LingoFly Privacy Policy

Welcome to LingoFly.

LingoFly is a multi-language learning product that integrates short video content consumption, language learning, community interaction and creator services. This "LingoFly Privacy Policy" (hereinafter referred to as "this policy") is formulated by Shenzhen Bilingguo Technology Co., Ltd. (hereinafter referred to as "we") and applies to LingoFly Chinese version, overseas version App and related services provided by us and clearly applicable to this policy. If different countries or regions apply different personal information processors, legal basis, cross-border mechanisms, minor age thresholds or rights response periods, we will provide regional additional terms before the corresponding services go online.

We value the security of your personal information and privacy. This policy explains how we collect, use, store, share, transfer, publicly disclose and protect your personal information, and how you can exercise relevant rights. Please read this policy carefully and fully understand it before using LingoFly, especially the content involving sensitive personal information, personalized recommendations, third-party processing, account cancellation, your rights and the protection of minors. For content that is of great interest to you, we will draw your attention through bolding, scene prompts, or other prominent methods.

You don't need to register or log in to use basic video browsing, playback and search functions. You have the right to refuse to provide personal information that is not necessary to implement basic functions; your refusal will not affect the basic functions, but may make the corresponding additional functions unavailable. For processing activities that require consent or separate consent in accordance with the law, we will obtain your consent separately through a separate page, pop-up window or unchecked option with a clear proactive confirmation operation; simply displaying the policy link, continuing to browse or turning on device permissions does not automatically mean that you agree to other personal information processing activities.

If you do not agree to this policy, please stop using functions that require the processing of corresponding personal information. For the new processing purposes, processing methods or types of personal information after the policy is updated, we will not only regard your continued use of the service as consent; if we need to obtain new consent according to law, we will obtain your consent separately.

We follow the principles of legality, legitimacy, necessity and good faith and only process personal information that matches the functions for the purposes stated in this policy.

1. Basic browsing, playback and search

When you browse, play and search content as a guest or logged-in user, in order to provide corresponding functions, we will process the following related information:

We use the above information to provide content loading, playback, search, resume viewing, troubleshooting, security and basic statistics. Visitors can also use basic browsing, playback, and search functions; we try to process visitor records with anonymous session identifiers.

The search history currently saves up to the last 10 items, which you can clear on the search page. To resume watching from a breakpoint, you need to save the video ID, exit progress and recording time. If you do not want to continue to generate corresponding records, you can not use additional capabilities such as search history and resume viewing at breakpoints, or clear the records according to the entrance provided by the product.

2. Registration, login and account security

Depending on the version you download and use, we provide different login methods: the Chinese version supports one-click login with the operator, WeChat login and mobile phone number login; the overseas version supports Google login and email login. App versions are determined by the download channel or app store region and are not switched based on runtime IP address or system language.

If you choose to register or log in, we will process the following relevant information in order to create an account, verify identity, maintain login status and ensure account security:

We will not obtain your carrier service password, WeChat password or Google password. Third-party login credentials are handled by the respective platform.

For the new identity, we first complete the identity verification and invitation code verification, then create an account and bind the invitation relationship. Invitation codes are used for account creation, invitation attribution, one-time invitation rewards and anti-cheating. The invitation level or upstream and downstream relationships will not be displayed on the front desk.

We will save the necessary login token on your device for maintaining login status and silent login. You can skip logging in and enter the home page as a guest.

3. Personal information, following relationships and public display

If you create or edit a profile, in order to save and display the information you choose to provide, we will process your avatar, nickname, account ID, personal profile, default view, following relationship, fan relationship and the visibility range you set.

Your avatar, nickname, account logo, personal profile, public following relationships, publicly posted content and corresponding interaction data may be displayed to other users. Mobile phone number, email address, login credentials, fruit currency balance, wallet balance, payment information and invitation attribution relationship will not be displayed as public information.

You can manage partial relationship visibility, blocking users, and private message recipients in the privacy settings provided by the product. The specific setting items are subject to the page in the version you are using.

4. Content publishing, drafting and content governance

If you publish a video or post, we will process the following related information to complete uploading, display, subtitles, review and content management:

You can make content public or visible only to you. Public content may be viewed, commented on, liked, collected, or shared through the system sharing panel by other users. Please do not post personal information about yourself or others that you do not wish to be made public.

A maximum of 50 copies of a publication draft are saved for 30 days; you can delete them early. In order to save the draft, continue uploading and handle network abnormalities, we will temporarily save the draft and upload status on the device or server.

When you select content annotations such as "Including real-person appearances," "AI-generated content," "Including virtual items," "Second creations," or "Personal opinions," the corresponding annotation names will be displayed on the content playback layer in the form of "Author's Statement." For AI-generated synthetic content, we will also process the identification in the file related to the generated synthesis, the statement submitted by you, the necessary detection results and the dissemination identification to add explicit prompts in accordance with the law, write the necessary implicit identification and prevent the identification from being maliciously deleted or tampered with. Relevant records are retained only for as long as necessary to fulfill content identification, governance and audit obligations.

5. Others involved in the content

The photos, videos, audios, texts, comments, private messages or report materials you upload may contain the likeness, voice, name, contact information or other personal information of other users or natural persons who have not registered with LingoFly. Before uploading or providing such information, you should have a legal basis and respect the legitimate rights and interests of relevant persons.

If you find that your personal information appears in content provided by other users, you can contact us through the methods listed in this policy to apply for review, correction, deletion or complaint. We will handle it based on the nature of the content, scope of disclosure, rights and interests of both parties and applicable laws.

6. Community interaction, comments, private messages, reporting and blocking

If you like, collect, follow, comment, post, send a private message, report or block, in order to perform your operations and maintain community safety, we will process the following related information:

Comments and their corresponding avatars and nicknames may be disclosed to other users. Private messages are only displayed to users participating in the conversation, but in order to ensure security, handle reports, manage illegal content, or resolve disputes, we will review and retrieve the corresponding information through automated or manual methods to the extent necessary.

The current community scope includes posts, comments, and private chats with language partners, but does not include discussions, group chat communities, or group chat functions; when additional processing activities are added in the future, we will update the corresponding notices and security measures before the function is enabled.

7. Subtitles, word searches, vocabulary books and Faye learning services

If you use subtitles, word search, vocabulary books, sentence-by-sentence reading, word following, speech-to-text or Faye intelligent analysis, in order to provide corresponding learning functions, we will process the following related information:

The voice you actively submit and the information that may reflect pronunciation characteristics are highly sensitive information. Only after you click the record, voice input or read-along button will we call the microphone and process the corresponding voice.

Follow-up recordings are processed temporarily by session: the device only retains temporary recordings of the current session and current sentence, and clears them when you close the follow-up panel, exit learning, switch videos, or re-record; the server only processes the original audio within the time required to complete speech recognition or Faye scoring, and does not provide retrievable recording history. After processing is completed, canceled or ultimately failed, we will delete the original audio and the temporary copy formed for retry; to prove the processing and deletion results, the task ID, processing time and result log without audio content can be saved. The processing rules of third-party voice service providers will be explained in the "Third-Party Information Processing List" and corresponding scenario notifications.

Temporary recordings of speech-to-text comments are deleted after you send the text or cancel typing; you send the confirmed text, not the temporary recording. Unless otherwise clearly stated on the page and with your consent, we will not use the learned speech to train a general speech model or generate your voice tattoo identity template.

8. Personalized content recommendations

In order to help you discover more relevant content, we may generate recommendation results based on your actively selected interests, field of view, viewing and search records, likes, favorites, follows, comments, negative feedback, language learning behavior, and content characteristics. We will inform you in a conspicuous manner that you are using personalized recommendations, and explain the purpose, basic principles and main operating mechanism of the recommendations in an appropriate manner.

We will not use personalized recommendations to implement unreasonable differential treatment on you, nor will we show you unreasonable differentiated transaction conditions based on your ability to pay. You can select, modify or delete recommendation tags in LingoFly's recommendations or privacy settings, and turn off or reset personalized recommendations; after turning off, we will stop providing content recommendations based on personal characteristics and show you content results that are not targeted at personal characteristics.

In the minor mode, we will limit stranger interactions and voice comments, and reduce the scope of minor interaction behaviors for social diffusion.

9. Membership, fruit currency, payment and transaction records

If you purchase a membership, recharge Fruit Coins, use Fruit Coins to buy learning abilities or give rewards, we will process the following relevant information in order to complete the transaction, issue rights, reconcile accounts and handle disputes:

Payment is processed by the payment service provider listed on the purchase page according to the applicable region, application platform and product type. We will not obtain or save your third-party payment password, complete bank card number or bank card security code; the payment service provider will return to us the account ID, order status or mask information required to complete the transaction and reconciliation. The specific service providers, processing roles and information types are subject to the "Third Party Information Processing List".

When the transaction result is unknown, times out, or the callback is missing, we will mark the order as "processing" and check the order with the payment channel, and limit repeated submissions before the final status is confirmed. In order to fulfill transaction, reconciliation, tax, audit, anti-money laundering and dispute handling obligations, some transaction facts may be retained in accordance with the law after the account is deleted, and de-identification or pseudonymization measures may be taken.

10. Creator Wallet, Withdrawal and Identity Verification

If a qualified creator checks the wallet or applies for withdrawal, in order to display and settle the income, verify identity, and fulfill tax and risk control obligations, we will process the income, withdrawable balance, withdrawal amount, handling fee, payment channel, payment account identification and mask summary, withdrawal status, order flow, tax status, and risk verification results.

When making a first withdrawal, account anomaly, or as required by laws and regulations, we may need to verify your true identity and collection account, including name, ID number, ID document image, facial recognition information, collection account, and tax information required by law. The above information may be sensitive personal information. We will separately inform you of the necessity, processing method and impact on personal rights before processing, and obtain your separate consent.

Identity verification can be completed directly by a third-party authentication service provider. We only process the identity information you submit to the extent necessary to complete verification, and take measures such as encrypted transmission, access control, and minimum period storage. Unless it is absolutely necessary in accordance with the law, we do not store ID images or face images for a long period of time. We can store certification task identification, certification results, time, agreed versions and necessary audit records. The specific service providers, processing roles, information types and storage rules are subject to the separate notification when the function is enabled and the "Third Party Information Processing List".

11. Customer service, feedback, complaints and dispute handling

If you contact us to submit feedback, complaints or appeals, in order to verify your identity, locate the problem, respond to the request and save necessary processing evidence, we will process your account information, contact information, communication content, relevant screenshots or screen recordings, order information, problem handling records and other supporting materials that you actively provide.

Please do not submit ID, bank card, password or other sensitive information in your feedback that is not relevant to the question.

12. Message notification

After you authorize the notification permission, we may send you private messages, comments, attention, orders, withdrawals, review results, safety reminders and learning reminders. You can turn off notifications in your device's system settings or LingoFly's notification settings. Necessary account security, transaction results or service change notifications may still be sent via site messages, email or SMS.

13. Safety assurance, fault diagnosis and statistical analysis

In order to ensure the security of accounts, content, transactions and systems, diagnose faults and perform necessary statistics, we will process device and application information, IP addresses, network status, operation logs, request identifiers, crash logs, interface responses, login and transaction risk characteristics, and cleaned usage events.

We will try our best to avoid recording content text, passwords, complete mobile phone numbers, complete email addresses, ID numbers, payment credentials and other sensitive information in diagnostic logs, and will truncate and filter free text such as search terms in sensitive patterns. Raw product analysis events are retained for 180 days, after which time they are deleted or aggregated into statistical results that do not directly identify individuals.

We will not use algorithms or automated accounts to generate false likes, comments, retweets, follows, reviews, transactions or traffic. If operating accounts or automated accounts are used to provide system notifications, product guidance, learning aids or safety reminders, we will mark them in an identifiable way and isolate the system behavior from the number of real-person interactions, rankings, recommendation weights, transactions, creator income and invitation rewards; relevant logs are only used for function fulfillment, security, risk control and auditing.

14. Exceptions to consent

To the extent permitted by applicable law, personal information may be processed without your prior consent in the following circumstances:

We only apply for device permissions when you use the corresponding functions. You can revoke the authorization in the system settings. After the withdrawal, the corresponding functions may not be available, but it will not affect other functions that do not rely on this permission.

The current version does not apply for precise location, address book, call history or text message reading permissions for the purpose of providing basic functions. If relevant functions are added in the future, we will explain the purpose before calling and update this policy if necessary.

Networking, reading basic network status and maintaining secure connections are system capabilities required to provide online services, and do not belong to sensitive device permissions such as cameras and microphones that are turned on by users one by one. We will still treat IP addresses, network types, request times, and error messages to the minimum necessary.

LingoFly App uses necessary local storage to save login tokens, language and subtitle settings, privacy settings, search history, drafts, cache, temporary media, message queue, and failed retry status to maintain login, improve loading speed, and ensure operational integrity. You can clear some records through the product portal; uninstalling the app will usually clear the local data on the device, but will not automatically delete the accounts and content that have been synchronized to the server.

Our website or H5 pages use cookies or similar technologies that are necessary to maintain logins, security, payment bounces, and preferences. If analytics, advertising or other non-essential cookies are used, we will provide corresponding instructions and a choice mechanism before use; you can also manage or clear cookies through your browser settings.

The third-party SDK will only process device, network, account or transaction information directly related to the function when necessary to implement the disclosed function, and will not process information irrelevant to the current function in advance just because the App is launched. You can check the name of the actually activated service provider, processing role, processing purpose and method, information type, trigger timing, permissions, retention period, data area and privacy policy link through the "Third-Party Information Processing List" provided by LingoFly.

1. Entrust processing and provision to third parties

We will not sell your personal information. Only to the extent necessary to implement the functions described in this policy, we may entrust cloud computing, content distribution, SMS and one-click login, third-party login, payment, identity verification, speech recognition, translation, AI generation, content review, crash monitoring or customer support service providers to process personal information; when we really need to provide personal information to a third party that independently determines the purpose or method of processing, we will inform the recipient of the name and contact information, processing purpose, processing method and information type in accordance with the law, and obtain the necessary consent. The "Third Party Information Processing List" will distinguish different roles such as entrusted processors, co-processors, independent personal information processors, application stores and payment channels.

We will bind the trustee through contracts, security assessments, authority control and audits, etc., and require them to process information only in accordance with our instructions. If separate consent is required by law, we will obtain your consent separately.

2. Users actively disclose or share

Your publicly posted profile information, videos, posts, comments, likes or tips will be disclosed to other users based on your actions and visibility. When you share content to off-site applications through the system sharing panel, subsequent processing will be governed by the rules of the third-party application you choose. Please choose your sharing partners carefully.

3. Transfer

In the event of a merger, division, reorganization, asset transfer, bankruptcy liquidation or similar transaction involving the transfer of personal information, we will inform the recipient of the name and contact information and require it to continue to be bound by this policy; if the recipient changes the original purpose or method of processing, it will obtain your consent again in accordance with the law.

4. Public disclosure

Unless you voluntarily disclose and implement platform governance decisions in accordance with the law, or unless otherwise required by laws and regulations, we will not publicly disclose your personal information. If separate consent is required by law, we will obtain your consent before public disclosure.

We will list the third-party services actually enabled by LingoFly through an independent "Third-Party Information Processing List". The list includes the legal name of the service provider, processing role, processing purposes and methods, personal information types, trigger scenarios, device permissions, retention period, data region and privacy policy link, and is updated in a timely manner based on actual access conditions.

You can view this list in LingoFly's privacy settings or on the display page of this policy. Before using functions independently provided by a third party, please also read the third party's service rules and privacy policy; if consent or separate consent is required by law, we will obtain your consent before processing begins.

We may use automated technology for content recommendation, content security review, account or transaction risk judgment, voice scoring and learning feedback. If automated decision-making has a significant impact on your rights and interests, you have the right to ask us for explanations and the right to reject decisions made solely through automated decision-making; we will provide appeal or manual review channels.

Faye can call the AI or voice services listed in the "Third Party Information Processing List" to process the words, sentences, text, voice or context fragments you actively submit. We will remove account identifiers that are not required to complete the task before sending, and restrict service providers to process input content beyond our instructions through contractual and technical measures. We will not allow service providers to use your input for their general model training or independent marketing without otherwise clearly informing you and obtaining your consent in accordance with the law. The name of the service provider, processing role, whether it is used for model improvement, subcontractor, storage area and retention period are subject to the "Third Party Information Processing List" and the corresponding scenario notification.

The example sentences, analysis and ratings generated by AI are only used as learning aids, may be inaccurate or incomplete, and do not constitute professional opinions. Generative AI output will not be used as the sole basis when it comes to your appeal, ban, withdrawal or processing of major rights and interests.

1. Storage location

We will determine the storage location of personal information based on the actual operating entities, production deployment and applicable laws. Information stored domestically as required by law will be stored in accordance with the corresponding requirements; if it is indeed necessary to provide it overseas, we will complete the applicable security assessment, personal information protection certification, standard contract or other legal procedures, inform you of the overseas recipient, processing purpose, processing method, information type, retention period and rights exercise method, and obtain your separate consent when necessary.

For specific storage areas and overseas recipient information, please refer to the regional additional terms and "Third Party Information Processing List" applicable to your region.

2. Storage period

We will only store personal information for the shortest period necessary to achieve the purpose of processing, unless otherwise required by laws and regulations or you have otherwise agreed. If the specific period can be determined, it will be implemented in accordance with the table below; if it is difficult to determine the specific period, we will determine it based on the time necessary to complete the corresponding functions, maintain accounts and content, ensure security, perform legal obligations and handle disputes, and delete or anonymize it after the purpose is achieved.

After the retention period has expired, we will delete or anonymize the personal information; if it is technically difficult to delete it immediately, we will stop processing other than storing and taking necessary security protection measures.

3. Account deactivation and cancellation

There is a 30-day recovery period after you initiate account cancellation. During the recovery period, the account is deactivated; if you use the original login method to restore it, the account and necessary data can be restored. After the recovery period expires, we will initiate the final deletion process, release login identities and contact information, delete or anonymize deletable accounts and analytical data, and stop using them for daily product analysis. Only temporary deactivation without entering the final deletion process will not be considered as complete account cancellation.

After the recovery period expires, public videos, posts, comments and other user content associated with the account will in principle be deleted with the account or irreversibly anonymized. Only when laws and regulations clearly require that it is necessary to retain and handle other people's legitimate rights and interests or disputes, or if you actively choose to retain public content during the deletion process, the corresponding content can continue to be saved within a limited scope; when it continues to be publicly displayed, identifiable account information should be removed and marked as a "logged-out user". If applicable regional or app store rules require deletion of associated user content, such regulations shall apply. Records required for transactions, taxation, auditing, risk control, illegal content evidence, and dispute resolution may be limited to be kept within legal or necessary periods and will not be used for daily recommendations, marketing, or user profiling.

You may withdraw your cancellation request before the 30-day reinstatement period expires. You can submit an application through LingoFly's account and security or account cancellation portal; if an off-site portal is required by law or app store rules, we will also provide a public portal on the official website or this policy display page.

We adopt risk-appropriate technical and management measures, including access control, least privileges, transmission encryption, sensitive field encryption or digestion, log desensitization, environmental isolation, backup and recovery, security monitoring, supplier management and employee confidentiality management.

No Internet service is absolutely secure. Please keep your account number, verification code and password safe and do not disclose them to others. If you find that your account is being used abnormally, please contact us in time.

When a personal information security incident occurs, we will immediately take remedial measures and report it to the competent authority in accordance with applicable legal requirements; if it may cause damage to your rights and interests, we will inform you of the basic situation of the incident, possible impact, measures taken, preventive measures you can take, and contact information through App notifications, text messages, emails, or announcements.

Within the scope of applicable laws, you have the right to know, decide, restrict or refuse processing, access, copy, correct, supplement, delete, withdraw consent, cancel your account, request explanation of automated decision-making and request transfer of personal information.

You can exercise some of your rights in the following ways:

To ensure account security, we may verify your identity first. We will respond within the period specified by applicable law; if no shorter period is required by law, we will respond within 15 working days. If the request is complex, the quantity is large, or the request can be postponed according to law, we will explain the reasons for the extension. For requests that are unreasonably repeated, exceed reasonable limits, infringe upon the rights of others, or are otherwise permitted by law, we may reject and explain the reasons in accordance with the law.

Withdrawal of consent will not affect processing activities that have been carried out based on consent before the withdrawal. Deleting an item of information may cause features that rely on that information to no longer work.

LingoFly is not a product specifically designed for children under 14 years of age. If you are a child under the age of 14, please use functions that require the processing of personal information under the guidance of your guardian after your guardian has read and agreed to this policy and the special rules for protecting children's personal information. Before the children's personal information protection rules, guardian consent mechanism and age identification mechanism are officially launched, users under the age of 14 should not register their own accounts or use functions that require the submission of personal information.

If you are over 14 years old but under 18 years old, please read and use this service under the guidance of your guardian, and use publishing, private messages, recharges, memberships, single product buyouts, rewards, cash withdrawals and other paid or high-risk functions with caution. The underage mode will limit stranger interactions and voice comments; all payment activities should also comply with applicable laws, platform rules and guardian authorization requirements.

If we find that children's personal information has been processed without valid guardian consent, we will stop the relevant processing after verification and delete or anonymize it in accordance with the law. Guardians can contact us through the methods listed in this policy to apply for access, correction or deletion of the ward’s personal information.

The age threshold and guardian consent requirements for minors in overseas versions should also comply with the laws of the user's location. Before the specific target market goes online, we will supplement the corresponding regional rules.

If you use LingoFly outside of China, you may also have rights to access, correct, delete, restrict processing, object to processing, data portability, withdraw consent, complain to regulatory authorities, or refuse the sale, sharing or targeted advertising of personal information in accordance with local laws.

Before officially entering a specific country or region, we will provide applicable regional additional terms based on the target market, operating entities, server regions, third-party services and local laws. Regional additional clauses should at least describe the local personal data processor or representative, the legal basis for processing, rules for sensitive information and minors, cross-border transfer mechanisms, retention periods, scope of rights and response periods, supervisory authorities and complaint methods. If regional additional terms conflict with this policy, the terms that apply to the region and provide more specific protection shall prevail; before the additional terms are completed, the general expressions in this section will not replace the information that must be provided by local law.

We may update this policy due to changes in functionality, processing activities, laws, regulations or regulatory requirements. When major changes occur, we will notify you through app pop-ups, site messages, push notifications, emails or announcements and other prominent means, and provide you with a reasonable reading period.

Significant changes include substantial changes in the purpose of processing, processing methods or types of personal information, new processing of sensitive personal information, changes in the objects to which personal information is shared, transferred or publicly disclosed, significant changes in your rights and the way they are exercised, or significant changes in the security risks of personal information.

If consent or separate consent is required by law, we will obtain your consent again before starting relevant processing. You can view the current version and historical versions on this page.

If you have questions, comments, complaints or appeals about this policy, personal information processing activities or your rights, you can contact us in the following ways:

We will verify your identity and process it within the period specified by applicable law. If you are dissatisfied with the processing results, you can complain to the personal information protection, Internet information, consumer rights protection or other competent authorities with jurisdiction, or you can seek other relief in accordance with the law.