Dimension Space — Children's Privacy Statement and Parental Consent

Version: v1.0
Effective Date: 8 May 2026
Applies to: Parents / legal guardians of users under 18
Companion Documents: This document should be read together with the Privacy Policy and Terms of Service.
Legally Binding Version: The Traditional Chinese version of this document is the legally binding version. This English version is for convenience only; in case of discrepancy, the Traditional Chinese version shall prevail.

A Letter to Parents

Dear Parent,

Thank you for taking a few minutes to read this document. We are the Dimension Space team — a group of Hong Kongers who have built an AI learning companion for Hong Kong secondary school students.

If you are a busy parent, these three things matter most:

✅ All of your child's data is stored only in Hong Kong and will not be transferred outside Hong Kong
✅ We will not use your child's data to train AI and will not sell their data to advertisers
✅ You can view, delete, or withdraw consent at any time, and we will not penalise your child for it

If you have questions, email support@starcloudedu.com.

— The Dimension Space Team

1. Why This Document Exists

1.1 Best Interests of the Child (UNCRC Art. 3)

We commit to "best interests of the child" as the overarching principle for all child-related decisions, including service design, dispute resolution, data protection, and emergency intervention. This principle is consistent with Article 3 of the United Nations Convention on the Rights of the Child (UNCRC) and Hong Kong's longstanding stance on child protection.

1.2 Hong Kong Privacy Framework

The Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD) has additional guidance on processing children's and youth data. While the Personal Data (Privacy) Ordinance (PDPO) does not set a specific age threshold, the PCPD strongly recommends:

• For users under 13, parental consent should be obtained before collecting personal data
• For users aged 13–17, while they can legally consent independently, we voluntarily add a parental confirmation layer for sensitive features (paid features, long-term storage)

1.3 The Child's Right to Be Heard (UNCRC Art. 12)

We also respect children's rights to independently express their views, report concerns, and seek help. Parental consent is a safeguard, but it does not eliminate the child's own voice. See Privacy Policy §9.4 for child-voice channels and reporting.

2. Our Five Commitments on Handling Children's Data

These five are our core commitments. If we ever need to amend them due to legal, business, or technical reasons, we will give 60 days' advance notice under the change protocol in Section 7 of this document, and parents may choose to delete the account (with proportional refund of paid-but-unconsumed fees).

1. Data only in Hong Kong — All data is stored only on Hong Kong servers and will not be transferred outside Hong Kong (except for the standard Apple App Store necessity)
2. No proactive AI training use — We will not use your child's data to train AI; the commercial AI API contract also prohibits using customer input for training. If third-party API terms change, we will notify under the change protocol
3. No behavioural advertising — We do not display ads, do not use learning data for ad targeting, and embed no advertising SDKs
4. No public question bank — Photos, exam papers, and uploaded content will not be shown to other users, nor rewritten by AI into a public question bank
5. Always deletable, no penalty — You may withdraw consent or delete data at any time, and we will not retaliate or raise prices

3. Treatment by Age Group

"Sensitive features" include: any subscription, first-time question photo, Diamond purchase exceeding HK$50/day, upload features.

4. What Data We Collect (Reader-Friendly Version)

The full list is in Privacy Policy Section 3.

We do collect: nickname, grade, age band, learning progress, question photos, AI conversation content; the email used in the parental consent flow; subscription payment record (credit card data is handled directly by Apple — we never touch it).

We absolutely do not collect: real names (unless used as nickname), school / class / student ID, ID card number / date of birth, phone number, contacts / photo album / microphone, location / GPS, or sensitive data such as health / race / religion.

Special photo protection: original photos are stored only in the child's personal space, not shown to other users, and can be deleted in Settings at any time.

5. Your Child's Rights — and Yours

Children (assisted by you if under 13) have PDPO rights: access, correction, deletion, and objection (see Privacy Policy Section 10).

You additionally have the right to:

• View your child's learning progress and weekly report (if enabled), Diamond balance, and spending
• Set the daily Diamond purchase limit (default HK$50), enable parental supervision mode, and block certain features
• Withdraw consent at any time: partial withdrawal by emailing us; full withdrawal by deleting the account (see Section 8)

Regarding access to AI conversation content: based on PCPD's special protection of youth privacy and the child's autonomous expression rights, the parent dashboard does not display conversation content by default. However, this clause does not override your guardianship rights under the Parent and Child Ordinance (Cap. 429) and the Guardianship of Minors Ordinance (Cap. 13):

• In emergencies (e.g., reasonable suspicion of grooming, self-harm, or abuse), email support@starcloudedu.com — after verification, we will help you view the relevant conversations and contact the Hong Kong Police or Social Welfare Department if necessary
• In legal proceedings (e.g., Hong Kong court orders, SWD child protection procedures, police criminal investigations), we will comply with the legal order

Emergency contacts: if you suspect your child is in immediate danger, dial 999 or call the SWD child protection hotline 2755 1122, and email us — we will cooperate immediately.

6. Parental Identity Verification

We use the industry-standard email verification: child enters your email in the App → you receive a verification email → click the link → fill in this consent form → upon submission, the child's feature is unlocked.

Recognised parental status: either biological parent may sign on behalf of the family; legal guardians (including step-parents, adoptive parents, foster families, kinship guardians); other adult guardians authorised by a Hong Kong court. If the other parent has a different view, see "Parental Disagreement" below.

Multiple children sharing one parent email: yes — each child's account has its own consent status.

Parental Disagreement: we apply the best interests of the child principle — features are activated upon receiving the first parent's consent; if the other parent objects in writing, we will immediately suspend the disputed feature until the parents reach agreement or a Hong Kong family court order is issued. We do not arbitrate family disputes nor take sides.

Limitation Statement: we do not provide an absolute guarantee of email-verification effectiveness (e.g., if someone uses a forged email). If you discover unauthorised impersonation, email support@starcloudedu.com immediately.

7. Parental Consent Form (Signature Required)

In actual operation, this section is presented as a web form; submission constitutes signature.

Items I Consent To

I, [Parent Name], as the parent / legal guardian of [Child Nickname] (age [Child Age]), confirm that:

☐ I have read and understood the Privacy Policy, Terms of Service, and this Parental Consent; I consent to my child using Dimension Space, and I understand:

• My child's data is stored only in Hong Kong, but Apple is involved in account identification / subscription cross-border
• My child's AI conversations are sent to our Hong Kong backend, but will not be used to train AI
• My child's data will not enter a public question bank, will not be used for behavioural advertising, will not be sold to third parties
• AI answers may be wrong and cannot replace school teaching or professional advice; Dimension Space does not warrant any examination outcome

About sensitive features (subscription, Diamond purchases, upload features): when the child uses them for the first time, the App will pop up to ask for your email confirmation — you do not need to pre-authorise all features in advance.

Parental Identity Declaration

I authorise Dimension Space to use my email to contact me (limited to App-related matters; not for marketing). I understand that I may withdraw this consent at any time by emailing support@starcloudedu.com.

8. How to Withdraw Consent

Partial Withdrawal (cancel certain features): email support@starcloudedu.com with subject "Withdraw Parental Consent — [Child Nickname]". We will process within 7 days.

Full Withdrawal (terminate use): in App → Settings → Delete Account → 30-day grace period (revocable) → after grace period, all data is deleted under the Privacy Policy procedure.

Consequences of Withdrawal: paid-but-unconsumed fees are refunded proportionally (see Terms Section 7); used Diamonds are non-refundable; learning progress is deleted (you may export before withdrawing); we will not obstruct re-registration.

9. Contact Us

If unresolved, you may complain to the PCPD (www.pcpd.org.hk / 2827 2827).

Appendix — Parent FAQ

Q1: My child is 14. Do I need to sign this? Only when they use sensitive features (subscription, Diamond purchase exceeding HK$50/day, upload features) — we will email you for confirmation. For general learning use, 13–17-year-olds can use the App independently.

Q2: Can I view my child's AI conversations directly? The parent dashboard does not display conversation content by default (respecting the child's autonomous expression). However, if you have reasonable suspicion of grooming, self-harm, or abuse risk, email support@starcloudedu.com — after verification, we will help you view the relevant conversations. This safeguards your guardianship rights under Cap. 429 / Cap. 13.

Q3: How long does this consent last? For as long as the child is under 18. On their 18th birthday, we will automatically convert the account to an adult account and email you.

Q4: I have moved abroad — is this consent still valid? Yes. The geographic basis of this consent is the child's location, not the parent's location.

Appendix — Trilingual Versions

This document is provided in Traditional Chinese (legally binding version), Simplified Chinese, and this English version (for convenience only). In case of discrepancy, the Traditional Chinese version shall prevail.

If you have questions, email support@starcloudedu.com.

— The Dimension Space Team