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  2. LearnSys Vocab · English
  3. LearnSys Vocab · English — Privacy
LearnSys Vocab · English

Privacy

Effective / published version: 2026-10-01

This policy covers this product when provided through a school-managed LearnSys account, including students under 18. IGEARS TECHNOLOGY LIMITED provides LearnSys. The school determines the educational purposes, authorised users and school-record arrangements; iGears provides processing and support within the agreed school service. Public demos accept fictional data only. Separate consumer apps, Poe tools and Tutor Centre Cloud have their own policies.

Routine English vocabulary answers and progress do not require AI processing. The AI text sections apply only to an enabled teaching tool that submits selected text; English speaking and writing links have their own product policy.

For students: what you need to know

  • Your school uses your work and school records to teach you and manage school life. Submit only what your teacher or school asks for.
  • Use made-up names in practice work where possible. Do not put passwords, identity card numbers, home addresses or other people’s private information into an essay, recording or AI conversation.
  • Assigned school staff can see the records needed for their work. Your parent or guardian can see only the child records the school has authorised and made available to that account.
  • If you are unsure, want something corrected or want to stop an optional activity, ask a teacher or parent to help you contact the school. Logging out does not erase your school records.

Before collection: school notice and choices

Before collecting student data, the school should explain to students and parents, in age-appropriate language, the data required, each purpose, who receives it, retention, the school contact, whether supply is mandatory or optional and the consequences of not supplying it. This product policy does not replace the school’s collection notice.

School enrolment, reading this page or allowing the microphone does not give blanket permission for unrelated uses. The school must obtain any consent required for the particular use, including a new purpose not directly related to the original purpose unless a legal exemption applies. A parent or guardian acts for a child only where legally entitled; an app account link alone does not settle that authority.

Required identity and class details support school access and assignments; omitting them may prevent the relevant service. Optional uploads or device permissions affect only the functions that need them. Students or parents can ask the school to withdraw an optional permission or discuss an alternative; the school must explain the actual learning impact and which existing records still need to be kept.

Data collected and each purpose

School account, class/group, assigned word lists, submitted answers, attempt times, errors and progress support English vocabulary teaching, practice and teacher review. A saved personal word list is still student-linked data.

Ordinary vocabulary questions and progress recording do not require sending pupil records to an AI provider. Teacher-enabled AI material authoring may send the selected topic or teaching text through the school AI gateway. Links to English writing or speaking open that product’s separate learning flow and policies.

Who can see a student’s records

  • Students: their own authorised tasks, submissions and released results. Other classmates’ private records are not made available by student access.
  • Teachers and school staff: records allowed by their current school role and assigned class, group or duties. Sensitive notes have additional restrictions.
  • Parents and guardians: only linked children and records the school has made available to that account. This does not grant unrestricted access to staff notes or other pupils’ information. Ask the school to resolve an incorrect link or authority dispute.
  • iGears support and configured providers: only the agreed processing or school-authorised support scope. A support role is not unrestricted permission to browse school data. Any legally required disclosure must be assessed separately.

Storage locations and service recipients

The school deployment uses a dedicated school server, database and private file storage. School content must stay on the school server or an approved Hong Kong host; the actual host, AI processing location and service terms must be confirmed for each school before real pupil use. Do not infer location merely from a LearnSys domain name.

A configured web proxy such as Cloudflare handles connection traffic, including IP addresses and requested pages. Optional staff sign-in through Google or Microsoft involves those providers. Email, SMS, push and payment providers receive only data needed for enabled services. These provider operations are not automatically confined to Hong Kong; the school must identify the active recipients, locations and safeguards in its notice and agreement. Demo payment/notification functions do not establish a live provider arrangement.

Student records are not sold or rented for advertising. The school apps do not use advertising or cross-app tracking. Unrelated publicity, research, model development or disclosure needs its own lawful basis and school review; this policy is not authorisation for those uses.

Account security and operational records

School, role and assignment checks protect private records. Passwords are hashed. Security and audit records may include account references, action, time and request metadata; they support access control and investigation. Not logging AI prompts does not mean no operational metadata is kept. Required session and preference storage supports sign-in and display.

AI and voice: read before use

Routine English vocabulary answers and progress do not require AI processing. The AI text sections apply only to an enabled teaching tool that submits selected text; English speaking and writing links have their own product policy.

Access, correction, deletion and help

Contact the school office or its designated privacy contact through an existing verified private channel. Identify the student using the school reference, explain the records or activity concerned, and state whether you seek access, correction, removal or withdrawal of an optional permission. The school checks identity and any parental/guardian authority before disclosure.

Under Hong Kong’s Personal Data (Privacy) Ordinance, statutory access and correction requests are generally to be complied with within 40 calendar days of receipt, subject to the applicable requirements and exceptions. If unable to comply in time or lawfully refusing, the responsible data user must give the required written notice and reasons within that period. An internal review does not restart the statutory clock.

Deletion is reviewed against the purpose and any continuing retention duty; it is not an unconditional promise to erase every record immediately or within the access-request deadline. The school should explain any retained category, reason, review date and progress. See this product’s retention and deletion pages.

If you cannot identify the school contact, email [email protected] with the school name and a short description only. Do not send student records, passwords, invitation codes or identity documents in ordinary email or the public quotation form. Suspected exposure should be reported promptly through these channels without forwarding the exposed records. You may also contact the PCPD about privacy concerns.

Changes to student-data arrangements

The version date identifies this published policy. Before a new data category, recipient, processing location or purpose is introduced, the school and iGears must review the arrangement and provide the relevant notice and any required consent process. Posting a revised page alone does not authorise a new purpose.

Related policies and official guidance

LearnSys service recipients and hosting information

  • PCPD: protecting children’s personal data
  • PCPD: data access requests and the 40-day period
  • PCPD: handling data correction requests
  • Contact the PCPD

[email protected]

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