This Privacy Policy explains how Thinka Limited (“Thinka”, “we”, “us”, or “our”) collects, uses, discloses, and protects your information when you use our website, mobile applications, and related services (collectively, the “Platform”). By using the Platform, you agree to the practices described in this Policy.

If you do not agree with this Policy, please do not use the Platform.

1. Who We Are

Thinka Limited

Company Registration Number: 67855959

Flat 1426, 14/F, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong

Email: info@thinka.hk

Website: https://www.thinka.hk

2. Scope

This Policy applies to personal data we process about visitors, registered users (students, teachers, schools), and other individuals who interact with the Platform. 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: name, email address, password (hashed), role (e.g., student, teacher, school), class or course associations, and communication preferences.
  • Profile and School Information: school name, logo, grade/level, subjects, and teacher or institution contact details provided by you or your institution.
  • User Content: uploaded answers, handwritten notes, images, documents, prompts, feedback, and any annotations or corrections you submit.
  • Learning Activity Data: generated questions, scores, progress, time-on-task, attempts, and analytics derived from your use of the Platform.
  • Device and Usage Data: IP address, device identifiers, browser type, operating system, app version, pages viewed, clicks, referring/exit pages, date/time stamps, and performance logs.
  • Cookies and Similar Technologies: cookies, local storage, and SDKs to remember settings, maintain sessions, and analyze usage (see “Cookies” below).
  • Communications: messages and correspondence with us, including support requests, feedback, and survey responses.
  • Payment Information: if you purchase a subscription, limited payment metadata (e.g., transaction ID, plan, billing status). Payment card details are processed by our payment processor and are not stored by us.

4. How We Use Information

We use your information to:

  • Provide, operate, secure, and maintain the Platform and core features.
  • Create, grade, and analyze practice questions and learning activities.
  • Personalize content, recommendations, and analytics.
  • Process subscriptions, payments, and account management.
  • Provide support, respond to inquiries, and send service-related communications.
  • Monitor performance, fix errors, and improve reliability.
  • Conduct research and development to improve AI models and learning outcomes.
  • Comply with legal obligations and enforce our Terms.

5. AI, Model Improvement, and Safety

  • We use artificial intelligence to generate study content and feedback. AI outputs may be inaccurate or outdated; users should verify content with official materials.
  • We may use anonymized or aggregated data to evaluate and improve our AI systems and features.
  • 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 info@thinka.hk. We will honor your request where required by applicable law.

7. How We Share Information

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

  • Service Providers/Processors: hosting, analytics, customer support, email delivery, and payment processing, under contracts that require appropriate safeguards.
  • School Administrators/Teachers: for education-related reporting, oversight, and progress tracking as configured by the institution.
  • Affiliates: to support Platform operations in accordance with this Policy.
  • 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.
  • Public Attribution for Schools: with consent or as allowed under our Terms, we may display a school’s name and logo unless the school opts out.

8. Cookies and Similar Technologies

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

9. International Data Transfers

Your information may be processed in countries other than your own. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) to protect personal data transferred internationally.

10. Data Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure.

11. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary by data category and context.

12. Your Rights and Choices

Your privacy rights depend on your location and applicable law. Subject to limitations, you may have the right to:

  • Access, correct, or delete your personal data.
  • Object to or restrict certain processing.
  • Port your data to another service.
  • Withdraw consent where processing is based on consent.
  • Lodge a complaint with a supervisory authority.

To exercise your rights, contact us at info@thinka.hk. We may verify your identity before responding.

13. Students and School Accounts

  • When a school provides or manages accounts, the school may be the controller of certain data. We process such data on the school’s instructions and our agreement with the school.
  • Students and parents should direct requests regarding school-managed data to the relevant school administrator or teacher.

14. Children’s Privacy

The Platform is intended for use by students with appropriate consent where required by law. 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 info@thinka.hk.

15. 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 info@thinka.hk.

16. Jurisdictional Notices

16.1 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 at info@thinka.hk.

16.2 European Economic Area/United Kingdom (GDPR/UK GDPR)

See “Legal Bases” and “Your Rights.” If we rely on legitimate interests, we balance them against your rights and freedoms.

16.3 California (CPRA/CCPA)

California residents may have rights to know, delete, correct, and opt out of certain processing. We do not sell personal information for monetary consideration, but we may engage in processing that could be considered “sharing” for cross-context behavioral advertising. To exercise rights or opt out, contact info@thinka.hk.

18. 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.

19. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our data practices, please contact:

Thinka Limited

Flat 1426, 14/F, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong

Email: info@thinka.hk

Website: https://www.thinka.hk