Privacy Policy
EC2 Limited, Company No. 79142069-000-11-25, Hong Kong
Effective Date: 9 March 2026
Questions? privacy@ec2excel.com
Your privacy matters to us.
EC2 Excel is a platform built for students — many of whom are young people. That means we take data protection especially seriously. This Privacy Policy explains, in plain English, exactly what data we collect, why we collect it, how we use it, and what rights you have over it. No hidden surprises, no data games. Just transparency.
This Policy forms part of our Terms of Service. By using EC2 Excel, you confirm that you've read and understood both documents.
1. Who We Are
EC2 Excel is an online exam revision platform operated by EC2 Limited, a company incorporated in Hong Kong (company number 79142069-000-11-25).
When we say "EC2 Excel", "we", "us", or "our", we mean EC2 Limited. When we say "you" or "your", we mean you — the student, parent, educator, or institution using our platform at www.ec2excel.com or our mobile app (collectively, the "Services").
EC2 Limited is the data controller for the personal data you provide when using the Services — meaning we decide why and how your data is processed, and we're responsible for keeping it safe.
Our Data Protection contact is reachable at privacy@ec2excel.com.
2. Who This Policy Applies To
This Policy applies to everyone who uses EC2 Excel, including:
- Students — whether using a free or paid account
- Parents or guardians — who create accounts on behalf of children
- Teachers and educators — using the platform for classroom or tutoring purposes
- School or institutional administrators — managing group or school accounts
- Visitors — who browse www.ec2excel.com without registering
A note on younger users: EC2 Excel is designed for exam students — typically aged 15 and above — and is not intended or designed to attract children under the age of 13. We do not knowingly collect personal data from anyone under 13. If you are under 13 and wish to use the platform, please ask a parent or legal guardian to do so on your behalf.
If you believe a child under 13 has provided us with their data without parental involvement, please contact us at privacy@ec2excel.com and we will delete it promptly.
For users under 18, we encourage parental awareness of their use of the Services and apply additional safeguards where appropriate.
3. What Data We Collect
We only collect data that we actually need.
Data you give us directly
| Data | When |
|---|---|
| Name and email address | When you register an account |
| Password (stored encrypted) | When you register or change your password |
| School or institution name | When you set up a school or teacher account |
| Syllabus and subject preferences | When you set up your study profile |
| Submitted exam answers and practice papers | When you use our AI Feedback feature |
| Payment information | When you subscribe to a paid plan (processed securely via our payment provider — we never store full card details) |
| Communications | When you indicate how you'd like to be contacted |
Data we collect automatically
When you use the Services, we automatically collect certain technical and usage data, including:
- IP address and approximate location
- Device type, browser version, and operating system
- Pages visited, features used, time spent, and links clicked
- Login timestamps and session data
- Cookies and similar tracking technologies (see Section 9)
Data generated by our AI
When you submit exam answers for AI grading, our systems process the content of your Submitted Materials to generate AI Feedback. Your Submitted Materials are retained for as long as your account is active so you can review them alongside your feedback.
4. How We Use Your Data
To provide the Services
- Creating and managing your account
- Delivering AI-powered grading and feedback on your Submitted Materials
- Personalising your study experience based on your syllabus and subject choices
- Processing your Subscription and managing payments
To improve EC2 Excel
- Analysing how the platform is used to identify bugs, improve features, and develop new content
- Monitoring platform performance and security
- Conducting internal research and analytics (using aggregated, anonymised data where possible)
To communicate with you
- Sending account-related emails (registration confirmations, password resets, subscription updates)
- Notifying you of changes to our Services, Terms of Service, or this Privacy Policy
- Sending educational updates, product news, or promotional content — but only if you've opted in (you can opt out at any time)
To keep the platform safe and legal
- Detecting and preventing fraud, abuse, and security threats
- Complying with applicable laws, regulations, and legal obligations
- Responding to lawful requests from government authorities or law enforcement
5. AI Training
We do not use your Submitted Materials or your personal data to train AI models. Your submissions are used solely to generate feedback for you.
6. Legal Basis for Processing
| Basis | When we rely on it |
|---|---|
| Contract | To provide the Services you've signed up for — e.g. account management, AI Feedback, Subscription processing |
| Legitimate interests | To improve the platform, prevent fraud, ensure security, and analyse usage — where our interests don't override your rights |
| Legal obligation | To comply with Hong Kong law, regulatory requirements, or lawful court/authority orders |
| Consent | For marketing communications and optional cookies — where you've actively opted in |
You can withdraw consent at any time where we rely on it (see Section 11 for your rights).
7. Who We Share Your Data With
We don't sell your personal data. Full stop. We only share it in the following circumstances:
Service providers: We work with trusted third-party companies who help us run EC2 Excel — including cloud hosting providers, payment processors, email delivery services, analytics tools, and AI infrastructure providers. These providers only process your data on our instructions and are contractually required to keep it secure and confidential.
Group companies and affiliates: We may share data within the EC2 Limited group of companies for internal administration, product development, and operational purposes.
Legal and regulatory authorities: We may disclose your data to government bodies, courts, law enforcement, or regulators where required by law or in response to a valid legal request. We'll always aim to notify you where we're legally permitted to do so.
Professional advisers: Our lawyers, accountants, auditors, and other advisers may access data where necessary in the course of their professional duties, subject to obligations of confidentiality.
With your consent: We may share data with third parties if you've explicitly asked us or agreed for us to do so.
Business transfers: If EC2 Limited is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We'll notify you in advance and your rights under this Policy will continue to be protected.
8. International Data Transfers
EC2 Limited is based in Hong Kong. Your data may be stored and processed in Hong Kong or in other countries where our service providers operate.
Where data is transferred outside Hong Kong, we take reasonable steps to ensure it receives an equivalent level of protection — including contractual safeguards with our service providers. By using EC2 Excel, you consent to such transfers as described in this Policy.
If you are accessing EC2 Excel from the European Economic Area (EEA), we ensure transfers comply with applicable EU data protection law, including through the use of standard contractual clauses or other approved mechanisms.
9. Cookies and Tracking Technologies
Cookies are small text files stored on your device when you visit a website. They help us make EC2 Excel work properly, remember your preferences, and understand how people use the platform.
For full details on the cookies we use and how to manage them, please see our Cookie Policy.
Managing your cookies: You can manage your cookie preferences at any time through your browser settings or via our cookie consent banner. For full instructions on how to control, disable, or delete cookies, please refer to our Cookie Policy.
| Type | Purpose | Can you turn them off? |
|---|---|---|
| Essential cookies | Keep the platform running — logins, security, core features | No — the platform won't work without them |
| Analytics cookies | Help us understand how EC2 Excel is used so we can improve it. All data is aggregated and anonymised | Yes |
| Preference cookies | Remember your settings, language, and study preferences | Yes |
| Marketing cookies | Deliver relevant promotional content (only if you've opted in) | Yes |
10. Data Security and Retention
How we keep your data safe
We take security seriously and implement appropriate technical and organisational measures, including:
- Encrypted storage for passwords and sensitive data
- Secure HTTPS connections across the platform
- Regular security monitoring, testing, and backups
- Access controls limiting who within our team can see your data
- A clear process for identifying and responding to data breaches
No system is 100% secure. If you ever suspect unauthorised access to your account, please change your password immediately and contact us at privacy@ec2excel.com.
How long we keep your data
| Data type | Retention period |
|---|---|
| Account data | For as long as your account is active, plus a reasonable period after deletion to handle queries or legal obligations |
| Submitted Materials (exam answers) | Retained for as long as your account is active, so you can review your submitted answers alongside your AI Feedback at any time. Deleted upon account closure or upon your request. |
| Payment records | As required by Hong Kong tax and financial regulations (typically 7 years) |
| Support communications | Up to 3 years after the last contact |
| Analytics and usage data | Up to 2 years in identifiable form; indefinitely in aggregated, anonymised form |
When data is no longer needed, we securely delete or anonymise it. Note that deleted data may temporarily persist in encrypted backups for a short period before permanent removal.
11. Your Rights
| Right | What it means |
|---|---|
| Access | Ask for a copy of the personal data we hold about you |
| Rectification | Ask us to correct any inaccurate or incomplete data |
| Erasure | Ask us to delete your data ("right to be forgotten") — subject to legal retention obligations |
| Restriction | Ask us to pause processing your data in certain circumstances |
| Portability | Ask us to send your data to you or another service in a machine-readable format |
| Objection | Object to processing based on our legitimate interests |
| Withdraw consent | Withdraw any consent you've given us at any time (e.g. for marketing or AI training) |
| Automated decisions | Request human review of any decision made about you purely by automated means that significantly affects you |
How to exercise your rights
Email us at privacy@ec2excel.com with your request. We aim to respond within 30 days. If your request is complex or we receive a high volume, we may take up to 60 days — and we'll let you know if that's the case.
We may ask you to verify your identity before processing a request, to protect your data from unauthorised access.
Some rights may be limited where we need to retain data to comply with legal obligations, protect our legal claims, or safeguard the rights of others.
12. Young Users and Parental Rights
We're committed to protecting the privacy of younger users. As noted in our Terms of Service, EC2 Excel is not intended or designed for children under the age of 13. We do not knowingly collect data from under-13s, and if we become aware that a child under 13 has registered without parental involvement, we will delete their data promptly.
For users under 18, we encourage parents and guardians to be actively involved in their child's use of the platform.
For parents and guardians: You can contact us at privacy@ec2excel.com to access, correct, or request deletion of your child's personal data.
We will never use data from users under 18 for targeted advertising.
13. Third-Party Links
EC2 Excel may include links to external websites — for example, examination board websites. As noted in our Terms of Service, we don't control these sites and this Privacy Policy doesn't apply to them. We recommend reviewing the privacy policy of any third-party site before providing your data.
14. Changes to This Policy
We review and update this Privacy Policy from time to time as our Services evolve or legal requirements change.
When we make changes:
- We'll post the updated Policy at www.ec2excel.com/privacy with a new effective date
- For material changes, we'll notify you by email or in-app notice at least 30 days before they take effect
- Continuing to use EC2 Excel after changes are effective means you accept the updated Policy
15. Contact Us and Complaints
We're happy to answer any questions about this Policy or how we handle your data.
| Privacy enquiries | privacy@ec2excel.com |
| Website | www.ec2excel.com |
| Company | EC2 Limited |
| Address | Hong Kong |
| Company No. | 79142069-000-11-25 |
We aim to respond to all privacy enquiries within 30 days.
If you're not satisfied with how we've handled your concern, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong at www.pcpd.org.hk. If you are based in the EEA, you may also contact your local data protection supervisory authority.
© 2026 EC2 Limited. All rights reserved. EC2 Excel is a product of EC2 Limited, incorporated in Hong Kong.
This Privacy Policy was last updated on 9 March 2026.