Data user: 明日領展有限公司 (Future Link Group Limited)
Privacy Policy
- Effective date
- This Policy will take effect upon official launch
- Last updated
- 2026-08-26
1. Scope of these terms
These terms apply to SmartPapers AI (the “Service”). By using the Service, you confirm that you have read and accept these terms.
The Service is operated and billed by 明日領展有限公司 (Future Link Group Limited) (“we”, “us”). Full company registration details are set out in section 15.
If you do not accept these terms, please do not use the Service.
2. What data we collect
2.1 Data you provide voluntarily
At the waitlist stage:
| Data | Required? |
|---|---|
| Parent form of address | Required |
| Child’s year level (P1–P6) | Required |
| Email address | Required |
| WhatsApp number | Voluntary |
| Subject for which practice material is hardest to find | Voluntary |
| Difficulties you encounter when helping your child revise | Voluntary |
When using the service:
| Data | Required? |
|---|---|
| Account login information | Required |
| Payment information | Required (processed by a third-party payment service provider; see §6) |
| The past paper and revision scope you upload | Required (otherwise we cannot generate a practice paper) |
| Child profile name (a nickname may be used) | Required |
2.2 Data we do not collect
We will not ask you to provide your child’s full name, identity card number, school name or date of birth.
If you provide any of this information in a voluntary field, we will handle it in accordance with this Policy, but we do not need it to provide the service.
2.3 Data collected automatically
We use Cloudflare Web Analytics to understand website usage. This service does not use cookies, track individual visitors or create a fingerprint to identify you for analytics purposes.
3. Why we collect this data
| Purpose | Data involved |
|---|---|
| Generate the practice paper you request | Uploaded past paper, revision scope and child’s year level |
| Deliver the completed practice paper to you | Email address |
| Manage your account and subscription | Account information and payment records |
| Respond to your enquiries | Contact details and correspondence |
| Notify you of important changes to the service, prices or terms | Email address |
| Improve service quality and generation accuracy | Usage data and failure records |
| Send you promotional information | See §5 — your consent is required |
4. Consequences of not providing data
Required data: If you do not provide it, we will not be able to create an account for you, generate a practice paper or deliver the result.
Voluntary data: Choosing not to provide it will not affect your use of the service.
5. Direct marketing
This section explains whether we may send promotional information to you. Please read it carefully.
5.1 Data we may use
We may use your name (form of address), email address and WhatsApp number to send you direct-marketing information.
5.2 What we may promote
- SmartPapers AI services, plans and offers
- New year levels, subjects or features
- Service-related events or information
5.3 What we will not do
We will not transfer or sell your personal data to any third party for direct-marketing purposes.
5.4 Your consent — we separate the two purposes
We seek consent separately for “the notification you requested” and “promotional information”. You may agree to only one of them.
| Purpose | Required? | |
|---|---|---|
| First | Notify you when your child’s year level opens | Required — this is the purpose of joining the waitlist; without consent, we cannot notify you |
| Second | Offers, new features and other promotional information | Voluntary — declining does not affect the first purpose |
Neither option will be pre-selected. We will not treat silence or inaction as consent.
We will record the time of your consent and the version of the terms in force at that time.
5.5 You may opt out at any time, free of charge
You may ask us at any time to stop using your data for direct marketing, free of charge and without giving a reason.
You may do so in either of the following ways:
- Click the unsubscribe link at the bottom of any promotional email
- Email
hello@smartpapersai.com
We will stop as soon as practicable after receiving your request and process it within two working days.
Even if you opt out of promotional information, we will still send you essential notices directly related to the service (for example, that a practice paper you requested is ready, a payment receipt, or an important change to the service or terms). These notices are not direct marketing.
6. Who we may transfer your data to
We do not sell your personal data. We disclose data to third parties only in the following circumstances:
| Category | Purpose |
|---|---|
| Website and infrastructure service providers | Website hosting, domain and email routing |
| Email service providers | Sending service and notification emails |
| Artificial intelligence service providers | Generating practice-paper content |
| Payment service providers | Processing payments |
| Our professional advisers | Accounting and legal services |
| Law-enforcement agencies, regulators or courts | Where required by law |
Some service providers are located outside Hong Kong, so your data may be transferred outside Hong Kong for processing. We will take reasonable steps to require those providers to protect your data to a standard no lower than this Policy.
Payment information: We do not store your full credit-card number. Payments are processed by Stripe. We retain only transaction records and the last four digits of the card.
7. How long we retain data
We retain personal data only until the original purpose for which it was collected has been fulfilled. When data is no longer needed for that purpose, we will delete or anonymise it.
Exception: Transaction and payment records are retained as required by Hong Kong tax and company law (generally for 7 years).
You may ask us at any time to delete personal data that is no longer required (see §11).
8. Past papers you upload
A past paper you upload is used only for that generation. We do not store or reuse its text, images or questions across users.
We will not create a shared database containing original paper content. If we create any cross-school database in future, it will store only abstract structural patterns (such as question-type distribution and section rhythm), not copyright-protected content.
9. Children and minors
SmartPapers AI is intended for parents or guardians. Anyone under the age of 18 should not register independently. To use the service, a parent or guardian must register on their behalf and agree to this Policy.
A past paper you upload may contain your child’s name or class. We do not need or extract this information. The system extracts only question structure and content, which are not stored or reused across users (see §8).
If you would like us to delete any data relating to your child, email hello@smartpapersai.com.
10. Data security
Our measures include:
- HTTPS encryption across the website
- High-entropy random tokens for delivery links, with expiry periods
- Storing only token hashes in the database, not the tokens themselves
- Restricting access to personnel who need it
- Regular backups
However, no system can guarantee absolute security. If a security incident affects your personal data, we will notify you in accordance with applicable law and regulatory guidance.
11. Your rights
Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request deletion of data that is no longer required
- Opt out of direct marketing at any time (see §5.5)
- Complain about how we handle your data
How to exercise these rights: Email hello@smartpapersai.com
We will respond to an access request within 40 days (the statutory limit under the Ordinance). We may charge a reasonable fee for an access request.
If you are dissatisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong.
12. Contact us
| Matter | |
|---|---|
| Privacy enquiries, data access and correction | hello@smartpapersai.com |
| Report a suspicious email | security@smartpapersai.com |
13. Changes to this Policy
We may amend this Policy from time to time. If there is a material change, we will publish it on the website and notify you by email before it takes effect.