Hi Tutor Privacy Policy

Date of Last Update: August 5, 2025

Effective Date: August 5, 2025

Version Number: 20250805V1.0

EASETREND TECHNOLOGY LIMITED (hereinafter referred to as "Hi Tutor", "we", "us", or "our") is the provider and operator of the Hi Tutor application software and services (hereinafter referred to as "the Software"). This Privacy Policy (hereinafter referred to as "this Policy") is intended to explain in more detail to guardians (hereinafter also referred to as "you") and the children under your guardianship (referring to minors under the age of eighteen, hereinafter also referred to as "your child") how we handle personal information and the ways we provide for you/your child to manage and protect this information. To ensure you fully understand this Privacy Policy and can make your own choices, we have endeavored to explain it in clear and understandable terms, with key sections clearly marked or highlighted (especially through bolding, capitalization, underlining, etc.). We also provide a pop-up notification when you first use our services to draw your attention to the core content of this Privacy Policy.

Guardian Reminder: Before using our products and/or services, please carefully read and understand these rules. After accepting and agreeing to these rules, you may then permit your child to use our products and/or services. Guardians are requested to treat children's personal information with caution and ensure that your child's related actions (such as authorization, provision of information, etc.) are conducted with your consent.

Child Reminder: If you are a child, please inform your guardian to read these rules, and use our products and/or services under your guardian's management and with their authorized consent.

This Policy applies to all products and services provided by Hi Tutor, including applications for computers and mobile smart terminals, mini-programs, web pages, or other forms that may appear in the future. It is important to note that this Policy does not apply to services provided to you by third parties other than Hi Tutor.

Before using our products or services, submitting personal information to us, or agreeing to our collection of your personal information, please read this Policy carefully to understand our practices regarding your personal information, and please visit frequently to stay informed of any updates to this Policy.

Special Note on the Protection of Children's Personal Information: The protection of children's personal information requires the joint efforts of you and us. We hope you will assist us in protecting your child's personal information. Please be aware that children's personal information is considered sensitive personal information.

Should you have any questions, please feel free to contact us at any time via the following method:

privacy@transsion.com

You can also access this Privacy Policy through the following path:

Hi Tutor APP > Me > Privacy Policy

This Privacy Policy will help you understand the following:

  1. How We Collect and Use Your Personal Information
  2. How We Store and Protect Your Personal Information
  3. How We Share, Transfer, and Disclose Your Personal Information
  4. How Your Personal Information Is Transferred Cross-Border
  5. Your Rights Regarding Your Personal Information
  6. How We Handle Children's Personal Information
  7. Third-Party Service Providers and Their Services
  8. Supplements and Updates to This Policy
  9. How to Contact Us

1. How We Collect and Use Your Personal Information

General Overview

Hi Tutor firmly believes that fundamental privacy rights should not differ depending on where you live in the world. Therefore, we treat any information relating to an identified or identifiable natural person as "personal information," regardless of where that person resides.

We will only collect information necessary for specified, explicit, and legitimate purposes and will ensure that your information is not further processed in a manner that is incompatible with those purposes. If we intend to use your personal information for other purposes not specified in this Privacy Policy, we will obtain your consent again.

When collecting personal information, we do so in three ways: 1) information you provide to us directly; 2) information we collect through automated means during your use of the Software (e.g., device information, service log information).

You have the right to choose whether or not to provide personal information when using Hi Tutor products or services or when we request it. You are not required to provide personal information to Hi Tutor, but in some cases, if you choose not to, Hi Tutor may not be able to provide you with related products or services, nor respond to or resolve any issues you encounter. We will only collect and use your personal information for the purposes described in this Policy. The following are examples of the personal information we may collect:

Hi Tutor's Main Business Functions and Collection/Use Scenarios

The main business function of this Software is to provide online courses and intelligent tutor services.

To Provide You with Intelligent Tutor Services

Upon first entering the service, the user can set a nickname. The service will conduct conversations with you based on the nickname you set. If you uninstall and reinstall the service, we will clear the nickname.

We provide users with an AI intelligent tutor service. For any questions that arise during the learning process, users can ask the intelligent tutor to receive AI-generated intelligent answers. Please be aware that in this scenario, the service will acquire the questions you or your child input (including text, voice), and selected content. The service will generate a corresponding reply through an AI large model. If you use the voice input function, we will call upon your microphone permission. This permission is necessary for the function. If you refuse to grant this permission, you can still use other methods to input your questions.

Please be aware that to improve the accuracy of replies, optimize our service quality, and enhance our algorithm models, the questions you or your child input and the replies generated by the AI large model will be used for data annotation, improving voice recognition accuracy, and for algorithm training to optimize the large model. In the event of a service abnormality, we may need to perform manual troubleshooting, at which time we may view the input questions to investigate the abnormality.

We will record your course browsing history to help you quickly locate previously played content and provide you/your child with a more convenient playback service. We will intelligently trigger the AI study-aid function for you based on your/your child's browsing behavior (repeated playback, long-duration stays).

We will acquire your quiz-taking records and intelligently recommend the difficulty of questions by analyzing your/your child's performance through the AI large model.

To Improve Our Products or Services

We may also obtain your device information and network information for the reasonable need of improving our products or services. Specifically, we will acquire your operating system version number, your country, time zone, device language, device information (brand, model), network type, IP address, and in-service click and browsing records. This information will be aggregated into statistical data for internal analysis and to optimize our products and services.

Please be aware that to protect your and your child's privacy and security, we will not collect your device identifiers (e.g., IMEI, advertising ID, etc.).

Other Situations Where Your Information May Be Collected

We may also collect other information about you, your device, or your use of the services in other ways, which will be explained to you at the time of collection, and we will obtain your consent.

To better improve our product layout and provide you with higher quality services, we may conduct research, statistical analysis, and prediction on the collected information in an anonymized manner (including using anonymous data for machine learning or model algorithm training). We will take technical measures and other necessary measures to process the collected personal information so that such data cannot be re-identified to a specific individual and cannot be restored. According to applicable laws and regulations, the use of such processed data does not require separate notification to you or your consent.

2. How We Store and Protect Your/Your Child's Personal Information

1. How We Store Personal Information

Personal information collected with your consent will be stored in accordance with the provisions of relevant national laws and regulations on personal privacy data protection. Where not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions other than where the business is located.

Currently, Hi Tutor may store your/your child's personal information in: Frankfurt, Ireland. Specifically:

Whether we store personal information in the country of business or in other countries or regions without violating legal provisions, we will retain it in accordance with the relevant laws and regulations regarding data storage. We will also consider the characteristics, scope, and purpose of the personal information processing, the risks that may be encountered during processing, and the serious consequences of any damage, and implement necessary security measures. For example, we will use encryption and de-identification methods to store collected personal information. At the same time, we will store the information for the shortest period required for business needs, unless you agree to extend the retention period or it is permitted by law. For data that exceeds the storage period, or data that you request us to delete, we will delete it or take other appropriate measures without violating relevant laws and regulations.

2. How We Protect Your Personal Information

We will also take other necessary measures to ensure the security of your personal information to prevent data misuse, unauthorized access, and unauthorized modification, disclosure, or destruction.

We implement security measures designed to protect your personal information, and we regularly monitor our systems for possible vulnerabilities and attacks. We use administrative, technical, and physical safeguards to protect your personal information, taking into account the nature, processing, and security of the personal information. We continuously strive to improve these safeguards to ensure the security of your personal data.

Of course, it must be reminded that no matter how perfect the measures are, it is impossible to absolutely guarantee the avoidance of data storage security incidents. In the event of a security breach, we will, in accordance with the requirements of relevant laws and regulations, report to the appropriate regulatory authorities and, as required by the regulatory authorities, provide the type of personal data involved in the data breach, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take. We will take all possible measures to remedy or mitigate the damage and consequences of the data breach. Where permitted or required by law and regulations, we will promptly inform you of the possible consequences or significant harm the data breach may have on you, so that you can take appropriate measures in a timely manner to protect your rights as much as possible.

As no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to the necessary security measures we take, users also need to strengthen their awareness of privacy security risks. For example, when you jump to a third-party website, link, product, or service through our services, please be careful and read the terms and conditions of that website, link, product, or service regarding the security of any data information collected. We do not assume any legal responsibility for data security issues caused by such third parties. If you find that certain content, advertisements, or functions of our websites, products, or services may be provided by a third party and may endanger your privacy and security, please contact us promptly, and we will give priority to handling it in accordance with laws and regulations.

3. How We Share, Transfer, and Disclose Your Personal Information

Regarding the sharing, transfer, and disclosure of your personal information, we adhere to the principles and requirements of minimization, necessity, and legal compulsion. Under normal circumstances, we will not share, transfer, or disclose your personal information externally. However, where applicable or permitted by relevant laws and regulations, we may share, transfer, or disclose your personal information in the following situations:

1. How We Share Personal Information

We do not sell any personal information to third parties. To provide you/your child with timely services, your personal information may be shared with Hi Tutor's affiliated companies. We will only share the collected personal information within Hi Tutor's affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy. If the relevant purposes are not included in this Policy, we will state them in the privacy policy or notice of the specific product or service.

We may share necessary personal information with authorized third-party partners (including technical service providers) to perform certain functions or to provide better services and user experiences.

When using this service, we will use cloud storage services and large model services provided by technical service providers to provide intelligent tutor services.

We will embed the software development kits (SDKs) of authorized partners in this Software. Specifically:

SDK Provider SDK Name Data Collection & Purpose Privacy Policy
Google LLC Firebase SDK Device information, records of personal app usage behavior https://firebase.google.com/support/privacy?hl=en-cn

We adhere to the principles of minimization, necessity, and legal permission for such sharing activities. Before sharing information, we will sign strict confidentiality agreements with authorized partners, requiring them to handle personal information in accordance with this Policy and applicable laws in your jurisdiction, and to take relevant confidentiality and security measures. In addition, we will require them to provide data security capabilities and information security qualifications (e.g., graded protection assessment, information security management system, etc.).

In transactions involving mergers, acquisitions, or bankruptcy liquidation, asset transfers, etc., if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures, and require such entities to take confidentiality and security measures no less than those required by this Policy to process personal information.

2. How We Transfer Personal Information

Hi Tutor will not transfer your/your child's information to any other party unless:

3. How We Disclose Your Personal Information

Hi Tutor may be required to disclose personal information in accordance with legal requirements, legal process, litigation, and/or requests from government departments and authorities. If disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information.

In addition, we may share your personal information with the following parties:

4. How Personal Information Is Transferred Cross-Border

For the purposes described in this Privacy Policy, and in compliance with the applicable laws and regulations of your region and with your authorized consent, we may transfer the collected personal information to the resources or servers mentioned in Section 3 of this Policy for storage or processing. We may also transfer personal information to third-party service providers and business partners, and therefore your/your child's data may also be transferred to other countries or regions. The privacy protection laws of these countries or regions may differ, and the jurisdictions where these servers are located may or may not protect personal information to the same standards as your jurisdiction. However, we will still strive to comply with our privacy policy to protect your personal information, and we will carry out the cross-border transfer and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information to a region outside of your jurisdiction, whether to our affiliates or to third-party service providers, we will comply with relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers meet the requirements of applicable local data protection laws.

5. Your Rights Regarding Your Personal Information

As a data subject, you have a series of rights regarding your personal information, including the right to confirmation, access, correction, deletion, withdrawal of consent, and complaint (hereinafter referred to as "requests"). We fully understand and respect these rights, and according to applicable law, such rights will also be subject to specific exclusions and exceptions. We will also take active measures to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. For your legitimate and reasonable requests, we do not charge a fee in principle. However, for multiple, repetitive requests that exceed a reasonable limit, we will charge a certain reasonable fee based on actual administrative costs, to the extent permitted by applicable law. We may refuse requests that are groundless, require excessive technical means (e.g., requiring the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, are highly impractical, or violate mandatory legal provisions.

Right to Confirmation and Access:

We inform you of how we collect and process personal information through this Privacy Policy or through the privacy policies or notices of specific product and service scenarios. You have the right to confirm or refuse this collection and processing by ticking a box or other means. However, after you refuse, some functions that require your explicit authorization and consent may become unavailable. You can directly query the personal information you/your child have already provided to us on the interface of our products or services. For situations where you cannot query, you can send an email to privacy@transsion.com. We will process it promptly upon receiving your email.

Right to Correction and Deletion:

When your/your child's personal information changes, or when you find that the personal information we have collected and processed is incorrect or incomplete, you have the right to ask us to make corrections or additions. For some personal information, you can directly correct or modify it on the relevant function pages of the product or service. When the purpose for which we collected your personal information has been achieved or is no longer necessary, or when you find that we have collected and processed your personal information in violation of laws, administrative regulations, or the provisions of this Privacy Policy, you have the right to request that we delete the relevant personal information. For personal information for which a correction or deletion channel has not yet been provided, you can request correction or deletion by contacting privacy@transsion.com.

However, in some cases, we may not approve your deletion request, for example, when Hi Tutor is legally obligated to retain relevant records to comply with applicable local laws. Please also note that if you request to delete your/your child's information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from the backup system, but we will securely store your/your child's personal information and prevent it from being further processed until the backup system is updated and your information can be deleted or anonymized.

Right to Withdraw Consent:

To realize the corresponding functions of our different products or services, we will require necessary personal information in accordance with applicable local laws. This is explained in the "How We Collect and Use Your Personal Information" section of this Privacy Policy. You can withdraw the consent you previously granted to us for a specific purpose, including the collection, use, and/or disclosure of your/your child's personal information that we hold or control, by deleting information, turning off device functions, or submitting a withdrawal of consent request. You can contact us for related operations by sending an email to privacy@transsion.com. We will process your request within a reasonable time after you send it, and thereafter will not collect, use, and/or disclose your/your child's personal information in accordance with your request.

If you withdraw your consent, you/your child may not be able to continue to receive some and/or all of the features of Hi Tutor's products and services. Withdrawing your consent or authorization will not affect the validity of our previous processing activities based on your consent.

Right to Complain:

You have the right to file a complaint by sending an email to privacy@transsion.com. We will respond promptly upon receiving your complaint. If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you can also complain or report to the local statutory personal data protection authority, or file a lawsuit in a court with jurisdiction.

Right to Manage Privacy Settings:

You have the right to control your privacy settings, through which you can restrict our collection, use, disclosure, or processing of your personal information. For example, you can choose to turn on or off the "Microphone" function and permission; you can also get more detailed information about the device's security status in "Settings". If you have previously agreed to enable the corresponding permissions or agreed to our use of your personal information for the aforementioned business scenarios, you can turn it off through Settings > App Management > Permission Management or change your decision by contacting us at privacy@transsion.com.

6. Rights in Certain Jurisdictions

Please note in particular: According to the applicable laws of certain jurisdictions, you may have the following data subject rights:

We have the right to refuse to process your requests, and we have the right to refuse certain requests under applicable exemptions or where permitted by applicable law. For example, some requests are clearly unfounded or manifestly excessive, or require the disclosure of third-party information.

7. How We Handle Children's Personal Information

Hi Tutor understands the importance of protecting children's personal information. Therefore, children under the age of 18 or the equivalent age stipulated by law in your jurisdiction (the definition of a child's age varies according to the laws and regulations of different countries or regions, and we will define a child based on the laws and regulations of the specific country or region where the business is located) must use our products or services with the permission and guidance of their legal guardian and where permitted by relevant laws and regulations. In principle, we do not directly provide services to children, do not actively collect children's personal data, and do not use children's personal information for marketing purposes. We will only collect, use, and disclose children's personal information with the explicit permission and consent of the child's guardian, where permitted by law, and where the collection of such information is truly necessary. If at any time a guardian needs to access, modify, or delete personal information related to the person under their guardianship, please contact us in the manner described in this Policy, and we will respond to you in a timely manner. If you discover that relevant child information has been transmitted to us without the knowledge of the child's legal guardian, please send an email to privacy@transsion.com to contact us, and we will delete the relevant information as soon as possible. If we discover that we have collected children's personal information without first obtaining verifiable guardian consent, we will also try to delete the relevant content as soon as possible.

8. Third-Party Service Providers and Their Services

When you use Hi Tutor products or services, you may receive links to websites from third parties other than us or content and services provided by third parties. You can choose whether to visit or accept websites, products, and services provided by third parties based on your own judgment. Our privacy policy does not apply to any products and services provided by any third party. Because we cannot substantially control a third party, we are not responsible for the third party's collection and processing of your personal information. When you submit any information to such a third party, please carefully read the third party's privacy policy and be mindful of protecting your own personal information.

9. Supplements and Updates to This Policy

We reserve the right to update or modify this Policy from time to time based on changes in our business, technology, applicable laws, and practices. If this Policy is modified, we will post the latest policy here (on this page) or notify you by sending a separate notice. Please pay regular attention to this page or the notices we send you to stay informed of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not diminish your rights under this Privacy Policy without your express consent.

When we collect additional personal information or when we use or disclose your personal information for new purposes, we will seek your express consent again in accordance with applicable law.

The content of the Hi Tutor products or services described in this Policy may vary depending on the type of product you use, the system version, or the requirements of local laws and regulations.

10. How to Contact Us

If you have any suggestions, questions, or concerns about our privacy policy or our practices regarding the protection of personal information, please contact us through the following method:

Email: privacy@transsion.com (Note: This email is only for receiving emails related to our privacy policy or our practices in personal information protection)

We will review your privacy or personal information request as soon as possible and reply to you within 15-30 days after verifying your user identity. If your request itself involves complex or significant issues, we may ask you for more information.

If you are not satisfied with our reply, especially when your legitimate rights and interests have been violated by us, you can seek a solution from the relevant data protection regulatory authority in your jurisdiction. If you consult us about the above, we will provide information on possible relevant complaint channels based on your situation.

Thank you for taking the time to read our Privacy Policy!