Privacy Policy

The data controller (the organisation responsible for your personal data) is Champion Future International Education Group Limited, a company incorporated in the Hong Kong Special Administrative Region of China, registered address: [registered address]. You can reach our privacy team at Contact page or through the Contact page.

This policy applies to the CNLingo app for iOS and Android, the CNLingo web app (m.cnlingo.cn), the website cnlingo.vvtalker.com and related customer support. It does not apply to third-party websites, app stores or payment services, which have their own privacy policies.

Our services are intended for learners aged 13 and over (or the higher age required where you live). The section "Children's privacy" explains how we treat the data of younger learners and what parents can do.

We collect the following categories of personal data. "You provide" means you enter it yourself; "collected automatically" means our apps or servers record it while you use the service.

We do not ask for, and ask you not to submit, special categories of data such as health, religion, ethnicity or political opinions. Voice recordings are used only to transcribe and score your speech; we do not create voiceprints to identify you.

We use personal data only for the purposes below. Where the GDPR, the UK GDPR or a similar law applies, the legal basis for each purpose is shown.

We do not sell personal data, we do not use it for third-party behavioural advertising, and we do not make decisions with legal or similarly significant effects on you based solely on automated processing. AI-generated scores and feedback are learning aids only.

Speaking features are the heart of CNLingo, so here is exactly what happens with your voice:

• Recording is always started by you (press-to-talk or a record button) and stops when you release or stop it. We never record in the background.
• The recording is sent over an encrypted connection to our servers and then to the speech provider needed for the feature: pronunciation and tone scoring is performed by SpeechSuper or Chivox; speech recognition and text-to-speech by Volcengine, Alibaba Cloud or our own servers; written feedback and conversation replies by large-language-model (LLM) providers. These providers are located in mainland China and act as our processors under contract — see "Who we share data with" and "International data transfers".
• Your recordings, and the audio of the AI tutor's spoken replies, are kept for no more than 30 days and then deleted automatically, unless you choose to keep a recording in your learning history. Transcripts, scores and feedback stay with your learning records (see "How long we keep data").
• We send providers only what the feature needs: the audio (or a temporary link to it), the reference text and a pseudonymous identifier that does not reveal who you are. We do not send your name, phone number or e-mail address.
• We do not use your recordings to train our own or third-party AI models, and our contracts with providers prohibit them from using your data for their own purposes.
• AI output can be wrong. Scores, corrections and conversation replies are generated automatically, are not reviewed by a teacher, and are not an official HSK, HSKK or YCT result.

We share personal data only with the categories of recipients listed below, only to the extent needed for the stated purpose, and under contracts that require them to protect it. We may update this list as our providers change; the current list is always on this page.

We do not sell personal data. Device identifiers are passed to Ocean Engine only to measure our own advertising campaigns and only with your consent (iOS tracking prompt or our in-app privacy dialog); you can withdraw it at any time in your device settings. We never allow third parties to use your data to show you targeted advertising.

Our servers are hosted in the Hong Kong SAR, and the speech, AI, SMS, advertising-measurement and order-management providers listed above process data in mainland China. If you use CNLingo from another country, your personal data — including voice recordings — is therefore transferred to and processed in Hong Kong and mainland China, whose data-protection laws may differ from those of your country.

• European Economic Area, United Kingdom and Switzerland: we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum) with each recipient, together with supplementary measures such as encryption in transit, data minimisation (speech and AI providers receive only pseudonymous identifiers) and short retention. You can request a copy of the safeguards at Contact page.
• Mainland China: data of users located in mainland China is processed in accordance with the Personal Information Protection Law (PIPL). Storage in Hong Kong is an outbound transfer under PIPL; we obtain your separate consent where required and adopt the standard contract or other mechanisms prescribed by the Cyberspace Administration of China as applicable.
• Hong Kong SAR: we handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and the recommended model contractual clauses of the Privacy Commissioner for Personal Data when transferring data outside Hong Kong.
• Other countries: where your local law requires a specific transfer mechanism, consent or notice, we apply it. If a transfer cannot be made lawfully, we will not offer the affected feature in your country.

By using the speaking features you acknowledge that your recordings will be processed by the providers above. You can use CNLingo without these features: vocabulary, reading, listening and writing exercises do not involve voice recordings.

We keep personal data only as long as needed for the purposes above, then delete or anonymise it. Default periods:

We may keep data longer where the law requires it or where it is needed to resolve a dispute, enforce our Terms or prevent fraud, and we may keep anonymised statistics indefinitely.

Depending on where you live you have some or all of the following rights, which we honour for every user regardless of location:

• Access: obtain confirmation that we process your data and a copy of it.
• Correction: have inaccurate or incomplete data corrected (nickname, avatar and profile can be edited in the app).
• Deletion: have your data deleted — see "Deleting your account".
• Portability: receive the data you provided in a structured, commonly used, machine-readable format.
• Restriction and objection: ask us to limit processing, or object to processing based on legitimate interests, including any direct marketing.
• Withdraw consent: at any time, with effect for the future — for example by revoking the microphone permission or the tracking permission in your device settings.
• Not to be subject to automated decisions with legal or similarly significant effects.
• Complain: lodge a complaint with a supervisory authority — in the EEA your national data-protection authority, in the UK the Information Commissioner's Office (ICO), in Hong Kong the Privacy Commissioner for Personal Data (PCPD), in mainland China the Cyberspace Administration of China or other competent departments.

To exercise a right, write to Contact page or use the Contact page. We may ask you to verify your identity (for example with the phone number on the account). We respond within 30 days, or sooner if your local law sets a shorter deadline, and we do not charge a fee unless requests are manifestly unfounded or excessive. We will not discriminate against you for exercising your rights.

You can delete your CNLingo account at any time:

• In the app: open My profile → Settings → Delete account and confirm with the SMS code sent to your phone number. Deletion is available in every country.
• On the web: send a request through the Contact page or to Contact page from the phone number or e-mail linked to the account; we will verify it and confirm when deletion is complete.

When you delete your account we immediately deactivate it and stop all processing; within 30 days we permanently delete or anonymise your account data, learning records, recordings and transcripts. We keep only what the law requires us to keep (for example purchase records for accounting purposes) and what is needed to resolve disputes or prevent fraud, as described in "How long we keep data". Deleting your account does not cancel an active subscription — cancel it first in the App Store or Google Play (see the Refund & Cancellation Policy).

We use technical and organisational measures appropriate to the risk: encryption in transit (TLS) for all app, website and provider traffic; salted password hashing; access to production systems restricted to authorised staff with authentication and logging; recordings stored under random, non-guessable file names and deleted on the schedule above; pseudonymous identifiers in data sent to providers; regular backups; and contractual security obligations for every provider. No system is perfectly secure; if a breach affects your data we will inform you and the competent authorities as required by law.

CNLingo is designed for learners aged 13 and over. Where your local law sets a higher age for consenting to data processing, that age applies — for example the age set by your EU member state (13 to 16), 14 in mainland China and South Korea, and 16 in some other countries. We do not knowingly create accounts for, or collect personal data from, children below that age.

Our YCT (Youth Chinese Test) learning content is suitable for young learners. It is intended to be used by learners who meet the age requirement, or by younger children only through the account and under the supervision of a parent or guardian, who is then responsible for the account. We do not currently offer a separate children's mode, we do not show behavioural advertising, and we do not sell the data of any user.

Parents and guardians: if you believe a child has created an account or provided us with personal data without the required consent, contact us at Contact page or via the Contact page. We will verify your request and delete the child's account and data promptly. You can also use the in-app account deletion described above.

Website (cnlingo.vvtalker.com): we do not use advertising or analytics cookies and we do not track you across other websites. The site stores your language and display preferences in your browser's local storage, and sets a session cookie only when a member of our staff signs in to the administration area. Pages, fonts and images are served from our own servers, so viewing the site does not send your data to other companies. Where a course offers a preview video, it is loaded from YouTube's privacy-enhanced mode (youtube-nocookie.com) only when you choose to play it; YouTube then receives your IP address and may store data in your browser. Our web server keeps standard access logs (IP address, requested page, time, browser) for security.

App and web app: the app stores your sign-in token, language and learning preferences on your device so that you stay signed in; they are removed when you sign out or uninstall the app. We honour the "Allow apps to request to track" setting on iOS and the Android advertising-ID settings. Because we do not track across sites, we do not currently respond to browser "Do Not Track" or Global Privacy Control signals in any other way.

We send messages necessary for the service — verification codes, security alerts, changes to our terms and the in-app learning reminders you set yourself. We send marketing e-mails or messages only if you opt in, and every marketing message contains an unsubscribe link. Learning reminders and push notifications can be switched off in the app or in your device settings at any time.

European Economic Area, United Kingdom and Switzerland: Champion Future International Education Group Limited is the controller. The legal bases we rely on are listed in "How and why we use your data". We have not appointed a representative in the EU or the UK; you can contact us directly at Contact page. You may complain to your local supervisory authority.

California (CCPA/CPRA) and other US states: in the past 12 months we have collected the categories of personal information described in "Information we collect" (identifiers, customer records, commercial information, audio information, internet activity, geolocation derived from the IP address and inferences about learning level) for the purposes described in "How and why we use your data". We do not sell personal information. Passing device identifiers to Ocean Engine for campaign measurement may count as "sharing" under Californian law; it happens only with your consent, and you can opt out at any time by refusing or withdrawing that consent in your device settings. We do not use sensitive personal information to infer characteristics about you, and we do not knowingly sell or share the data of consumers under 16. You have the rights to know, delete and correct, and to non-discrimination; you may use an authorised agent. Contact Contact page or the Contact page.

Mainland China (PIPL): we process your personal information with your consent and for the purposes above. Voice recordings are sensitive personal information; we ask for your separate consent before you use speaking features and before transferring data outside mainland China (to Hong Kong). You have the rights to access, copy, correct, delete, restrict and withdraw consent, to request an explanation of our processing rules and to have your account deleted; to exercise them contact Contact page. If you believe we have not handled your request properly you may complain to the Cyberspace Administration of China.

Hong Kong SAR (PDPO): this policy serves as our Personal Information Collection Statement. Providing data is voluntary, but without the data marked as required we cannot provide the service. We will not use your data for direct marketing without your consent. You may make a data access or correction request under the PDPO to Contact page; we may charge a reasonable fee for data access requests as permitted by the Ordinance.

Other countries: you may have similar rights under your local law (for example Brazil's LGPD, Japan's APPI, South Korea's PIPA, Thailand's PDPA, Vietnam's Decree 13/2023, Indonesia's PDP Law, Türkiye's KVKK or Russia's Federal Law 152-FZ). Contact us to exercise them; where a local requirement prevents us from providing a feature lawfully, we may restrict it in your country.

We may update this policy when our services, providers or the law change. Each version carries a version number and date at the top of the page. For material changes we give at least 30 days' notice in the app, by e-mail or on the website before they take effect and, where the law requires, we ask for your consent again. Earlier versions are available on request.

Data controller: Champion Future International Education Group Limited. Registered address: [registered address]. Privacy enquiries, data-subject requests and parental requests: Contact page or the Contact page. Please include "Privacy" in the subject line so that we can route your request quickly. If you prefer to write, mark your letter for the attention of the Data Protection Officer at the address above.