1. Who we are
Controller: Student Detectives Pty Ltd trading as North Pole PD ("we", "us").
North Pole PD is our festive themed investigative platform that provides educational and entertainment experiences through NorthPolePD.com.
Registered office: Suite 302, 13/15 Wentworth Ave, Sydney NSW 2000, Australia.
For privacy enquiries relating to North Pole PD, please email contact@thedetectiveexperience.com.
2. Scope of this policy
This policy covers personal data processed via NorthPolePD.com and related support channels for the North Pole PD platform. This includes site access, account management, case participation, and licence or gift activation for North Pole PD cases.
We aim to comply with applicable data protection laws. These include the Australian Privacy Act 1988 (Cth) and, where relevant, the UK GDPR and EU GDPR for customers in those regions. For the terms that govern your use of the North Pole PD platform, please see the Terms and Conditions on NorthPolePD.com.
3. Data we collect
We collect and process the following categories of personal data when you use North Pole PD:
- Account and access data: name, email address, login details, role or context (for example educator, home user, parent), school or organisation where applicable, case roles and access codes that are linked to your account.
- Licence and purchase data: licence codes, gift codes, case selections, order history and basic billing metadata where purchases are made.
- Communications: enquiries, support messages, feedback and any information you choose to provide when contacting us about North Pole PD.
- Technical data: IP address, browser type, device or user agent information, pages visited, approximate region, referral source and similar data collected through server logs and analytics tools.
- Payment data: payments are processed by our payment service providers. We receive limited information such as transaction references and status, but not full card details.
Special categories: We do not request sensitive or special category data (for example health information or information about your religion). Please do not include such information in uploads, messages or support requests relating to North Pole PD.
4. How we use your data
We use personal data on North Pole PD for the following purposes and legal bases:
- To provide the platform and manage accounts so that you can register, sign in, access cases, activate licences or gifts, track progress and receive support. The legal basis is performance of a contract and our legitimate interests in operating the service.
- To process payments and prevent misuse including handling orders, resolving payment issues and monitoring for fraudulent or abusive behaviour. The legal basis is performance of a contract, legal obligation and our legitimate interests.
- To operate and improve North Pole PD including diagnostics, analytics, testing new features and improving stability and content. The legal basis is our legitimate interests and, where required for analytics cookies, your consent.
- To communicate with you including responding to support enquiries, sending operational messages related to your account or licences and, where you choose to opt in, sending occasional updates about new cases or features. The legal basis is performance of a contract, legitimate interests and consent for optional updates.
- To meet legal and compliance obligations including record keeping for tax and audit purposes and responding to lawful requests from authorities. The legal basis is legal obligation and our legitimate interests.
5. Sharing and processors
We do not sell personal data. We share personal data only when necessary for the operation of North Pole PD or where required by law, including with:
- Service providers that host our websites and databases, provide email delivery, analytics, customer support tools and payment processing. These providers act as processors and are bound by contracts that limit their use of the data to our instructions.
- Professional advisers such as accountants, auditors or legal advisers where this is necessary to support our business and comply with our obligations.
- Authorities or regulators where we are required to do so by law or where this is necessary to protect our rights or the rights of others.
6. Children’s data
North Pole PD is designed for use by adults, including educators and parents, who introduce the content to children and young people. Accounts, purchases and licence activation are intended to be managed by adults.
We do not knowingly collect personal data directly from children through NorthPolePD.com. Any information about students that is linked to North Pole PD is managed by the relevant educator or institution in line with their own policies and legal obligations. For home use, supervision and any handling of information about children remain the responsibility of the adult who purchases or activates the case.
If you believe that a child has provided personal data to us directly through NorthPolePD.com, please contact contact@thedetectiveexperience.com and we will review the situation and remove the data where appropriate.
7. Cookies and analytics
North Pole PD uses essential cookies that are necessary for the site to function, for example to keep you signed in and to remember basic preferences. We may also use analytics tools to understand how the platform is used in aggregate, so that we can improve performance and content.
Where required by law, we will present a banner or similar mechanism that allows you to consent to or manage non essential cookies. If you wish to know more about how cookies are used on NorthPolePD.com, you can contact us using the details below or refer to any separate cookie notice that we provide on the site.
8. Security
We take security seriously and use technical and organisational measures that are appropriate to the nature of the data and risks involved. These measures include:
- encryption in transit for data sent to and from NorthPolePD.com
- access controls and authentication for administrative systems
- keeping software and infrastructure up to date where practicable
- restricting access to personal data to staff and contractors who need it for their role.
No online service can be guaranteed as completely secure, but we work to reduce risk and respond promptly to issues.
9. Data retention
We keep personal data only for as long as it is needed for the purposes explained in this Privacy Policy, including meeting legal, accounting or reporting requirements.
Typical retention periods are:
- Account and licence records held while your account is active and for a reasonable period after closure, then archived or anonymised.
- Order and payment records kept for up to seven years where needed for tax and audit requirements, subject to local law.
- Support correspondence kept for up to twenty four months from the date of last contact, unless needed longer for an ongoing issue.
We may keep information for longer where required for legal or regulatory reasons, or where it is not possible to delete data immediately from backup systems, in which case it will be securely stored and isolated.
10. Your rights
Depending on your location and the laws that apply, you may have some or all of the following rights in relation to your personal data processed in connection with North Pole PD:
- the right to request access to your personal data
- the right to request correction of inaccurate or incomplete data
- the right to request deletion of your data in certain circumstances
- the right to request restriction of processing in certain circumstances
- the right to object to processing that is based on our legitimate interests
- the right to data portability in relation to information that you have provided to us, where the legal basis is consent or contract and the processing is carried out by automated means
- where processing is based on consent, the right to withdraw that consent at any time.
To exercise your rights, please contact us at contact@thedetectiveexperience.com. We may need to request information in order to verify your identity and to help us locate your data.
11. International transfers
North Pole PD may involve the transfer of personal data to service providers located outside your country, for example where we use cloud hosting or support tools. When we transfer personal data across borders, we seek to ensure that appropriate safeguards are in place.
These safeguards may include the use of standard contractual clauses or similar approved mechanisms, together with practical measures designed to protect the privacy and security of the data.
12. Contact and complaints
Contact: For any questions or concerns about how your personal data is handled in relation to North Pole PD, please email contact@thedetectiveexperience.com.
Complaints: You also have the right to lodge a complaint with your local data protection authority. Examples include the Office of the Australian Information Commissioner (OAIC) in Australia and the Information Commissioner’s Office (ICO) in the United Kingdom. We would appreciate the chance to address your concerns first, so please consider contacting us before approaching a regulator.
For the terms that govern your use of North Pole PD and its cases, please see the Terms and Conditions on NorthPolePD.com.
13. Governing law and jurisdiction
This Privacy Policy and any dispute or claim (including non contractual disputes or claims) arising out of or in connection with it or its subject matter shall be governed by and construed in accordance with the laws of New South Wales, Australia.
You agree that the courts of New South Wales shall have exclusive jurisdiction to settle any such dispute or claim, subject to any applicable consumer protection laws that give you the right to bring proceedings in your home jurisdiction.