Privacy Policy

1. Who is responsible for your data

Penpal is used by schools. When a school subscribes, the school decides whose accounts exist and how Penpal is used. Under the Personal Data (Privacy) Ordinance (Cap. 486), the school is the data user for the personal data of its teachers and students, and Penpal processes that data on the school’s behalf and on its instructions.

For visitors to this website and for people who send us a demo enquiry, Penpal is the data user.

You can contact us about anything in this policy at hello@penpal.hk.

2. What we collect

We collect only what is needed to run Penpal for a school:

• Account details the school gives us: name, school email address, role, registration class and class number, and teaching groups.
• The work students do: drafts, the drafts captured when they use Check my work and the feedback they receive, the final version they hand in, answers to Reading and Listening papers, marks and feedback, their vocabulary book and game results.
• Pally conversations: the questions a student or teacher types and Pally’s replies.
• What teachers create: assignments, papers, marks, comments and uploaded files.
• Sign-in and activity records: when someone signs in, which days they used Penpal, an audit log of important actions, and counts of AI use.
• If someone links a Google account to sign in: the Google account identifier and email address.
• If someone turns on notifications on a device: that device’s push subscription.
• If you send a demo enquiry: your school, name, role, email address and message.

3. How we use it

We use personal data to provide Penpal to the school: to run assignments, give feedback, mark work, keep the school’s records, send the notifications people have asked for, keep the service secure, and give support. We use demo enquiries only to reply to them.

We do not sell personal data, we do not use it for advertising, and we do not use students’ work to train AI models.

4. AI processing

Penpal uses AI models from third-party providers to give feedback, mark work, transcribe recordings and answer Pally questions. Each request sends only what that task needs, such as the text being checked and the assignment it belongs to. It never includes a student’s name, email address or any identifier other than an internal reference that means nothing outside Penpal.

Pally receives the question a student types and the recent turns of that conversation. Students are reminded not to share personal details with it. A Pally conversation can be read only by the person who had it, and a school decides whether Pally is turned on at all.

Our AI providers currently process requests in Singapore, outside Hong Kong. We record which provider and region handled every request.

5. Who we share it with

We share personal data only with service providers who help us run Penpal, and only as far as each needs:

• Hosting, database and file storage providers, which store Penpal’s data.
• AI providers, as described in section 4.
• Google, if a school uses Google sign-in, and for the fonts this website loads.
• YouTube, which plays recordings on Listening papers through its privacy-enhanced embed.
• Pexels, the source of assignment cover photos.
• The push service of a person’s browser or device, if they turn on notifications. A push message carries no content.

6. Cookies and local storage

Penpal sets one cookie to keep you signed in, and a short-lived cookie while you sign in with Google. Both are strictly necessary. We use no analytics or advertising cookies.

Your browser may also keep a local copy of an unsaved draft and a few display preferences on your own device, so work is not lost if the connection drops.

7. How long we keep it

We keep a school’s data for as long as the school subscribes to Penpal, because it forms the school’s record of its students’ work. When a school asks us in writing to delete its data, we delete it, including Pally conversations and records of AI requests.

Detailed records of individual AI requests are kept for 90 days and then removed. Demo enquiries are kept for as long as we need them to follow up.

8. How we protect it

Each school’s data is kept apart from every other school’s. Teachers see only the students they teach, and access is limited by role. Data is encrypted in transit, credentials for AI providers are encrypted at rest, and important actions are recorded in an audit log.

9. Your rights

Under the Personal Data (Privacy) Ordinance you may ask for a copy of your personal data and ask for it to be corrected. If you are a student, teacher or parent, please make your request to the school, which is responsible for your account; we will help the school respond. For data about a website visit or a demo enquiry, write to hello@penpal.hk.

10. Children

Most people who use Penpal are students under 18. Nobody can sign up for Penpal on their own: every account exists because a school created it. Schools are responsible for informing parents about how Penpal is used, including any AI features they turn on.

11. Changes to this policy

We will update this policy when Penpal changes in a way that affects personal data, and change the date at the top. If a change is significant, we will tell the schools that use Penpal before it takes effect.