Compliance & Risk Control Policy
Last Updated: January 13, 2026
1. Introduction
Growth Education Limited ("we," "our," or "the Company") is committed to operating a legal, compliant, and safe online education platform. This Compliance & Risk Control Policy outlines our internal mechanisms to ensure all content, products, and services offered on our platform comply with applicable laws and regulations in Hong Kong and internationally.
This policy demonstrates our commitment to payment providers, regulatory authorities, and users that we maintain strict standards for content quality, legal compliance, and risk management.
Business Model: Growth Education operates as a curated educational content platform. All educational materials (question banks, e-books, and study resources) are created, vetted, and published by our internal team. We do not provide a marketplace for third-party content creators or user-generated content.
2. Prohibited & Restricted Items List
2.1 Absolutely Prohibited Content
The following content is strictly prohibited on our platform:
Illegal Content
- Content that violates Hong Kong laws or international laws
- Pirated or copyright-infringing materials
- Content promoting illegal activities (drugs, weapons, human trafficking)
- Content related to terrorism, extremism, or organized crime
Harmful Content
- Pornographic, obscene, or sexually explicit content
- Content promoting violence, self-harm, or suicide
- Hate speech, discrimination based on race, religion, gender, or other protected characteristics
- Bullying, harassment, or threatening content
Fraudulent Content
- Misleading or false educational credentials
- Fake diplomas, certificates, or academic qualifications
- Scams, phishing, or fraudulent schemes
- Unauthorized use of trademarks or impersonation
2.2 Restricted Content (Requires Review)
The following content requires special review and approval:
- Medical or health advice (must include disclaimers and professional credentials)
- Financial investment advice (must include risk warnings)
- Content discussing sensitive political or social topics (must be educational and balanced)
- Content featuring minors (requires parental consent and child protection measures)
2.3 Educational Content Standards
All educational content must meet the following standards:
- Accuracy: Content must be factually correct and up-to-date
- Academic Integrity: No plagiarism or unauthorized copying
- Proper Attribution: All sources must be properly cited
- Age-Appropriate: Content must be suitable for the target age group
- Cultural Sensitivity: Content must respect diverse cultures and perspectives
3. Content Moderation System
3.1 Internal Content Development Process
All educational content is developed and reviewed internally before publication:
Development & Review Process
- Content Creation: Educational materials are developed by our qualified team of subject matter experts and educators
- Accuracy Verification: Academic review by senior educators to ensure factual correctness and curriculum alignment
- Compliance Check: Legal and compliance team reviews content for adherence to educational standards and regulations
- Quality Assurance: Multi-stage testing and proofreading for errors, clarity, and appropriateness
- Final Approval: Content is published only after passing all review stages and receiving management approval
3.2 Post-Publishing Monitoring
We continuously monitor published content through:
- Regular Content Updates: Periodic reviews to ensure materials remain current and accurate with latest curriculum changes
- User Feedback System: Users can report errors or suggest improvements through our platform
- Quality Audits: Quarterly reviews of all published content for accuracy and compliance updates
- Curriculum Alignment: Annual verification that content aligns with Hong Kong Education Bureau standards
3.3 Issue Response Timeline
| Issue Type | Response Time | Action |
|---|---|---|
| Critical Errors | Within 4 hours | Immediate correction and user notification |
| Content Inaccuracies | Within 24 hours | Review, correct, and update affected materials |
| User Feedback | Within 48 hours | Investigate and implement improvements |
| Curriculum Updates | Within 30 days | Update materials to reflect new requirements |
4. Risk Control Mechanisms
4.1 Payment Fraud Prevention
- Real-time transaction monitoring for suspicious activity
- Multi-factor authentication for high-value transactions
- Collaboration with certified payment service providers for fraud detection
- Chargeback monitoring and dispute resolution procedures
- Regular financial audits and reconciliation
4.2 User Identity Verification
- Email verification required for all user accounts
- Secure password requirements with encryption
- Session management and account security monitoring
- Optional profile information for personalized learning experience
4.3 Data Protection & Privacy
We implement comprehensive data protection measures:
- Compliance with Hong Kong Personal Data (Privacy) Ordinance (PDPO)
- SSL/TLS encryption for all data transmission
- Regular security audits and penetration testing
- Secure storage with access controls and audit logs
- Data breach response plan with notification procedures
- Minimal data collection principle - we only collect necessary information for service delivery
4.4 Age Verification & Child Protection
- Parental consent required for users under 18
- Age-appropriate content designed for target student demographics
- No social features or direct messaging between users
- Reporting mechanisms for safety concerns
- Compliance with child protection laws and regulations
5. Compliance Evidence & Documentation
5.1 Compliance Documentation
We maintain comprehensive compliance documentation to demonstrate our commitment to legal and regulatory requirements. Documentation is available for review by authorized parties including payment service providers and regulatory authorities.
Documentation Categories:
- Corporate registration and business licenses
- Internal policies and procedures
- Security and data protection assessments
- Third-party compliance certifications
- Audit reports and compliance records
Detailed documentation is provided upon request to authorized entities in accordance with applicable laws and confidentiality agreements.
5.2 Regulatory Compliance
We comply with:
- Hong Kong Laws: Personal Data (Privacy) Ordinance, Copyright Ordinance, Trade Descriptions Ordinance
- Payment Regulations: Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations
- Education Standards: Hong Kong Education Bureau guidelines for supplementary education
- Consumer Protection: Consumer Goods Safety Ordinance, Fair Trading Ordinance
5.3 Audit & Reporting
- Monthly Reports: Content moderation statistics and policy violations
- Quarterly Reviews: Compliance status and risk assessment updates
- Annual Audits: Independent third-party compliance and security audits
- Incident Reports: Immediate reporting of serious violations to relevant authorities
6. Continuous Improvement
We are committed to continuously improving our compliance and risk control systems:
- Regular policy reviews and updates to reflect changing laws and regulations
- Staff training programs on compliance, content moderation, and risk management
- Technology investments in AI-powered content screening and fraud detection
- Collaboration with industry associations, regulatory bodies, and payment providers
- User feedback mechanisms to identify and address compliance concerns
7. Contact & Reporting
Compliance Officer
Growth Education Limited
Room A, 19/F, Max Share Centre
367-373 King's Road, North Point
Hong Kong
Email: admin@geledtech.com
General Inquiries: info@geledtech.com
Reporting Channels
- In-Platform Reporting: Use the "Report" button on any content page
- Email: admin@geledtech.com for urgent compliance issues
- Compliance Hotline: Available 24/7 for serious violations
- Anonymous Reporting: Whistleblower protection for employees and users
8. Policy Updates
This Compliance & Risk Control Policy may be updated from time to time to reflect changes in laws, regulations, industry standards, or our business practices. We will notify users of significant changes through our website and email notifications.
Last Updated: January 13, 2026
Next Scheduled Review: April 13, 2026
For Payment Providers: This policy demonstrates Growth Education Limited's commitment to legal compliance and risk management. Supporting documentation including business registration, audit reports, and compliance certificates are available upon request to authorized payment providers and regulatory authorities.