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Privacy Policy

Last updated: 15 May 2026

This Privacy Policy explains how Althemax International Limited ("AlthemaxAI", "we", "us", "our") collects, uses, shares, and protects personal information when you use the ProgressMentor mobile application and related services (the "App"). By using the App you agree to the practices described in this Policy. If you do not agree, please do not use the App.

1. Who We Are

The data controller for the App is Althemax International Limited, a company registered in Hong Kong. Contact: [email protected].

2. Information We Collect

We collect the following categories of personal information:

CategoryExamplesSource
Account information Email address, display name, hashed password, Apple ID identifier (when you use Sign in with Apple), account creation date. You, Apple
Profile information Year group, subject preferences, school or region if you choose to provide it. You
Learning data Answers you submit, marks, hints requested, exercise history, mastery scores, archive of past exercises. App usage
Technical data Device model, iOS version, App version, IP address, crash logs, diagnostic events. Your device
Communications Emails, support messages, feedback you send to us. You

We do not knowingly collect special category personal data (such as health, racial or ethnic origin, or political opinions). Please do not enter such information into the App.

Information collected automatically

When you use the App, we automatically collect technical data and usage events (such as which screens are opened, how long sessions last, and which exercises are attempted) for the purposes described in section 3. We do not use third-party advertising trackers in the App.

3. How We Use Information

We use personal information to:

  • create and maintain your account and authenticate you;
  • provide the core features of the App, including generating, marking, and explaining practice questions;
  • personalise content, difficulty, and progress tracking;
  • maintain an archive of past exercises and wrong-question reviews;
  • improve and develop new features, including improving question quality and AI accuracy;
  • diagnose and fix bugs, prevent abuse, and ensure security;
  • communicate with you about service updates, support, and important notices;
  • comply with legal obligations and enforce our terms.

Legal bases (UK / EEA users)

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

  • Contract — to provide the App and account services you request;
  • Legitimate interests — to improve and secure the App, prevent fraud, and develop new features, where these interests are not overridden by your rights;
  • Consent — where required, for example for optional analytics or marketing communications. You can withdraw consent at any time;
  • Legal obligation — to comply with laws that apply to us.

4. AI Processing

The App uses third-party large language models to generate practice questions, hints, and explanations, and to mark certain free-text answers. When AI features are used, we may send the prompt and necessary context (for example the question and your answer) to our AI provider. We do not knowingly send your name, email, or account identifiers to AI providers, and we instruct providers not to use the data to train their general models where such an option is offered.

5. How We Share Information

We do not sell your personal information. We share it only as follows:

  • Service providers — cloud hosting (Amazon Web Services), authentication (Amazon Cognito, Apple), database (Amazon RDS), AI model providers, error monitoring, and email delivery, each acting on our instructions under appropriate contracts;
  • Apple — when you use Sign in with Apple or make in-app purchases, Apple processes information in accordance with its own privacy policy;
  • Legal and safety — where required to comply with law, legal process, or to protect the rights, property, or safety of AlthemaxAI, our users, or others;
  • Business transfers — in connection with a merger, acquisition, or sale of assets, in which case we will require the recipient to honour this Privacy Policy.

6. International Transfers

We are based in Hong Kong and use service providers located in the United Kingdom, the European Union, the United States, and other regions. When we transfer personal information across borders, we use appropriate safeguards such as standard contractual clauses where required.

7. Data Retention

We retain personal information for as long as your account is active and for as long as necessary to provide the App, comply with our legal obligations, resolve disputes, and enforce our agreements. Learning data is generally retained while your account exists so that the App can show your progress over time. When you delete your account, we will delete or anonymise your personal information within a reasonable period, except where retention is required by law.

8. Your Rights

Depending on where you live, you may have the right to:

  • access the personal information we hold about you;
  • correct inaccurate or incomplete information;
  • delete your personal information;
  • object to or restrict certain processing;
  • port your information to another service;
  • withdraw consent where processing is based on consent;
  • complain to your local data protection authority.

To exercise these rights, email [email protected]. You can also delete your account from within the App, which will trigger deletion of your personal information as described in section 7.

9. Children's Privacy

The App is intended for users aged 13 and over. If you are between 13 and the age of majority in your jurisdiction, you must have permission from a parent or legal guardian to use the App. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, contact us and we will delete the information.

10. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information, including encryption in transit (HTTPS/TLS), encryption at rest for databases, role-based access controls, and managed authentication via Amazon Cognito. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Tracking Technologies

The App does not use third-party advertising trackers and does not track you across other apps or websites for advertising purposes. We use Apple's App Tracking Transparency framework where applicable. Standard server logs (including IP addresses) are kept for security and diagnostics.

12. Push Notifications

With your permission, we may send you push notifications about practice reminders, account activity, and App updates. You can disable notifications at any time in your device settings.

13. Third-Party Links

The App may contain links to third-party sites or resources. We are not responsible for their content or privacy practices and recommend you review their policies.

14. Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by other reasonable means before the changes take effect. The "Last updated" date at the top of this page shows when this Policy was last revised.

15. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at [email protected].

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