Data Privacy Disclosure & Parental Consent

Students participating in Genesis Learning classes may interact with, or observe the instructor use, some or all of the following AI platforms, depending on the programme and lesson objectives. Our approach is deliberately model-agnostic — knowing which tool to reach for, and why, is itself a core AI fluency skill.

Students may interact with these tools via the instructor's devices, school-issued devices, or their own devices, depending on programme format. In all cases, use occurs under direct instructor supervision during class time only. New platforms may be introduced as the AI landscape evolves; parents will be informed of any material additions.

Most AI platforms impose minimum age requirements for independent account creation and use. The relevant thresholds are summarised below.

When a student — or the instructor on a student's behalf — interacts with an AI platform, the following categories of data may be collected and retained by the platform provider:

• Conversation content: all prompts entered and responses generated during a session
• Device and technical data: IP address, browser type, device identifiers, and session duration
• Usage patterns: frequency and type of queries, features accessed
• Account metadata: if an account is used, the account holder's profile information

Genesis Learning's strict in-class data safety protocol (see Section 7) is designed to ensure that no personally identifiable information about students is entered into any AI platform during our programmes. However, parents should be aware that platform data retention policies vary by provider:

• OpenAI (ChatGPT) retains conversation data and may use it to improve its models unless users opt out via account settings
• Anthropic (Claude) retains conversations for a period defined in its privacy policy; API-based interactions offer stronger data controls
• Google (Gemini, NotebookLM) data practices are governed by Google's Privacy Policy and, for Workspace accounts, the applicable data processing agreement
• DeepSeek, Qwen, and Doubao are developed by entities subject to the laws of the People's Republic of China, including data security regulations that may permit government access under certain conditions. These platforms are used selectively for illustrative or comparative tasks only; students are instructed never to enter personal information into these tools

4.1   Hong Kong — Personal Data (Privacy) Ordinance (PDPO)

The PDPO governs the collection, use, and handling of personal data in Hong Kong. Genesis Learning complies with the PDPO's six Data Protection Principles, including:

• Collecting only the minimum personal data necessary for programme administration
• Using personal data only for the purposes for which it was collected
• Retaining data no longer than is necessary
• Taking reasonable security measures to protect personal data from unauthorised access or disclosure

Students' personal data collected by Genesis Learning is used solely for programme management and communication purposes and is never shared with third parties for commercial purposes.

4.2   International frameworks — GDPR & COPPA

Depending on a student's nationality or residency, additional frameworks may apply:

• EU General Data Protection Regulation (GDPR): Applies to students who are EU nationals or residents. Parental consent is required for processing personal data of children under 16. Genesis Learning does not knowingly process EU student data beyond administrative necessities.
• US Children's Online Privacy Protection Act (COPPA): Applies to US-based platforms collecting data from children under 13. Genesis ensures that students under 13 do not independently create accounts on COPPA-governed platforms.
• China's Personal Information Protection Law (PIPL) and Cybersecurity Law: Governs platforms operated by PRC entities (DeepSeek, Qwen, Doubao). These laws impose obligations on platform operators and may permit regulatory access to data under certain conditions.

Genesis Learning collects and processes the following personal data from enrolled students and their parents or guardians:

• Student full name, date of birth, and year group / academic level
• Parent or guardian name, contact number, and email address
• Programme enrolment details and attendance records
• Academic feedback and progress notes generated by instructors

This data is stored securely with access restricted to Genesis Learning staff, never sold or disclosed to third parties for commercial purposes, and retained for no longer than 24 months following the conclusion of a programme. It is available for parental review upon written request to info@genesislearning.ai.

Genesis Learning does not record, store, or retain transcripts of student interactions with AI platforms unless explicitly required for a specific programme activity and with prior written parental consent.

• No photographs or recordings that identify individual students will be used in any public-facing marketing material without separate, explicit written consent from the parent or guardian
• Screen recordings of AI interactions used for training or demonstration will be anonymised or conducted using the instructor's own prompts, not student content
• Parents may withdraw consent for any such use at any time by contacting info@genesislearning.ai

The following rules apply to all students during Genesis Learning programmes and are enforced by the instructor on every platform, on every device, in every class.

• Maintaining and securing all platform accounts used for student instruction
• Ensuring that no student independently creates accounts on platforms where they do not meet the minimum age requirement
• Supervising all AI interactions during class and intervening if a student inadvertently enters personal information
• Using only the minimum data necessary when constructing instructional prompts
• Reporting any data incidents or platform anomalies to Genesis Learning management promptly

• Genesis Learning cannot control the data practices, privacy policies, or security measures of third-party AI platform providers. Each platform's own terms of service and privacy policy govern its data handling.
• AI platforms may update their data practices or terms of service at any time. Genesis Learning will monitor material changes and communicate these to parents where they affect how platforms are used in our programmes.
• Students who access AI platforms independently, outside of Genesis Learning classes, do so at the discretion of their parents or guardians and are not covered by this disclosure.

By enrolling your child in a Genesis Learning programme, you as the parent or guardian confirm that you have read and understood this Data Privacy Disclosure in full, and that you consent to the following:

• Your child participating in supervised, instructor-guided AI platform activities as described in this document
• Genesis Learning using instructor-held accounts to facilitate access to platforms where your child does not meet the independent account age threshold
• Genesis Learning retaining the personal data described in Section 5 for programme administration purposes
• You have communicated the student data safety rules in Section 7 to your child

If you have any questions about this disclosure, wish to exercise your data rights under the PDPO, or wish to withdraw consent at any time, please reach out to us directly.