Privacy Policy

For the purposes of applicable Hong Kong personal data law, the data user responsible for personal data collected through the Services is:

We may collect the following categories of personal data:

1. Account Information: name, email address, username, password or authentication credentials, account preferences, Access Pass status, and user ID.
2. Payment and Access Pass Information: pass type, billing status, payment confirmation, transaction records, Access Pass history, and limited payment details provided by payment processors. We generally do not store full payment card numbers.
3. Learning and Test Information: TOEFL practice responses, essays, speaking responses, audio recordings, reading answers, listening answers, test selections, section preferences, task-type preferences, scores, AI-generated feedback, comments, study history, progress records, flashcard activity, daily practice results, and learning hub interactions.
4. Communications: messages, support requests, survey responses, feedback, complaints, and other communications you send to us.
5. Technical and Usage Data: IP address, device identifiers, browser type, operating system, log data, pages viewed, features used, access times, referring pages, session data, diagnostic data, and interaction data.
6. Cookies and Similar Technologies: cookie identifiers, analytics identifiers, preference cookies, and similar tracking technologies used to operate, secure, improve, and analyze the Services.
7. Marketing Preferences: newsletter preferences, communication preferences, consent records, and opt-out records.

We may collect personal data:

1. directly from you when you create an account, use the Services, complete practice tasks, submit answers, purchase an Access Pass, or contact us;
2. automatically through cookies, analytics tools, logs, and similar technologies;
3. from payment processors and billing providers;
4. from authentication providers, where you choose to sign in using third-party login services; and
5. from service providers that help us operate, secure, analyze, and improve the Services.

We may use personal data for the following purposes:

1. creating, maintaining, and administering your account;
2. providing, operating, personalizing, and improving the Services;
3. generating TOEFL mock tests, section-based tests, task-type-based tests, grades, comments, feedback, and learning recommendations;
4. processing Access Pass purchases, payments, refunds, invoices, and billing support;
5. providing daily practice, flashcards, learning hub content, and progress tracking;
6. responding to inquiries, support requests, complaints, and feedback;
7. monitoring usage, performance, quality, security, and reliability of the Services;
8. detecting, preventing, and addressing fraud, abuse, technical issues, security incidents, and unauthorized access;
9. conducting analytics, research, testing, model evaluation, and service improvement;
10. enforcing our Terms of Service and other policies;
11. complying with legal, regulatory, tax, accounting, and compliance obligations;
12. communicating with you about service updates, security notices, administrative matters, and account-related matters; and
13. sending marketing communications where permitted by law and with any required consent.

When you submit answers, essays, audio, text, prompts, or other learning materials, we may process that content using AI systems and related technology providers to generate mock tests, grades, comments, feedback, explanations, study recommendations, and performance insights.

Your submissions may be processed automatically. AI-generated outputs may be inaccurate or incomplete and are provided for educational purposes only.

We may use de-identified, aggregated, or anonymized data to improve our Services, develop educational features, analyze performance trends, and enhance system quality, provided such data does not identify you.

We may use your name, email address, account information, Access Pass status, and service usage preferences to send you promotional communications about MockGarden features, offers, content, and updates, but only where permitted by applicable law and, where required, with your consent.

Under Hong Kong privacy guidance, organizations generally must notify individuals and obtain consent before using personal data in direct marketing.

You may opt out of marketing communications at any time by using the unsubscribe link in our emails or contacting us at contact@mockgarden.com. Service-related, transactional, security, and account communications are not marketing communications and may continue even if you opt out of marketing.

We may disclose personal data to:

1. cloud hosting, infrastructure, database, and storage providers;
2. AI technology providers and model-processing vendors;
3. payment processors and billing providers;
4. analytics, diagnostics, and performance-monitoring providers;
5. customer support, communications, and email service providers;
6. security, fraud-prevention, and abuse-detection providers;
7. professional advisers, including lawyers, auditors, accountants, insurers, and consultants;
8. government authorities, regulators, courts, law enforcement agencies, or other third parties where required or permitted by law;
9. potential or actual buyers, investors, successors, or assignees in connection with a merger, acquisition, financing, restructuring, sale of assets, or change of control; and
10. other parties with your consent or at your direction.

We require service providers to handle personal data only for authorized purposes and to apply appropriate safeguards.

Your personal data may be transferred to, stored in, or processed in jurisdictions outside Hong Kong, including jurisdictions where our service providers, cloud infrastructure, AI providers, payment processors, or support providers operate.

Where personal data is transferred outside Hong Kong, we will take steps designed to ensure that the data is protected in accordance with this Privacy Policy and applicable legal requirements.

We take reasonable and appropriate technical and organizational measures to protect personal data against unauthorized or accidental access, processing, erasure, loss, use, disclosure, or alteration.

Such measures may include encryption, access controls, authentication safeguards, logging, monitoring, secure hosting, internal policies, and vendor controls.

No method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including providing the Services, maintaining accounts, complying with legal obligations, resolving disputes, enforcing agreements, preventing fraud, maintaining security, and keeping business records.

We may retain certain account, billing, transaction, support, security, and legal records for longer periods where required or permitted by law.

When personal data is no longer required, we will take reasonable steps to delete, anonymize, or securely dispose of it.

We take reasonable steps to ensure that personal data held by us is accurate, complete, and up to date, having regard to the purposes for which it is used.

You are responsible for ensuring that the information you provide to us is accurate and current. You may update certain account information through your account settings or by contacting us.

Subject to applicable law, you may request access to and correction of your personal data held by us.

To make a data access or correction request, contact us at contact@mockgarden.com. We may require you to verify your identity before processing your request.

We may charge a reasonable fee for processing data access requests where permitted by law.

You may request deletion of your account by contacting us at contact@mockgarden.com.

Following an account deletion request, we may delete or de-identify personal data associated with your account, subject to our right or obligation to retain certain information for legal, regulatory, billing, security, fraud-prevention, dispute-resolution, or legitimate business purposes.

We may use cookies and similar technologies to:

1. operate and secure the Services;
2. remember preferences and settings;
3. authenticate users;
4. analyze traffic and usage;
5. improve performance and functionality; and
6. support marketing and measurement, where permitted.

You may control cookies through your browser settings. Blocking certain cookies may affect the functionality of the Services.

The Services are intended for TOEFL preparation and may be used by students. However, users under the age of majority should use the Services only with parental or guardian consent and supervision.

We do not knowingly collect personal data from children in circumstances where parental or guardian consent is legally required and has not been obtained. If you believe that a child has provided personal data without appropriate consent, please contact us.

The Services may contain links to third-party websites, platforms, tools, or services. We are not responsible for the privacy practices, content, security, or policies of third parties.

You should review the privacy policies of any third-party services you access.

We may use, preserve, or disclose personal data where we reasonably believe it is necessary to:

1. comply with applicable law, regulation, court order, legal process, or governmental request;
2. enforce our Terms of Service or other agreements;
3. protect the rights, property, safety, or security of Athena AI, users, employees, service providers, or the public;
4. detect, prevent, or address fraud, security incidents, abuse, or technical issues; or
5. defend or pursue legal claims.

We may update this Privacy Policy from time to time. The updated version will be posted on our website or made available through the Services with a revised "Last Updated" date.

Where required by applicable law or where changes are material, we may provide additional notice. Your continued use of the Services after the effective date of the updated Privacy Policy constitutes acknowledgment of the updated policy.

For questions, requests, complaints, data access requests, data correction requests, account deletion requests, or privacy matters, please contact: