Nexties Classroom: Student Data Privacy Notice

Last updated: [DATE]

Introduction

This notice explains how Nexties Classroom, provided by Liven Labs Limited (“Nexties”, “we”, “us”, “our”), collects, uses, stores, and protects the personal information of students when a school uses Nexties Classroom.

This notice sits alongside our general Privacy Policy and applies specifically to student data collected through Nexties Classroom. Where there is a difference between this notice and our general Privacy Policy in relation to student data, this notice applies.

We comply with the Privacy Act 2020.

How students access Nexties Classroom

Nexties Classroom is set up per school using the school’s own email domain. Any student with a valid email address on that domain can create an account, signing in with their Microsoft or Google school account. Schools can also choose to send students a bulk invitation email, which simply invites them to complete the same sign-up process.

A student can request, at any time, to transfer the email address linked to their account to a personal address, for example if they are finishing school or moving to a different school. Once actioned, this moves their account to the general Nexties Platform, governed by our general Terms of Use and Privacy Policy, and means the school no longer receives new information about that student.

What we collect

We collect:

• Name and school-issued contact details
• Responses given during a student’s conversations with Nexties Classroom’s AI features, covering their interests, strengths, and study or career preferences — provided by typing, or by using the optional voice input feature
• Insights and observations generated to support the student’s career or pathway exploration
• Future Selves (pathway explorations) and course recommendations generated from those conversations
• Usage information: messages sent, time spent, session count, current stage, and last active date
• Contextual factors a student chooses to share that affect their pathway options, such as health considerations or physical ability, family or caregiving responsibilities, learning barriers, or sources of stress

Some of what a student shares is personal in nature. Information in the last category above is used only to keep guidance relevant to that student.

We do not collect more information than is needed to provide career and pathway guidance to the student.

Who can see a student’s information

This is the most important section of this notice.

Always private to the student, never visible to the school:

• The student’s raw conversation transcripts with Nexties Classroom.

Visible to school staff with permission for that student:

• Insights and observations generated to support the student’s career or pathway exploration.
• Future Selves (pathway explorations), including whether the student has accepted or rejected them.
• Course recommendations, including which the student has saved.
• Usage information such as time spent, number of messages, current stage, and last active date. This helps careers advisors identify students who may benefit from a check-in — for example if a student hasn’t returned in several days or has been in one stage for an unusually long time — rather than to monitor students generally.
• A one-to-one preparation report, which an administrator can generate on demand before meeting a student. It contains a short overview, the student’s interests, a neutral summary of their engagement and tone, a few suggested questions to open a conversation, and their psychometric results (such as RIASEC, Big Five, Schwartz Values, Kolb learning style, and archetype).

Any AI-generated summary or insight feature, now or in future, will draw only on the categories of information above and will never expose a student’s underlying conversation transcript.

We do not share student information with any third party outside the school, except:

• Where required by law
• With service providers who help us run the platform (see “Who else touches this information” below)
• Where a student separately chooses to use a feature that explicitly requests further consent

Cohort and aggregate reporting

Schools have access to a dashboard summarising activity across their student cohort, including metrics such as average progress, engagement levels, and highlights of students who may benefit from a check-in. This dashboard is built from the same categories of individual student information described above, rolled up across the school’s students. It does not expose any category of student information beyond what is already described in this notice.

How we use artificial intelligence

Nexties Classroom uses artificial intelligence to power its interactive conversation features, helping students explore career and study pathways based on what they share.

• Personal information a student provides during a conversation with Nexties Classroom is not used to train any underlying AI model. The AI processes only what is needed to generate a response to that student in that session.
• Students can choose to speak rather than type. When they do, the recording is sent to OpenAI purely to convert it into text, and the original audio is not stored by OpenAI or Nexties or used for any other purpose. Typing is always available instead.
• Students can see what Nexties Classroom has inferred about their interests and strengths, and can change or remove this information if it does not accurately represent them.
• Recommendations are based on the student’s own profile and course and provider information, not on any commercial arrangement with a course provider.

Where information is stored

Student information is currently stored on Amazon Web Services (AWS) infrastructure in the Australia region (ap-southeast-2). We intend to migrate to AWS’s New Zealand region in future, though no migration date is confirmed at this stage. Until migration occurs, appropriate contractual and technical safeguards are in place to ensure this offshore storage meets the requirements of the Privacy Act 2020.

How we protect information

We use industry-standard security measures, including:

• Encryption of data in transit and at rest
• Role-based access control for internal systems
• Multi-factor authentication for privileged access
• Logging and monitoring of access to production systems

How long we keep information

We retain a student’s information for as long as their account remains active and linked to the school’s domain.

If a student leaves the school and does not transfer their account to a personal email, we retain their personal information for 12 months from the date their account becomes inactive, after which it is anonymised, unless the school or the student asks us to delete it sooner.

If a school’s agreement with us ends, the same approach applies to that school’s students, unless the school asks us to use a different timeframe.

We may keep anonymised, aggregated insights derived from student information indefinitely, including to support sector-wide or government reporting, for example to the Ministry of Education, the Tertiary Education Commission, or regional partners such as Auckland Council. Once information no longer identifies an individual, it is no longer personal information under the Privacy Act 2020 and is not subject to the timeframes above.

A student, parent, or the school can request access to, correction of, or deletion of a student’s personal information at any time by contacting our Privacy Officer. We aim to act on deletion requests within 20 working days.

If something goes wrong

If a notifiable privacy breach occurs affecting student information, we will notify the Office of the Privacy Commissioner and affected individuals in line with the Privacy Act 2020, and will notify the school as soon as reasonably practicable so it can inform its own community if appropriate.

Who else touches this information

We use a small number of trusted service providers to operate Nexties Classroom. These providers only process the minimum data needed for their specific function and do not use student data for their own purposes:

We do not sell student information, and we do not use it for advertising or marketing purposes.

Your rights

Students, parents, and the school can ask us to access, correct, or delete the personal information we hold. Requests can be sent to our Privacy Officer:

Craig Boxall privacy@nexties.com

We aim to respond within 20 working days.

Changes to this notice

We may update this notice from time to time. We will notify schools of any material change before it takes effect.