Privacy notice

1. Who is responsible

This notice is issued by Tseung Kwan O Methodist Primary School (將軍澳循道衛理小學), the organisation responsible for personal data in the TKOMPS AI Portal.

To ask for a copy of a student’s data, or to ask for a correction, write to Mr Daniel Stroud, Native English Teacher, at the school: 15 Tong Chun Street, Tseung Kwan O, New Territories. Email danstroud85@tkomps.edu.hk, or telephone 2706 0770.

2. Why the school collects this data

The school uses the portal for English practice and feedback. Students practise speaking, writing, presentations, and interviews. The portal gives feedback. English teachers at the school review the work and can leave notes.

3. What is collected

• Sign-in: the school Google account email address and the basic account details Google provides for login.
• Name and class: the name and class number kept on the student’s profile.
• Written work: scripts, answers, and other text the student submits.
• Recordings: voice recordings and video of the student, used to assess speaking and presentation. They are not used to recognise who the student is. Sign-in already does that.
• Practice records: scores, transcripts, feedback from the portal, teacher notes, and time spent on a task.
• Interview booking: if a student books a mock interview, the student’s school email and the chosen time.

The portal does not ask for, and does not store, a student’s medical diagnosis.

4. Whether the student has to provide it

A student must sign in with an @tkomps.edu.hk Google account to use the portal. Without that sign-in, the portal cannot save the student’s work or give feedback. The school decides which classes use the portal.

5. Who can see it, and who receives it

Inside the school, a student can see their own work. English teachers at the school can open student work, review it, and leave notes.

The school also passes data to these companies, which may process it outside Hong Kong:

• Google, so the student can sign in, and so Gemini can produce feedback on submitted work.
• Supabase, which stores the database, the recordings, and the practice records.
• Vercel, which hosts the website.

The school does not use this data for direct marketing.

6. Google Gemini

Writing, audio, and video submitted for feedback are sent to Google’s Gemini API. The school uses Google’s paid Gemini service. Under Google’s terms for that paid service, Google does not use the student’s work to train or improve its general models.

Google may still keep the work and the reply for up to 55 days to detect misuse of the service, and may store that copy outside Hong Kong. The school does not turn on sharing of these records with Google for model training.

7. How long it is kept

Recordings, scores, transcripts, written work, portal feedback, and teacher notes are kept for 365 days from the day they were made. The school then deletes them.

The student’s sign-in, name, and class stay while the student is enrolled. The school deletes them when it closes the account.

8. Access and correction

A student or parent may ask the school for a copy of the student’s personal data in the portal, and may ask the school to correct anything that is wrong. The school will reply within 40 days of receiving the request. Use the address in section 1.

A parent may also ask the school to delete recordings and practice records it no longer needs for the student’s learning. The school may keep them during the 365 days in section 7. After that, they are deleted.