TalkingPencil

Privacy Policy

What we collect, why, and what you can do about it. The short version: as little as possible, and it is yours.

Draft — pending review by a Hong Kong solicitor before launch.

What we collect

What we never collect

Children

An account for a child under 13 is held by a parent or guardian, who creates the child's profile and consents to the processing described here. We record when that consent was given and against which version of this policy.

Children never receive advertising here, cannot contact other users, and cannot be contacted by them.

How we measure use

We use Google Analytics to count visits and see which topics people look for. It sets a cookie that recognises the same browser coming back, so two visits from one person are not counted as two people. It is not connected to your account: it does not know who is signed in, and no name, email or learning record is ever sent to it.

Google's advertising features are switched off and cannot be switched on from here — no advertising identifier is set, and nothing measured is used to build an advertising profile. Visitors in the EEA, the UK and Switzerland are counted without a cookie at all until they choose otherwise.

If your browser sends “Do Not Track”, we honour it: nothing is recorded and no analytics cookie is set. Private browsing mode has the same effect at the end of the session.

Why we hold it

To run the service: to show a student the right topics, remember what they have practised, estimate what they have understood, and produce reports for a parent. Learning data is used to improve the platform and its content in aggregate. It is never sold, and never shared for advertising.

Who processes it for us

Content generation and any AI tutoring send question text and learning context to an AI provider. Personal identifiers are not included — a learner is an internal identifier there, never a name.

Your rights

Under the Personal Data (Privacy) Ordinance you may ask for a copy of the personal data we hold about you or your child, ask us to correct it, and ask us to delete it. Right now the way to do that is to write to us. Controls inside the account are being built; until they are there, the request goes by email and we action it.

Deleting an account removes the learning data within 30 days. Records we must keep by law, such as payment records, are kept for as long as the law requires and no longer.

Security and location

Data is encrypted in transit and at rest, and access is restricted at the database level so one account cannot read another's. Data is stored in the Asia-Pacific region.

If a breach affects you, we will tell you — we will not wait to be asked.

Last updated: 2026-09-09