Dimension Space — Data Storage and Cross-Border Transfer Statement

Version: v1.0
Effective Date: 8 May 2026
Companion Document: This statement is a standalone expansion of Section 5 of the Privacy Policy. The two documents are interrelated and not in conflict.
Legally Binding Version: The Traditional Chinese version of this statement is the legally binding version. This English version is for convenience only; in case of discrepancy, the Traditional Chinese version shall prevail.

Solemn Commitment

Dimension Space solemnly commits: all user personal data — including accounts, learning progress, AI conversations, uploaded photos, mistake records, timetables, and Diamond records — is stored only on servers located in the Hong Kong Special Administrative Region, and will absolutely not be transferred outside Hong Kong, except for the limited third-party exceptions listed in Section 2.

1. Data Storage Inventory

1.1 Primary Storage (all in Hong Kong)

1.2 Device Local Storage

JWT login tokens (encrypted in iOS Keychain), user preferences, and local caches of backend data. These are not the source of truth; the authoritative version always resides on our Hong Kong backend.

2. Cross-Border Transfer Exceptions

We acknowledge the following data transfers outside Hong Kong, each with clear commercial necessity and strictly limited data types.

2.1 Apple Inc. (USA)

3. Disclosure Principles for Government or Law Enforcement Requests

3.1 Hong Kong Legal Requests We Comply With

We will respond to valid law enforcement / legal requests under Hong Kong SAR law by disclosing only the minimum necessary data, including:

• Valid search warrants, subpoenas, or court orders issued by Hong Kong courts
• Formal written requests from the Hong Kong Police Force (including all its branches and the National Security Department) under the Police Force Ordinance (Cap. 232), relevant criminal procedure ordinances, or the Implementation Rules of Article 43 of the Hong Kong National Security Law
• Requests within the statutory powers of authorities such as Customs and Excise, the ICAC, the Social Welfare Department, and the PCPD
• Imminent serious threats to personal safety

Where legally permitted, we will notify affected users in advance and only provide the minimum necessary data.

3.2 Requests from Authorities Outside Hong Kong

Because our data and company are both located in Hong Kong, direct requests from authorities outside Hong Kong are generally outside our scope of response (lacking jurisdictional basis). If such foreign-authority requests are enforced through a Hong Kong court order, we will comply with that Hong Kong court order (not the original foreign request).

We will not respond to requests from commercial competitors, advertisers, or data brokers.

4. Change Notification

If, in the future, we must adjust data storage or add cross-border services: for material changes (adding a third-party cross-border service / relocating the primary database), we will notify all existing users via in-app pop-up and email 60 days before the effective date. Users have 60 days to delete their account (with proportional refund of any paid-but-unconsumed fees).

5. Independent User Verification

• iOS App Privacy Report (Settings → Privacy → App Privacy Report): you can see all endpoints this app accesses
• PCPD Complaint: www.pcpd.org.hk / 2827 2827

If you find any exception, please email support@starcloudedu.com.

6. Contact Us

Appendix — Trilingual Versions

This statement is provided in Traditional Chinese (legally binding version), Simplified Chinese, and this English version (for convenience only). In case of discrepancy, the Traditional Chinese version shall prevail.

— The Dimension Space Team