Privacy Policy

Last updated: 11 April 2026

Table of Contents

  1. Who We Are
  2. Scope
  3. Information We Collect
  4. How We Use Information
  5. AI, Model Improvement, and Safety
  6. Legal Bases for Processing
  7. How We Share Information
  8. Cookies and Similar Technologies
  9. International Data Transfers
  10. Data Security
  11. Data Retention
  12. Your Rights and Choices
  13. Children's Privacy
  14. Marketing Communications
  15. Jurisdictional Notices
  16. Third-Party Links and Services
  17. Changes to This Policy
  18. Contact Us
1.Who We Are
Sprout Garden Learning Limited
Address: Unit 801, One Vista Summit, 3 San Hop Lane, Tuen Mun, Hong Kong
Email: support@sproutgardenlearning.com
WhatsApp: +852 4427 0658
Website: https://www.examkinghk.com
2.Scope

This Policy applies to personal data we process about visitors, registered users, and other individuals who interact with the Exam King platform (examkinghk.com). This Policy supplements our Terms and Conditions and may be updated periodically.

3.Information We Collect

We collect information in the following categories:

Account Information: email address, password (hashed with bcrypt), account role (free/paid user), and communication preferences.

User Content: your selected grade, publisher, unit, generation mode (topic/mock), and any feedback or enquiries you submit.

Learning Activity Data: generated paper records, generation count, timestamps, and AI model used (Haiku/Sonnet).

Device and Usage Data: IP address, device identifiers, browser type, operating system, pages viewed, clicks, referring/exit pages, date/time stamps, and performance logs.

Cookies and Similar Technologies: cookies, local storage, and session identifiers to remember settings and maintain login sessions (see Section 8 below).

Communications: messages and correspondence with us, including support requests and feedback.

Payment Information: if you purchase a subscription, limited payment metadata (e.g., transaction ID, plan, billing status). Credit card details are processed by Stripe and are not stored by us.

Information We Do NOT Collect:

4.How We Use Information

We use your information to:

5.AI, Model Improvement, and Safety

We use artificial intelligence (Anthropic Claude) to generate exam paper content and feedback. AI outputs may be inaccurate or outdated; users should verify content with official materials.

We may use anonymised or aggregated data to evaluate and improve our AI systems and features. This data does not contain any personally identifiable information.

Where legally required or appropriate, we seek to de-identify data used for model improvement and apply access controls.

You may opt out of having your personal data used for model training (not including strictly necessary operational processing) by emailing support@sproutgardenlearning.com. We will honour your request where required by applicable law.

If we make any material changes to how data is used for AI training in future, we will notify all registered users by email at least 30 days before the change takes effect.

6.Legal Bases for Processing

Hong Kong (PDPO): We comply with the Personal Data (Privacy) Ordinance (Cap. 486). We process your personal data in accordance with the six Data Protection Principles: purpose and manner of collection, accuracy and retention, use of data, security, openness, and access rights.

If you are located in the EEA/UK (GDPR/UK GDPR), we rely on contract performance, legitimate interests, consent, and legal obligation as our legal bases for processing.

7.How We Share Information

We do not sell your personal information. We may share information with:

Service Providers / Processors: hosting (Render), payment processing (Stripe), under contracts that require appropriate safeguards.

AI Service Provider: Anthropic Claude β€” receives only non-personal data (grade, publisher, unit selection). Your email, name, or payment details are never sent to the AI service.

Legal / Compliance: to comply with law, enforce Terms, protect rights, safety, and security.

Business Transfers: in connection with a merger, acquisition, or asset sale, subject to continued protection of your data.

Referral Programme: if you use a referral code, we record the code-to-account association to process referral rewards. We do not disclose your personal data to the referrer.

8.Cookies and Similar Technologies

We use cookies and similar technologies to keep you signed in, remember preferences, and analyse usage. You can manage cookies via your browser or device settings. Disabling cookies may affect certain features.

Storage Items We Use:

We Do NOT Use:

Third-party: Stripe (our payment processor) may set cookies during the payment process. Please refer to Stripe's Cookie Policy for details.

9.International Data Transfers

Your information may be processed in countries other than your own. Our servers are located in Hong Kong. AI requests are processed via Anthropic's API (United States). Where required, we use appropriate safeguards to protect personal data transferred internationally.

10.Data Security

We implement technical and organisational measures to protect personal data, including:

However, no method of transmission or storage is completely secure.

11.Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce agreements.

12.Your Rights and Choices

Subject to applicable law, you may have the right to:

To exercise your rights, contact us at support@sproutgardenlearning.com or WhatsApp +852 4427 0658. We may verify your identity before responding. We will respond within 40 days.

13.Children's Privacy

Exam King is designed for use by parents and legal guardians, not for direct use by children. Accounts must be created by a parent or legal guardian aged 18 or above.

We do not knowingly collect personal data from persons under 18. When you generate exam papers, we only record grade level and publisher selections β€” we do not collect any personally identifiable information about your child. Children do not interact with the platform directly β€” parents generate papers, print them, and hand them to children to complete on paper.

If we learn that we have collected personal data from a child without required consent, we will take reasonable steps to delete it. If you believe this has occurred, please contact us at support@sproutgardenlearning.com.

14.Marketing Communications

We may send service announcements and administrative messages. Where required, we will obtain consent for marketing emails. You can opt out of marketing at any time using the unsubscribe link or by emailing support@sproutgardenlearning.com.

15.Jurisdictional Notices

Hong Kong (PDPO): We comply with the Personal Data (Privacy) Ordinance (Cap. 486). You may request access to and correction of personal data by contacting us.

EEA/UK (GDPR/UK GDPR): See "Legal Bases" and "Your Rights and Choices" sections above.

16.Third-Party Links and Services

The platform may link to third-party websites or services (such as Stripe payment pages). We are not responsible for their privacy practices. We encourage you to review their privacy policies.

17.Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by posting a notice on the platform. Your continued use of the platform after changes become effective means you accept the updated Policy.

18.Contact Us
Sprout Garden Learning Limited
Address: Unit 801, One Vista Summit, 3 San Hop Lane, Tuen Mun, Hong Kong
WhatsApp: +852 4427 0658
Email: support@sproutgardenlearning.com
Website: https://www.examkinghk.com