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Privacy Policy

Last updated: May 7, 2025

Company: Apparent Group Limited(“we,” “us,” “our”), a company incorporated in Hong Kong, operator of PolyRead(the “Service”).

This Privacy Policy explains what personal information we collect, how we use it, who we share it with, and the rights you have over your information. It applies to our website, applications, and any other services that link to this Privacy Policy.

If you have questions, contact us at hello@apparentgroup.co.

1. Information We Collect

1.1 Information You Provide Directly

• Account information — name, email address, password, country, and similar details you submit when you create an account or contact us.
• Quiz and onboarding responses — answers you provide during quizzes, assessments, or onboarding flows. Some answers may relate to your health, lifestyle, or wellness goals.
• Subscription and payment information — billing name, billing address, and the last four digits of your card. Full payment card details are collected and processed directly by our payment processors (e.g. PayPal, Whop) and are not stored on our servers.
• Customer support communications — emails, chat messages, and other communications you send us.

1.2 Information Collected Automatically

• Device and usage data — device type, operating system, browser type, IP address, language settings, referring URLs, pages and screens viewed, actions taken, and timestamps.
• Cookies and similar technologies — see Section 6.
• Approximate location — derived from your IP address.

1.3 Information from Third Parties

• Authentication providers — if you sign in using Google, Apple, or another third-party login, we receive basic profile information (such as name and email) from that provider, in accordance with your settings.
• Advertising and analytics partners — aggregated or pseudonymized data about how you reached the Service.

2. How We Use Your Information

We use your information to:

• Provide, operate, and maintain the Service
• Personalize content, recommendations, and quiz results
• Process subscriptions, payments, and refunds
• Communicate with you about your account, transactions, updates, and support requests
• Send marketing emails (where permitted — you can opt out anytime)
• Measure and improve the performance of the Service and our marketing
• Detect, prevent, and respond to fraud, abuse, security incidents, and legal violations
• Comply with legal obligations and enforce our Terms and Conditions

Lawful Bases (EU / UK Users)

Where the EU or UK General Data Protection Regulation applies, we rely on the following lawful bases:

• Performance of a contract — to deliver the Service you signed up for
• Legitimate interests — to operate, secure, and improve the Service, and to communicate with you about it
• Consent — for non-essential cookies, optional marketing, and any processing of sensitive data; you can withdraw consent at any time
• Legal obligation — to comply with applicable law

3. Sharing Your Information

We do not sell your personal information for money. We share information only as described below.

3.1 Service Providers

We share information with vendors who help us run the Service, including:

• Payment processing — PayPal, Whop and other payment service providers
• Hosting and infrastructure — cloud hosting, content delivery, and database providers
• Analytics — providers that help us understand product usage
• Marketing and advertising — providers that help us reach and communicate with users (e.g., Meta, Google, email service providers)
• Customer support — helpdesk and communications platforms

These providers are contractually required to safeguard your information and use it only for the purposes we authorize.

3.2 Legal and Safety

We may disclose information when we believe in good faith that disclosure is necessary to: comply with law, regulation, legal process, or government request; protect the rights, property, or safety of users or the public; investigate fraud, abuse, or security issues; or enforce our Terms.

3.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your information.

3.4 With Your Consent

We may share information with other parties when you direct us to or otherwise consent.

4. International Data Transfers

We are based in Hong Kong and our service providers are located in various countries. By using the Service, you understand that your information may be transferred to, stored in, and processed in countries outside your country of residence, including jurisdictions that may have different data protection laws.

Where we transfer personal information from the EU, UK, or other regulated jurisdictions, we rely on appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or your consent, as required by applicable law.

5. Data Retention

We retain personal information for as long as needed to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we delete or anonymize it.

Specific retention periods include (illustrative, may vary):

• Account data — for the life of your account, plus a reasonable period after deletion to handle disputes and legal claims
• Billing records — as required by tax and accounting law (typically 7 years)
• Marketing data — until you unsubscribe or we determine it is no longer relevant

6. Cookies and Tracking Technologies

We and our partners use cookies, pixels, SDKs, local storage, and similar technologies to operate the Service, remember your preferences, measure performance, and deliver advertising. Categories include:

• Strictly necessary — required for the Service to function
• Analytics — help us understand how the Service is used
• Advertising — measure ad performance and show you relevant ads on third-party platforms

You can manage cookies through your browser, your device’s privacy settings, or any cookie banner we provide. Disabling certain cookies may affect functionality.

7. Your Rights

Depending on where you live, you may have some or all of the following rights:

• Access — request a copy of the personal information we hold about you
• Correction — ask us to correct inaccurate or incomplete information
• Deletion — ask us to delete your information
• Portability — receive your information in a portable format
• Restriction / objection — restrict or object to certain processing
• Withdraw consent — where we rely on consent
• Opt out of marketing — at any time, via the unsubscribe link in our emails or by contacting us
• Lodge a complaint with your local data protection authority

EU / UK Users

You have the rights described above under the GDPR / UK GDPR. You can lodge a complaint with your national supervisory authority (in the UK, the Information Commissioner’s Office; in the EU, your national DPA).

California Residents (CCPA / CPRA)

You have the right to know what personal information we collect, use, disclose, and “share” (as defined under the CCPA); to request deletion or correction; to opt out of “sale” or “sharing” of personal information for cross-context behavioral advertising; and to limit the use of sensitive personal information. We do not sell personal information for money. To exercise your rights, email hello@apparentgroup.co.

Hong Kong Users

You have rights under the Personal Data (Privacy) Ordinance (PDPO) to access and correct personal data we hold about you. Submit requests to hello@apparentgroup.co.

We will respond to verifiable requests within the timeframe required by applicable law. We may need to verify your identity before fulfilling your request.

8. Sensitive and Health-Related Information

If the Service collects information about your health, lifestyle, or wellness (for example, through a quiz), we treat that information with additional care. We use it only to provide and personalize the Service, and we do not share it with advertising partners except in aggregated or de-identified form.

If you are in the EU or UK, we rely on your explicit consent before processing any data classified as a special category under GDPR.

9. Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, access controls, and monitoring. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If you believe your account has been compromised, contact us at hello@apparentgroup.co immediately.

10. Children’s Privacy

The Service is not directed to children under 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected information from a child under 16 without parental consent, we will take steps to delete it. If you believe a child has provided us with personal information, contact hello@apparentgroup.co.

11. Third-Party Services

The Service may contain links to or integrate with third-party services (e.g., payment processors, social platforms, app stores). This Privacy Policy does not apply to those third parties. Please review their privacy policies before using them.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top reflects the most recent version. If we make material changes, we will notify you by email or in-app notice. Continued use of the Service after changes take effect constitutes your acceptance.

13. Contact Us

For questions about this Privacy Policy or to exercise your rights, contact:

Apparent Group Limited

Flat/Rm 05-06, 18/F, Hollywood Plaza,

610 Nathan Road, Kowloon, Hong Kong

Email: hello@apparentgroup.co