request that this data be deleted at any time (provided that it is no longer required for your use of
our Websites, resources, products and services).

7. Complete and accurate details, and anonymity

Where possible and practicable, you will have the option to deal with us on an anonymous basis or by using a pseudonym. However, if the
personal information you provide to us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the
services or goods you are seeking, or deal with you effectively.

8. How MTA interacts with you via the internet

a) Website use and cookies

You may visit our Websites without identifying yourself. If you identify yourself (for example, by submitting an enquiry or completing a
form), any personal information you provide to MTA will be managed in accordance with this Digital Privacy Policy.

Our Websites also use cookies. A ‘cookie’ is a small file stored on your computer’s browser, which assists in managing customised settings
of the Website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have
accessed on our Websites and on third-party websites. Generally you are not identifiable from such information.

We use cookies to personalise your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor
to our Websites), and to track statistics about the usage of our Websites. This allows us to better understand our users and improve the
layout and functionality of our Websites.

When you visit any of the Websites, our system may collect information about your visit for statistical purposes, including:

i. server address;

ii. top level domain name (for example .com, .gov, .au, .nz, etc.);

iii. the date and time of your visit to the site;

iv. the pages you accessed and documents downloaded during your visit;

v. the previous site you visited;

vi. if you have visited our Website before; and

vii. the type of browser used.

If you do not wish to receive any cookies (other than those that are strictly necessary) you can use the settings in your browser to control
how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our Websites.

b) Third party links

Our Websites may contain links to third-party websites. MTA is not responsible for the content or privacy practices of websites that are
linked to our Websites.

These links are provided for your convenience and do not represent MTA’s endorsement of any linked third party website. We recommend that you
review the privacy policies of these third parties prior to providing them with your personal information.

9. Does MTA disclose your personal information overseas?

We generally collect personal information about you in Australia or New Zealand (as applicable), and your personal information that is stored
by us is stored in Australia only. However, your personal information may be disclosed to overseas recipients including service providers who
may handle, process or store your personal information on our behalf.

We only ever disclose your personal information outside the jurisdiction from which it was collected where we are permitted to do so under
applicable privacy laws. Generally, this means we will take reasonable steps to ensure your personal information is treated securely and
in accordance with applicable privacy laws.

There are other circumstances where we may disclose your personal information to an overseas recipient. For example, where you have provided
your consent or we are otherwise permitted to do so under the New Zealand Privacy Principles or other relevant laws.

10. How you can access or seek correction of your personal information

You are entitled to access your personal information held by MTA on request. To request access to your personal information, please contact
our Privacy Officer using the contact details set out below or contact our customer service team.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You
can assist us by notifying us if there are errors or discrepancies in information we hold about you, or if your personal details change.

If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled
to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the New Zealand Privacy
Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we
will include a statement with your personal information about the requested correction.

In respect of named educators, we may correct the school or other educational institution where you have specified that you are employed or
contracted if evidence comes to our attention that you have commenced employment or contracting services at a different school or other educational
institution, or if you are no longer employed by or provide contracting services to any school or other educational institution. Such actions may
be taken by us in respect of ‘Classroom Connect’ accounts, or any of our other resources, products, services, Websites or portals.

11. Questions and complaints

You may contact MTA at any time if you have any questions or concerns about this Digital Privacy Policy or about the way in which your personal
information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve
the complaint. We will generally respond to your complaint within one week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within one week and
endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and
the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals
involved.

12. Amendments to this Digital Privacy Policy

MTA may amend this Digital Privacy Policy from time to time, with or without notice to you. We recommend that you visit our Websites regularly
to keep up to date with any changes. We also try to let you know about major changes to our Digital Privacy Policy (for example by putting
notices on our Websites or by sending emails).

13. How you can contact MTA

Privacy Officer

Modern Teaching Aids Limited

PO Box 912001

Victoria Street West, Auckland 1142

Email: privacyinfo@teaching.co.nz

This Digital Privacy Policy was last updated on 16 June 2020.