Terms of Service & Privacy Policy

(a) Account Information: Name, email address, phone number. Used for identity verification, account management, and necessary communications.

(b) Exam and Practice Data: Answer records, scores, practice history, time spent on each question. Used for performance evaluation, academic analysis, and personalised learning recommendations.

(c) Device and Browser Information: Browser type, OS version, screen resolution. Used solely for compatibility checks and pre-flight environment verification, not for tracking or advertising purposes.

(d) Monitoring Data (collected only during exams/practice sessions):

· Face detection snapshots: Used to verify candidate identity and independent exam-taking, temporarily stored in compressed JPEG format.

· Audio frequency analysis data: Only volume levels and frequency characteristics are recorded. No raw audio content is recorded or stored.

· Violation event logs: Record violation type, severity level, and timestamp. No raw audio or video data is included.

· Screen behaviour data: Records tab switches, window focus loss, screenshot attempts, etc. Actual screen content is never captured.

(e) Network Request Logs: IP addresses, request timestamps, API call records. Used for security protection, anomaly detection, and service quality assurance.

All data collected is strictly limited to the following purposes:

(a) Providing, maintaining, and improving Platform services;

(b) Identity verification and account security;

(c) Exam anti-cheating and fairness assurance;

(d) Academic performance analysis and learning report generation;

(e) Platform anomaly detection and technical troubleshooting;

(f) Compliance with applicable laws and regulations.

We solemnly commit: User personal information will never be sold, rented, or provided to any third party for profit. Monitoring data will never be used for any purpose other than ensuring exam fairness.

We follow the principle of data minimisation, retaining data only for the minimum period necessary to fulfil the purpose of collection:

(a) Account Information: Retained during the account's lifetime. Permanently deleted within 30 business days of account cancellation.

(b) Exam Scores and Answer Records: Retained during the account's lifetime for score enquiry and academic analysis. Deleted within 90 business days of account cancellation.

(c) Face Detection Snapshots: Temporarily stored in server memory only during the exam/practice session for real-time face detection. Automatically and permanently deleted within 24 hours of session completion. Under no circumstances will snapshots be retained for more than 7 days.

(d) Audio Analysis Data: The Platform does not record or store any raw audio content. Real-time frequency analysis is performed locally in the user's browser during the exam only. Analysis results (volume level values) are saved with violation event logs and contain no data that could be reconstructed into audio.

(e) Violation Event Logs: Retained for 180 days for violation tracing and dispute resolution. Automatically deleted after the retention period.

(f) Network Request Logs: Automatically deleted after 90 days.

(g) Cookies and Session Data: Session cookies expire when the browser is closed. Persistent session tokens are valid for 7 days, after which they automatically expire and are deleted from the server.

If legal requirements (such as judicial investigation needs) necessitate extending the retention period for specific data, we will minimise retention within the scope required by law and promptly delete the data once the obligation is discharged.

We make the following explicit commitments regarding the processing of sensitive privacy data:

(a) No-Storage Principle: For sensitive monitoring data such as camera snapshots and audio analysis, the Platform does not perform permanent storage as a matter of principle. All temporary data is automatically cleared within defined time windows.

(b) Minimal Collection: Only the minimum amount of data necessary for anti-cheating functionality is collected. For example, the camera is used only for face detection (counting faces), not facial recognition (identifying who); the microphone only analyses frequency characteristics, not conversational content.

(c) Local Processing Priority: Audio analysis is performed locally in the user's browser; raw audio data never leaves the user's device. Face detection is performed using a client-side TensorFlow.js model; snapshots are only briefly uploaded when recording a violation event.

(d) Irreversible Anonymisation: All data used for Platform statistical analysis undergoes irreversible anonymisation and cannot be linked to specific users.

(a) Functionality: Uses the front-facing camera on the user's device for real-time face detection to confirm: the candidate's identity as the registered user (presence detection only, no biometric identification); only the candidate is present in the exam area (multi-face detection).

(b) Technical Implementation: Uses the TensorFlow.js MediaPipe Face Detector model running locally in the user's browser, performing detection every 30 seconds.

(c) Data Processing: Compressed snapshots (JPEG, 50% quality) are generated only when anomalies are detected (no face or multiple faces) as temporary violation evidence. Normal detection results generate no snapshots.

(d) Privacy Protection: Snapshots are automatically deleted within 24 hours of exam completion. Snapshots are never used for facial recognition, identity matching, or any data training purposes.

(a) Functionality: Monitors the exam environment for sound anomalies to prevent candidates from obtaining answers through verbal communication.

(b) Technical Implementation: Uses the Web Audio API for real-time audio frequency analysis locally in the user's browser, focusing on the human voice frequency range (300Hz–3000Hz). Anomalies are only flagged when voice characteristics above the threshold are detected consistently over multiple consecutive readings.

(c) Data Processing: The Platform does not record, transmit, or store any raw audio data. Only analysis results (volume level values) are recorded as violation event metadata.

(d) Privacy Protection: All audio processing is performed locally on the user's device. Raw audio streams never leave the device, and it is technically impossible to reconstruct any form of audio from the recorded numerical values.

(a) Scope: Tab switch detection; browser window focus loss detection; fullscreen mode exit detection; screenshot/screen recording attempt interception; developer tools detection; copy/paste operation interception.

(b) Data Processing: Only behavioural event types and timestamps are recorded. Actual screen display content is never captured, and no form of screen recording is performed.

A transparent digital watermark containing the candidate's name and contact information is overlaid on exam and practice interfaces to deter and trace screenshot-based content leaking. The watermark does not affect the answering experience and is only identifiable in screenshots to trace the source.

(a) Formal Exam Mode: All monitoring measures are active. Violations exceeding the threshold (5 severe violations or 15 total violations) will trigger automatic exam termination and forced submission.

(b) Practice Mode: All monitoring measures remain active (maintaining anti-leak consistency). Violations are recorded only and do not trigger automatic termination or affect the practice session.

Users must explicitly confirm their consent to activate the above monitoring measures through the pre-flight check page before each exam or practice session. Without consent, users cannot enter the exam or practice session. This consent is voluntary, but refusal will result in the inability to use exam and practice features.

(a) Scope: Original questions, explanations, study materials, teaching methodologies, and related textual, graphical, and mathematical content independently designed and authored by 方添优学（上海）教育科技有限公司 (Frontier Academy Education Technology (Shanghai) Co., Ltd.) and its team.

(b) Rights: The copyright of the above content belongs to 方添优学（上海）教育科技有限公司（Frontier Academy Education Technology (Shanghai) Co., Ltd.） and is protected under the Copyright Law of the People's Republic of China (2020 Revision), the UK Copyright, Designs and Patents Act 1988 (CDPA), the U.S. Copyright Act (17 U.S.C. § 101 et seq.), and the Berne Convention for the Protection of Literary and Artistic Works.

(c) Restrictions: Without written authorisation, it is strictly prohibited to copy, screenshot, screen-record, excerpt, distribute, sell, sublicense, or otherwise use the Platform's original content in any form.

(a) Scope: Specific exam schemes, practice sets, classification systems, and mock exam structures formed through the Platform's selection, combination, arrangement, and categorisation of questions.

(b) Rights: Even if individual questions are not entirely original, the overall work formed through the Platform's creative selection and arrangement constitutes a Compiled Work protected under Article 15 of the Copyright Law, the UK CDPA, and the U.S. Copyright Act 17 U.S.C. § 103 (compilation copyright). Copyright belongs to 方添优学（上海）教育科技有限公司（Frontier Academy Education Technology (Shanghai) Co., Ltd.）

(c) Restrictions: Without authorisation, the Platform's exam structure, question arrangement methodology, or classification system may not be copied, imitated, or reproduced.

(a) Scope: Historical examination papers published by official examination bodies (such as UAT UK (for ESAT, TMUA, TARA) and OCR (for STEP), etc.) constitute publicly released educational resources.

(b) Rights Clarification: The Platform does not claim copyright over the question content of official past papers. Copyright of these papers belongs to the respective official examination bodies.

(c) User Rights: Users are free to view, reference, and share the question content of official past papers, subject to the following:

· The original copyright of official past papers belongs to the respective examination bodies, and users should comply with those bodies' terms of use;

· The Platform's explanations, annotations, classification tags, and arrangement structures applied to official past papers remain the Platform's original/compiled works and are protected by intellectual property rights;

· Using the Platform's technical means (such as bypassing anti-screenshot or watermark systems) to bulk-acquire past paper content for commercial purposes is prohibited.

(a) Ownership: The FrontierVue Online Examination and Practice Platform as a whole — including but not limited to its software source code, technical architecture, algorithms, database structures, user interface design, interaction logic, functional workflows, brand name, logo, and visual design system — is the intellectual property of 方添优学（上海）教育科技有限公司 (Frontier Academy Education Technology (Shanghai) Co., Ltd.). The Company holds copyright, distribution rights, information network dissemination rights, adaptation rights, and all other rights prescribed by law.

(b) The Platform is protected under Article 3 of the Copyright Law of the PRC as a computer software work, and is comprehensively protected under the Regulations on Computer Software Protection. It is also protected under the UK Copyright, Designs and Patents Act 1988 (CDPA) as a computer program and database, and under the U.S. Copyright Act (17 U.S.C. § 101 et seq.) and the Digital Millennium Copyright Act (DMCA, 17 U.S.C. § 1201) regarding digital works and technological protection measures.

(c) Prohibited Conduct: Without the Company's written authorisation, the following is strictly prohibited:

· Copying, imitating, or plagiarising the Platform's functional design, interface layout, interaction flow, or product logic;

· Reverse engineering, decompiling, disassembling, or otherwise attempting to obtain the Platform's source code;

· Developing competing products or services that are substantially similar in function to the Platform;

· Using crawlers, automated tools, or other technical means to bulk-extract Platform data, questions, or other content;

· Interfering with, disrupting, or obstructing the normal operation and service delivery of the Platform in any way, including but not limited to: launching distributed denial-of-service (DDoS) attacks, injecting malicious code, exploiting vulnerabilities for unauthorised access, tampering with Platform data, or distributing harmful content to other users;

· Using the Platform's name, logo, or other brand elements for any form of false advertising, misleading promotion, or implied association.

(d) Legal Consequences: The above conduct will be prosecuted under the Copyright Law, the Anti-Unfair Competition Law Articles 9 (trade secret infringement) and 12 (unfair competition through technical means), the Regulations on Computer Software Protection Article 24, the UK Computer Misuse Act 1990 and CDPA 1988, as well as the U.S. Computer Fraud and Abuse Act (CFAA, 18 U.S.C. § 1030), DMCA (17 U.S.C. § 1201), and Lanham Act (15 U.S.C. § 1125). In serious cases, the Company will simultaneously pursue criminal liability.

(a) Provide truthful, accurate, and complete personal registration information, and update it promptly when changes occur;

(b) Properly safeguard account credentials. Do not allow others to use your account or take exams in your name;

(c) Comply with examination rules and all Platform policies;

(d) Respect the intellectual property of the Platform and third parties;

(e) Do not use technical means to attack, interfere with, or disrupt the normal operation of the Platform.

【Category 1 — Warning & Restriction】

Conduct: Minor violations during exams (e.g., occasional window focus loss, brief tab switches).

Penalty: The system records the violation event and issues a warning. When the cumulative threshold is reached, formal exams will be automatically terminated.

【Category 2 — Score Cancellation & Account Suspension】

Conduct: Exam cheating (including but not limited to: using external materials, communicating answers with others, using automated answering tools); allowing others to use your account or taking exams on behalf of others.

Penalty: (a) Relevant exam scores are immediately cancelled and cannot be restored; (b) Account suspended for 30-180 days; (c) Violation is recorded in the account file, affecting future exam eligibility.

【Category 3 — Permanent Ban & Legal Action】

Conduct: Unauthorised sharing, distribution, or sale of the Platform's original questions or compiled works; using technical means to bulk-scrape, download, or copy Platform content; cracking, reverse-engineering, or circumventing the Platform's anti-cheating/anti-leak systems; using Platform content for commercial competitive activities; copying, imitating, or plagiarising the Platform's functional design, interface, or product logic to develop competing products; interfering with, disrupting, or obstructing the normal operation of the Platform in any way (including network attacks, malicious code injection, vulnerability exploitation, etc.).

Penalty: (a) Account permanently banned without possibility of restoration; (b) The Company reserves the right to pursue the infringer's civil and/or criminal liability under the following laws.

The Company reserves the right to initiate legal proceedings against seriously violating users (particularly for intellectual property infringement and commercial content leaking), based on but not limited to:

【Laws of the People's Republic of China】

· Copyright Law (2020 Revision), Articles 52-54: Infringers shall bear civil liability including cessation of infringement, elimination of effects, formal apology, and compensation for damages. Compensation shall be calculated based on actual losses or illegal gains; where these are difficult to determine, the court may award between RMB 500 and RMB 5,000,000.

· Anti-Unfair Competition Law (2019 Revision), Articles 9 & 17: Article 9 defines trade secrets and prohibited acts of infringement; Article 17 provides for compensation liability, with punitive damages of 1-5 times the rights holder's losses in serious cases.

· Criminal Law, Article 217: Reproducing and distributing works without the copyright holder's permission for profit — where illegal gains are substantial or other serious circumstances exist, punishable by up to 3 years imprisonment and/or fines; where illegal gains are especially substantial or other especially serious circumstances exist, punishable by 3 to 10 years imprisonment and fines.

· Personal Information Protection Law (PIPL), Article 69: Those who infringe on personal information rights causing damage shall bear tort liability including compensation.

· Civil Code, Article 1185: Where intellectual property rights are intentionally infringed under serious circumstances, the infringed party may claim punitive damages.

【United Kingdom Laws】

· Copyright, Designs and Patents Act 1988 (CDPA), Sections 96-100: Civil remedies for copyright infringement including injunctions, damages, account of profits, and delivery-up orders.

· CDPA Section 107: Commercial-scale unauthorised copying of copyrighted works constitutes a criminal offence, punishable by up to 10 years imprisonment and unlimited fines.

· Computer Misuse Act 1990, Sections 1-3: Unauthorised access to computer systems and unauthorised modification of computer contents, punishable by up to 10 years imprisonment.

· Fraud Act 2006: Obtaining exam results through fraudulent means may constitute fraud by false representation (Section 2), punishable by up to 10 years imprisonment.

【United States Laws】

· Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 1201-1205: Circumventing technological protection measures (such as anti-cheating systems, anti-screenshot mechanisms) constitutes a violation, punishable by fines up to $500,000 and up to 5 years imprisonment; repeat offenders face fines up to $1,000,000 and up to 10 years imprisonment.

· Copyright Act, 17 U.S.C. § 501-505: Copyright infringement may result in actual damages or statutory damages ($750 to $30,000 per work; up to $150,000 per work for willful infringement).

· Computer Fraud and Abuse Act (CFAA), 18 U.S.C. § 1030: Unauthorised access to computer systems or exceeding authorised access to obtain data, punishable by up to 10 years imprisonment and fines.

· Lanham Act, 15 U.S.C. § 1125(a): False designation of origin, trademark infringement, and unfair competition, with remedies including injunctive relief, damages, and disgorgement of profits.

· Economic Espionage Act, 18 U.S.C. § 1831-1839: Section 1832 — theft of trade secrets for commercial advantage, punishable by up to 10 years imprisonment for individuals and fines up to $5,000,000 for organisations; Section 1831 — economic espionage involving a foreign government, punishable by up to 15 years imprisonment and fines up to $5,000,000 for individuals.

【International Conventions】

· Berne Convention for the Protection of Literary and Artistic Works: The Platform's original content is protected by copyright in all Convention member states without the need for separate registration.

· Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS): Provides minimum standards for intellectual property protection, binding on all WTO member states.

For users whose violations cause losses to the Company, the Company reserves the right to claim compensation, determined in the following order of priority:

(a) Actual Loss Compensation: Calculated based on the Company's actual economic losses caused by the infringing conduct, including but not limited to: direct economic losses (e.g., costs of voiding and re-creating questions due to leaks); indirect economic losses (e.g., reputational damage, user attrition); reasonable expenses (e.g., investigation costs, legal fees, litigation costs).

(b) Disgorgement of Profits: If actual losses are difficult to determine, calculated based on the infringer's illegal gains.

(c) Statutory Damages: If none of the above can be determined, under China's Copyright Law Article 54, the court may award between RMB 500 and RMB 5,000,000; under U.S. Copyright Act 17 U.S.C. § 504(c), $750 to $150,000 per work (for willful infringement); or as determined by UK courts under applicable law.

(d) Punitive Damages: For intentional infringement under serious circumstances, the Company may claim 1-5 times punitive damages under Article 1185 of the Civil Code.

(a) Transmission Encryption: All data transmission between clients and servers uses TLS 1.3 / HTTPS encryption to prevent data interception or tampering during transmission.

(b) Storage Security: User passwords are stored after processing with one-way cryptographic hashing (bcrypt/argon2). Even in the event of a database breach, attackers cannot recover plaintext passwords. Session tokens are SHA-256 hashed before storage.

(c) Environment Isolation: Production databases are completely isolated from development/testing databases, using different servers, different access credentials, and different network configurations. Developers cannot directly access production user data.

(d) Access Control: Role-based access control (RBAC) ensures that only necessary personnel can access data within the necessary scope. All data access is logged for audit purposes.

(e) Session Security: Login sessions are valid for 7 days with single sign-out support. Abnormal login activity triggers security alerts.

(f) Input Validation & Injection Prevention: All user inputs undergo strict validation and sanitisation to prevent SQL injection, XSS cross-site scripting, and other OWASP Top 10 security vulnerabilities.

(a) Employee Training: All employees with access to user data must undergo data protection training and sign confidentiality agreements.

(b) Security Audits: Regular security assessments and code reviews are conducted to promptly identify and remediate potential vulnerabilities.

(c) Incident Response: A data security incident response mechanism is in place. In the event of a data breach, affected users and relevant regulatory authorities will be notified within 72 hours (in compliance with UK GDPR Article 33 and PIPL Article 57).

(a) We commit to making all commercially reasonable efforts to protect the security of users' personal information and privacy data.

(b) If a user data breach occurs due to technical deficiencies of the Platform, the Company will bear corresponding liability under applicable law and take all necessary measures to mitigate the impact on affected users.

(c) We will continuously monitor developments in information security and promptly upgrade our security measures.

(d) Users also bear responsibility for protecting their own account security, including using strong passwords and not saving login status on public devices. The Company is not liable for account compromise caused by the user's own negligence.

You have the right to know how we collect and use your personal information, and to access a copy of the personal data we hold about you.

If you find that the personal information we hold is inaccurate or incomplete, you have the right to request correction or supplementation.

(a) You have the right to request deletion of your account and all associated data at any time.

(b) Deletion requests will be processed within 30 business days. We will delete: account information, exam scores, answer records, practice history, all monitoring data, and violation records.

(c) The following data may be retained after deletion: irreversibly anonymised statistical data (e.g., "average score for a particular exam"), as this data can no longer be linked to any specific user; records that must be retained by law (e.g., for ongoing legal disputes or tax audits).

You have the right to obtain your personal data in a structured, machine-readable format, including exam scores and answer records. To exercise this right, please contact our data protection team.

For data processed on the basis of consent (such as marketing communication subscriptions), you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

If you believe our data processing practices infringe on your rights, you have the right to file a complaint with the relevant data protection supervisory authority:

· China users: Cyberspace Administration of China (CAC), local market supervision authorities, or the Consumer Rights Protection Committee (12315 hotline)

· UK users: Information Commissioner's Office (ICO)

· US users: Federal Trade Commission (FTC) or the Attorney General's office in your state of residence

· Users in other regions: The data protection supervisory authority in your jurisdiction

(a) For users located within the People's Republic of China, this Agreement is governed by and construed in accordance with the laws of the PRC (excluding conflict of law provisions).

(b) For users located in the United Kingdom, this Agreement is governed by and construed in accordance with the laws of England and Wales.

(c) For users located in the United States, this Agreement is governed by and construed in accordance with applicable U.S. federal law and the laws of the user's state of residence.

(d) For users located in other regions, this Agreement is governed by and construed in accordance with the laws of England and Wales.

(e) Intellectual property protection provisions are subject to the laws of both the user's location and the place of content creation, with the law providing broader protection prevailing.

(a) Negotiation: Any dispute arising from this Agreement shall first be resolved through amicable negotiation between the parties. The negotiation period shall be 30 days from the date the dispute arises.

(b) Mediation/Arbitration: If negotiation fails, either party may refer the dispute to the following institutions for mediation or arbitration:

· China users — Shanghai Arbitration Commission, in accordance with its arbitration rules then in effect. The seat of arbitration shall be Shanghai. The arbitral award shall be final and binding on both parties.

· UK users — Centre for Effective Dispute Resolution (CEDR) for mediation; if mediation fails, the London Court of International Arbitration (LCIA) in accordance with its arbitration rules.

· US users — American Arbitration Association (AAA) in accordance with its Consumer Arbitration Rules. Arbitration shall be conducted on an individual basis, and both parties agree to waive the right to class action or class arbitration.

· Users in other regions — ICC International Court of Arbitration in accordance with its arbitration rules.

(c) Litigation: Where arbitration is not applicable or otherwise required by law: China users — disputes shall be submitted to the Jing'an District People's Court of Shanghai (the court with jurisdiction over the Company's registered address); UK users — disputes shall be submitted to the courts of England and Wales; US users — disputes shall be submitted to the federal or state courts in the user's state of residence; users in other regions — disputes shall be submitted to the courts of England and Wales.

(d) Emergency Relief for IP Infringement: For intellectual property infringement, the Company may directly apply to any court of competent jurisdiction for injunctive relief or interim protective measures without first going through negotiation, mediation, or arbitration procedures. This right is not limited by the dispute resolution provisions above.

(e) Small Claims Exception: Either party may bring a dispute that falls within the jurisdictional limits of a small claims court before the competent small claims tribunal without first going through arbitration.