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 early registration stage:

DataRequired?
Parent form of addressRequired
Child’s year level (P1–P6)Required
Email addressRequired
Your two consent choices and when you made themRecorded automatically
Your registration numberGenerated by us

Your registration data is stored in Cloudflare’s database service, on servers outside Hong Kong.

When using the service:

DataRequired?
Account login informationRequired
Payment informationRequired (processed by a third-party payment service provider; see §6)
The past paper and revision scope you uploadRequired (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 do not run any website analytics tool and we do not use cookies to track visitors. Our website provider, Cloudflare, keeps standard server logs for security and operational purposes.

3. Why we collect this data

PurposeData involved
Generate the practice paper you requestUploaded past paper, revision scope and child’s year level
Deliver the completed practice paper to youEmail address
Manage your account and subscriptionAccount information and payment records
Respond to your enquiriesContact details and correspondence
Notify you of important changes to the service, prices or termsEmail address
Improve service quality and generation accuracyUsage data and failure records
Send you promotional informationSee §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) and email address 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.

PurposeRequired?
FirstNotify you when your child’s year level opensRequired — this is the purpose of registering; without consent, we cannot notify you
SecondOffers, new features and other promotional informationVoluntary — 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 cancel link in any email we send you — one click, no reply needed
  • 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:

CategoryPurpose
Website and infrastructure service providersWebsite hosting, domain and email routing
Email service providersSending service and notification emails
Artificial intelligence service providersGenerating practice-paper content
Payment service providersProcessing payments
Our professional advisersAccounting and legal services
Law-enforcement agencies, regulators or courtsWhere 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).

Early registration data: retained until you cancel your registration, or until 24 months after the service formally launches, whichever comes first.

After you cancel: we keep your registration record and mark it as cancelled. This serves one purpose only — to make sure we never email you again. You may ask us to delete the record entirely.

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:

  1. Access the personal data we hold about you
  2. Correct inaccurate data
  3. Request deletion of data that is no longer required
  4. Opt out of direct marketing at any time (see §5.5)
  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

MatterEmail
Privacy enquiries, data access and correctionhello@smartpapersai.com
Report a suspicious emailsecurity@smartpapersai.com

Data user: 明日領展有限公司 (Future Link Group Limited)

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.