Privacy Policy

Last Updated: 27-10-2025

This policy applies to the services provided by E-Lam Limited ("the Company", "we", "us").

1. What Data We Collect

To provide you with our "Daily Mission + Coach Feedback" English service, we will collect and process the following types of personal data:

• Account Data: Your real name, email address, and your WhatsApp or WeChat account number.
• Payment Data: Your payment transaction history and billing details. Sensitive credit card information is processed directly by our payment processor (Stripe) and is not stored by us.
• Service Operational Data:
  • All 1-on-1 communication records between you and your tutor, including text messages and images.
  • Voice Messages you submit to complete learning tasks.
  • Video Messages or Calls that may be used for synchronous coaching or feedback, subject to your consent.

2. How We Use Your Data

We use your personal data only for the following specific purposes:

• To Provide and Manage Services: To process your registration, manage your account, send daily missions, and allow tutors to provide personalized feedback and corrections.
• To Process Payments: To manage your monthly subscription, process billing, and prevent fraud.
• For Quality Assurance and Teacher Training: To ensure our teaching standards are met and to provide ongoing professional development for our tutors, your communication and service records may be reviewed by company management.
• For Marketing (With Your Consent): We will not use your learning outcomes (e.g., your work, comments, or progress) for marketing purposes without your prior written consent. If we wish to feature your success, we will contact you separately to obtain your explicit permission.
• To Communicate: To use your email or WhatsApp/WeChat to send you notifications about your account, service updates, or significant policy changes.

3. Who We Share Your Data With

We only share your personal data with the following third parties when strictly necessary:

• Freelance Tutors: We share your Account Data (name, contact) and all Service Operational Data with your assigned tutor so they can provide 1-on-1 teaching. These tutors are independent contractors who may be located anywhere in the world (i.e., outside of Hong Kong) and are contractually bound to keep your data confidential.
• Technology & Cloud Providers: We rely on the following third-party providers to operate our service:
  • Meta (WhatsApp) / Tencent (WeChat): For delivering teaching messages.
  • Stripe: For processing your payments.
  • Google (Google Drive): May be used for storing curriculum or operational backups.
  • GitHub: For hosting our website pages (including this policy).
• Legal Requirements: If required by Hong Kong law or a binding request from law enforcement.

4. Data Retention and Deletion

Retention Period: When you cancel your subscription or terminate your service, we will securely delete your personal data (including chat logs and learning outcomes) within 6 months from the termination date. We may retain anonymized data (data that can no longer identify you) indefinitely for internal statistics and service improvement.

Exceptions: We may retain necessary transaction or payment records beyond your service termination to comply with our legal, tax, or auditing obligations.

5. Your Rights Under PDPO

Under Hong Kong's Personal Data (Privacy) Ordinance (PDPO), you have the right to:

• Access Data: Request a copy of the personal data we hold about you.
• Correct Data: Request the correction of any inaccurate data.
• Delete Data: Request the deletion of your personal data (subject to our retention policy in Section 4).

How to Exercise Your Rights: To exercise any of these rights, you must send a written request via email to our Data Protection Contact. To protect your privacy, we will take reasonable steps to verify your identity before processing your request.

6. Contact Us

If you have any questions about this Privacy Policy, or if you wish to exercise your privacy rights, please contact our Data Protection team at:

contact.elamltd@gmail.com

7. Language

This Policy is prepared in both English and Chinese. In the event of any discrepancy or conflict between the English and Chinese versions, the English version shall prevail.