Privacy Policy

Apparent Group Limited ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, Brightly (the "App").

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the App.

1. Important Information and Who We Are

1.1 Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Apparent Group Limited collects and processes your personal data through your use of the App, including any data you may provide when you create an account, subscribe to our services, or interact with our content.

1.2 Controller

Apparent Group Limited is the controller and responsible for your personal data.

1.3 Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on February 12, 2026. We may update this policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: Includes first name, last name, username, or similar identifier.
• Contact Data: Includes email address.
• Profile Data: Includes your username, password (hashed), your interests, learning goals, learning style preferences, feedback, and survey responses.
• Usage & Progress Data: Includes details of your use of the App, such as lessons completed, quiz scores, accuracy rates, time spent on lessons, streaks, achievements, and topic mastery levels.
• Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this App.
• Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us. Note: We do not store full credit card details; financial transactions are processed by third-party providers (e.g., Apple App Store, Google Play Store).
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.

2.1 Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and Profile Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you create an account, subscribe to our service, complete the onboarding quiz, request marketing, or give us feedback.
• Automated technologies or interactions. As you interact with our App, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, such as analytics providers (e.g., Google Analytics, Firebase) and payment services (e.g., Apple, Google).

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., providing access to lessons, tracking your progress).
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., to improve our App, to keep our App secure).
• Legal Obligation: Where we need to comply with a legal obligation.
• Consent: Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you.

4.1 Purposes for Which We Will Use Your Personal Data

• To register you as a new user: Identity, Contact, Profile Data.
• To provide the App content and features: This includes delivering personalized lessons, quizzes, and tracking your learning streaks and achievements.
• To manage our relationship with you: This includes notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey.
• To administer and protect our business and this App: This includes troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
• To use data analytics to improve our App: Products/services, marketing, customer relationships, and experiences.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in Section 4 above.

• Service providers acting as processors who provide IT and system administration services (e.g., cloud hosting providers like Google Firebase).
• Professional advisers including lawyers, bankers, auditors, and insurers.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We are based in Hong Kong. However, our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

9. Your Legal Rights (GDPR)

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

9.1 No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

9.2 What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

9.3 Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Third-Party Links

The App may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy policy of every website you visit.