Privacy Policy

Wadmore Pty Ltd (ABN 39 686 562 470) ("Wadmore", "we", "us", or "our") is committed to protecting the privacy of everyone who uses our cognitive profiling platform. This Privacy Policy explains how we collect, use, store, disclose and protect personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

Wadmore handles information about children and produces cognitive profiles that families and schools may rely on. We treat that as a serious responsibility. We apply the Australian Privacy Principles to all of our activities as a matter of policy, and we hold ourselves to them regardless of any small business exemption that might otherwise be available to us.

This policy applies to our websites, our assessment platform, and all Wadmore products including Wadmore Schools, Wadmore Families and Wadmore Professional.

Under APP 2 you have the right to deal with us anonymously or under a pseudonym where it is lawful and practicable.

You can browse our public website, and make a general enquiry, without identifying yourself.

It is not practicable to complete a cognitive assessment anonymously. A cognitive profile is developmental and age-referenced, results are returned to a specific parent, guardian or school, and we must be able to confirm that the person receiving a child's profile is entitled to receive it. For these reasons we require identifying information for assessment accounts.

Where a school or organisation prefers, students may be identified by a school-issued identifier rather than by name, provided the school retains the mapping. Contact us if you would like to discuss this arrangement.

Account Information

• Name and contact details (email address, and phone number where provided)
• Organisation details (for school and professional accounts)
• Billing information (processed by our payment provider; we do not store full card numbers)
• Account credentials (passwords are stored in hashed form and are not visible to us)

Assessment Data

• Responses to cognitive assessment items
• Response timing and interaction patterns
• Written or spoken responses to open-ended items, where the assessment includes them
• Cognitive profile results across our eight domains
• Developmental band placements and associated confidence estimates

Child and Student Information

For individuals under 18, assessments are always set up and authorised by a parent, guardian or an authorised school administrator. Children cannot create Wadmore accounts independently.

Family accounts: we collect:

• First name and surname
• Date of birth
• Year level (where provided)
• Assessment responses and results

School accounts: we may collect:

• First name and surname
• Date of birth
• Year level
• Student identifier as provided by the school
• Class or group information
• Assessment responses and results

Research and Calibration Participation

Where a participant joins a research or calibration programme, we may also collect limited background information that supports the validity and fairness of our assessments. This may include state or territory, school sector, main language spoken at home, and whether a diagnosed learning difference is present.

Providing this information is optional. You can take part in a research programme without providing any of it, and declining will not affect the assessment or the profile you receive.

Technical Information

• Device type and browser information
• IP address and approximate location derived from it
• Platform usage and interaction logs

We collect only the information we need to deliver the assessment, return an accurate profile, keep the platform secure, and meet our legal obligations.

We use collected information to:

• Deliver cognitive assessments and generate developmental profiles
• Select appropriate assessment items for a participant's demonstrated performance level
• Provide growth strategies and recommendations within reports
• Enable schools to support student learning and development
• Improve the validity, fairness and accuracy of our assessments
• Maintain platform security and investigate misuse
• Communicate with you about your account and our services
• Comply with legal obligations

We do not sell personal information to any party. We never use cognitive assessment data, assessment responses, cognitive profiles, or any information about a child for advertising or marketing targeting purposes.

Wadmore uses automated processes to deliver and score assessments. This section explains what those processes do, what information they use, and how you can ask for human review. We provide this information in the interests of transparency and in anticipation of the automated decision-making transparency requirements commencing 10 December 2026.

What is automated

• Item selection during the assessment. The assessment is adaptive. As a participant responds, an automated routing process selects the next set of items based on the accuracy of previous responses and the participant's age. This determines which items a participant sees.
• Ability estimation. Responses are scored using a statistical model that produces an estimate of demonstrated performance in each domain, together with a measure of the precision of that estimate.
• Developmental band placement. Each of the eight domains is assigned a developmental band based on that estimate. Band placements are the primary output of the assessment.
• Scoring of open-ended responses. Where an assessment includes written or spoken open-ended responses, those responses are evaluated using an automated language model operating within Australia (AWS, Sydney region), against a fixed scoring rubric. Spoken responses are first transcribed by automated speech recognition running on our own infrastructure in Australia.
• Report narrative generation. Descriptive text within reports is generated from band placements and the participant's demonstrated response patterns.
• Response filtering. Responses submitted implausibly quickly are excluded from scoring, as they do not reflect genuine engagement with the item.

What information is used

These processes use: assessment responses, response timing, the participant's date of birth or age, and the participant's performance on earlier items within the same assessment. They do not use name, contact details, school, gender, language background, or any information about a diagnosed learning difference.

What these outputs are, and are not

A Wadmore profile describes observed cognitive performance on the tasks presented. It is not a diagnosis, not a clinical assessment, and not a measure of intelligence, potential or worth. Wadmore does not itself make decisions about enrolment, placement, selection, employment or access to services.

Where a school, organisation or family uses a Wadmore profile to inform such a decision, that decision is made by that school, organisation or family, and they are responsible for it. We ask all partners to use profiles as one input among several, and never as a sole determinant.

Requesting human review

You may ask us to have a person review any automatically generated result. This includes band placements, scores given to open-ended responses, and report content. Contact privacy@wadmore.com.au with the participant's name and the date of the assessment.

We will acknowledge your request within 5 business days and complete the review within 30 days. If the review identifies an error, we will correct the profile and reissue the report at no cost. You may also request that an assessment result be withdrawn and deleted entirely.

All assessment responses, cognitive profiles and student records are stored on secure servers located in Melbourne, Australia, and remain within Australian jurisdiction. Automated scoring services operate within the AWS Sydney region. Encrypted database backups are stored in the AWS Sydney region.

We implement security measures including:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Network isolation between application, processing and database servers
• Firewall controls restricting administrative access
• Two-factor authentication on administrative and partner accounts
• Rate limiting and monitoring to detect unauthorised access attempts
• Continuous encrypted backups with tested restoration procedures
• Documented data handling and access procedures
• Access to identifiable assessment data limited to personnel who require it

No system can be guaranteed completely secure. If a data breach occurs that is likely to result in serious harm, we will respond as described in section 12.

Wadmore assessments are available for individuals aged 8 years and older. Most of the people assessed on our platform are children, and we design our practices accordingly.

Our commitments

• Best interests. We handle children's personal information in a way that is consistent with the best interests of the child. Where a proposed use of children's data would not serve the child, we do not do it.
• Consent. A parent, guardian or authorised school administrator must consent before a child is assessed. Consent is sought separately for each distinct purpose. We do not bundle consents, and declining an optional consent never prevents participation.
• No independent accounts. Children cannot register for Wadmore themselves.
• No advertising. We never use children's personal information for targeted advertising, and we never share it with advertising platforms. Advertising and marketing analytics tools are not present anywhere within the assessment platform.
• No commercial profiling. We do not build commercial or behavioural profiles of children.
• Minimal collection. We collect only what is necessary to deliver the assessment and return an accurate profile.
• Deletion. A parent or guardian may request deletion of a child's data at any time. A young person may also contact us directly to ask that their own information be deleted, and we will act on that request in consultation with the parent, guardian or school that holds the account.

For young people

If you are the person taking a Wadmore assessment, here is what happens to your information, in plain terms:

• We keep your answers and the profile they produce.
• Your parent, guardian or school can see your profile. So can we.
• Nobody else sees it. We never sell it, and we never give it to advertisers.
• The profile describes how you went on the tasks you did. It is not a judgement about you, and it does not say anything about how clever you are.
• A computer works out your results. If you think something is wrong, you can ask a person to check it.
• You can ask us to delete your information. Email privacy@wadmore.com.au and we will help.

Regulatory context

The Office of the Australian Information Commissioner is developing a Children's Online Privacy Code, which is required to be registered by 10 December 2026. We are monitoring the Code's development and will update our practices and this policy to comply with it.

We may disclose personal information to:

• Schools and organisations: assessment results for students or employees assessed under an institutional account, to that institution
• Parents and guardians: a child's profile, to the parent or guardian who holds the account
• Service providers: providers who support platform operations, under contractual confidentiality and data protection obligations (see section 9)
• Distribution partners: where an assessment is purchased through an authorised reseller, we may confirm to that reseller that an assessment has been used, and share aggregate usage information. We do not disclose individual assessment responses or cognitive profiles to resellers unless the participant, parent or school has expressly agreed
• Legal requirements: where required by law, court order, or to prevent a serious threat to life, health or safety

We may use de-identified, aggregated data for research and platform improvement. De-identified data cannot reasonably be used to identify an individual, and we actively assess re-identification risk before any such use.

Research Collaboration

Where participants have given specific consent, we may share de-identified assessment data with academic and research institutions for the purpose of validating and improving cognitive assessment methodology. Findings may be published in academic journals or presented at conferences.

Published research reports only aggregated, de-identified findings. No individual participant is identifiable in any research output. Consent for research use is optional, is sought separately from consent to participate, and can be withdrawn at any time by contacting us. Research involving academic partners is conducted under the ethical approval arrangements of the partner institution.

Assessment responses, cognitive profiles and student records are not transferred outside Australia. They are stored and processed in Australia only.

A limited set of account and operational information is handled by service providers who may process or store data outside Australia:

• Payment processing: name, email and billing details (United States, Ireland)
• Transactional email delivery: name and email address (United States)
• Website hosting and marketing site analytics: technical and usage data for our public website (United States)
• Enquiry management: name, email address, organisation and message submitted through our website contact form (United States)
• Advertising measurement: technical and event data from our public marketing pages only (United States, Ireland)

Before disclosing personal information to an overseas recipient we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles, including through contractual data protection terms.

A current list of our service providers is available on request from privacy@wadmore.com.au.

We may send you information about Wadmore products and services where you hold an account with us, or where you have asked to hear from us.

Our commitments:

• Every marketing message includes a clear unsubscribe link, and we action unsubscribe requests promptly
• We never send marketing communications to a child
• We never use assessment data, cognitive profiles, or information about a child to target marketing
• We do not provide your contact details to third parties for their own marketing
• Consent to marketing is always optional and separate from participation or purchase

Service communications, such as assessment instructions, report delivery and account or security notices, are not marketing and will continue regardless of your marketing preferences.

You can opt out at any time using the unsubscribe link, through your account settings, or by emailing privacy@wadmore.com.au. You may also ask us to tell you the source of information we hold about you.

We keep personal information only for as long as we need it. Our retention periods are:

• Family accounts: assessment data is retained while the account remains active, to support re-assessment and developmental comparison over time. If an account is inactive for 3 years, we will contact the account holder and then de-identify or delete the data.
• School and organisational accounts: retained for the term of the agreement with that institution, and then for 12 months, unless the institution requests earlier deletion or a longer period is agreed in the contract.
• Account and billing records: retained for 7 years where required by taxation and corporations law.
• Marketing contacts: deleted within 12 months of unsubscribing or of the last interaction, whichever is later.
• Research data: where consent has been given, retained in de-identified form. De-identified data is not personal information and may be retained indefinitely for research and calibration.
• Technical logs: retained for 90 days for security and troubleshooting.

You can request earlier deletion at any time. We will comply unless we are legally required to retain the information, in which case we will tell you why and for how long.

We maintain a data breach response plan. If we suspect a breach we will contain it, assess it promptly, and take steps to reduce any harm.

If a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. Where a breach affects a student assessed under a school account, we will also notify the school without delay.

Our notification will describe what happened, what information was involved, and what you can do in response.

Under Australian privacy law, you have the right to:

• Access the personal information we hold about you, or about a child for whom you are the parent or guardian
• Request correction of information that is inaccurate, out of date or incomplete
• Request deletion of your data, subject to legal retention requirements
• Request human review of an automatically generated result (see section 5)
• Withdraw consent for any optional processing, including research use and marketing
• Deal with us anonymously or pseudonymously where practicable (see section 2)
• Complain about our handling of your information

To exercise any of these rights, contact privacy@wadmore.com.au. We will acknowledge your request within 5 business days and respond within 30 days. Access requests are free of charge.

If a student was assessed under a school account, the school controls that record. We will direct your request to the school and support them in responding.

We use:

• Session cookies, which are essential for the platform to operate
• Vercel Analytics on our public website, which does not track individuals
• Google Analytics on our public website, to understand how visitors use our marketing pages
• The Meta pixel on our public marketing pages only

On our public marketing pages we use the Meta (Facebook) pixel and Conversions API to measure the effectiveness of our advertising and to reach people who may be interested in our services. This involves sharing limited technical and event data, such as page visits and form submissions, with Meta.

We never share cognitive assessment data, assessment responses, cognitive profiles, or any information about a child with advertising platforms. Advertising and marketing analytics tools are not present within the assessment platform itself.

You can manage cookie preferences through your browser settings. Disabling essential cookies will prevent the platform from working.

We may update this Privacy Policy from time to time. Where a change is significant, we will notify account holders by email or platform notification before it takes effect. The version number and date at the top of this page indicate the current version. Previous versions are available on request.

For privacy enquiries, requests, concerns or complaints:

Privacy Officer
Wadmore Pty Ltd
ABN 39 686 562 470
PO Box 35, Stirling SA 5152
Email: privacy@wadmore.com.au

We will acknowledge complaints within 5 business days and respond within 30 days. If we need longer, we will tell you why and when to expect our response.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC), by phone on 1300 363 992 or at oaic.gov.au.