PRIVACY POLICY

PRIVACY POLICY Effective Date: October 2, 2026 (Last Updated: October 2, 2026)

Khoi Nguyen operates the Lyngopal: AI Language Tutor application (the "Service"), which is provided at no cost and is ad-supported. This privacy policy is intended to inform users regarding the collection, use, and disclosure of personal information when using our Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Information Collection and Use We may collect and use personal information to provide and improve our Service. The types of personal data we collect include: Device or Other IDs: We may collect Device IDs (such as UUID, Advertising ID, Firebase installation ID, or other unique device identifiers) for the purposes outlined in this policy. We do not collect IMEI or MAC addresses. Approximate Location: Derived from your device's IP address. The app does not request or access your precise (GPS) location. Log Data: If the app encounters an error, we may collect log data such as your device's IP address, device name, operating system version, app configuration, and usage statistics. In-App Activity: Information about your interactions with the app, such as app launches, lessons opened, feature usage, and session duration (collected via Firebase Analytics). Microphone and Voice Input (RECORD_AUDIO permission): Speaking lessons and the AI tutor let you answer by voice. The microphone is only used while you tap the record/speak button, after you grant the microphone permission. Your speech is converted to text by your device's built-in Android speech recognition service (usually provided by Google), which may process the audio according to its own privacy policy. We do not record, store, or upload your audio to our servers. You can deny or revoke the microphone permission at any time in your device settings; all other features keep working. AI Tutor Chat Messages: When you chat with the AI tutor, the text you type or dictate is sent over an encrypted connection to the Google Gemini API to generate a reply. Please do not include sensitive personal information in your messages. Your chat history is saved only on your device so you can continue the conversation, and it is removed when you clear the app data or uninstall the app. Learning Progress: Your selected language, completed lessons, exercise attempts, and scores are stored locally on your device to track your progress. This data is not uploaded to our servers. Notifications (POST_NOTIFICATIONS permission): If you allow notifications, we use Firebase Cloud Messaging to send learning reminders and app updates. Firebase assigns your device a messaging token for this purpose. You can turn notifications off at any time in your device settings. Cookies: We do not explicitly use cookies, but third-party services like Google Play Services, AdMob, and Firebase Analytics may use cookies or similar technologies to collect information for their services. Crash logs: Firebase Crashlytics automatically collects crash reports (such as device model, operating system version, app state, and stack traces) when the app crashes. This helps us fix bugs faster. Google receives this data.

2. Use of Personal Data The personal information we collect is used for the following purposes: To provide and maintain the Service (e.g., lessons, speaking practice, and the AI tutor). To improve, personalize, and enhance the Service (e.g., lesson recommendations based on your progress). To send learning reminders and notifications you have allowed. To monitor the performance and error reporting of the app. To configure app features and ad settings remotely (via Firebase Remote Config). For targeted advertising, ad measurement, and analytics purposes (e.g., serving relevant ads via AdMob and measuring ad performance and app installs via Adjust). We will not use or share your information except as described in this Privacy Policy. You can opt out of personalized advertising by deleting or resetting your Advertising ID in your device settings (Android: Settings > Google > Ads > Delete/Reset advertising ID).

3. Third-Party Services Our app uses third-party services that may collect information used to identify you. These include: Google Play Services Google AdMob (including the Google User Messaging Platform for ad consent) Google Firebase (Analytics, Crashlytics, Cloud Messaging, Remote Config) Google Gemini API (AI tutor replies) Adjust (ad attribution and measurement) These third parties may collect and use data in accordance with their own privacy policies. You can find links to their privacy policies below: Google Privacy Policy: https://policies.google.com/privacy AdMob Privacy Policy: https://support.google.com/admob/answer/6128543 Firebase Privacy and Security: https://firebase.google.com/support/privacy Gemini API Additional Terms: https://ai.google.dev/gemini-api/terms Adjust Privacy Policy: https://www.adjust.com/terms/privacy-policy/

4. Your Rights Regarding Personal Data If you are located in the European Union (EU), California, or Virginia, you have specific rights regarding your personal data: For EU Residents (GDPR): Right to Access: You have the right to request access to your personal data. Right to Correct: You have the right to request correction of inaccurate or incomplete personal data. Right to Deletion: You can request the deletion of your personal data. Right to Restrict Processing: You can request restrictions on the processing of your personal data. Right to Object: You have the right to object to processing, especially for marketing purposes. For California Residents (CCPA): Right to Know: You can request information about the categories and specific personal data we collect about you. Right to Delete: You have the right to request the deletion of your personal data. Right to Opt-Out: You can opt-out of the sale of your personal data (although we do not sell your data). Right to Non-Discrimination: You will not be discriminated against for exercising your rights. For Virginia Residents (VCDPA): Right to Access: You can request access to your personal data. Right to Correct: You can request correction of inaccurate personal data. Right to Delete: You can request deletion of your personal data. Right to Opt-Out: You can opt-out of targeted advertising, the sale of personal data, and profiling. How to Exercise Your Rights: To exercise any of these rights, including data deletion, please contact us at the details below. We will respond to verified requests within 30 days (or 45 days for CCPA, if applicable). For deletion, we will remove your data from our systems unless retention is required for legal or operational reasons (e.g., fraud prevention). The app has no user accounts, so deletion applies to all collected identifiers and logs associated with your device. Data stored only on your device (learning progress and chat history) can be deleted at any time by clearing the app's data or uninstalling the app. Email: nguyenhoangminhkhoi2301@gmail.com

Advertising and Opt-Out Options This app uses Google AdMob to display ads. AdMob (provided by Google) may collect data such as your device advertising ID, IP address, and usage information to serve personalized ads. Users in the EEA, UK, and Switzerland are asked for consent through Google's consent form before personalized ads are shown. Google does not sell your personal information. However, the use of your data for personalized advertising may be considered a "sale" or "sharing" of personal information under certain US state privacy laws (e.g., California, Colorado, Virginia, etc.). How to opt out:

1. Opt out of personalized ads: Go to your device settings > Google > Ads > Delete advertising ID (or Opt out of Ads Personalization on older Android versions).

2. Manage your ads preferences online: Visit https://adssettings.google.com

3. For California and other state residents: You can submit a "Do Not Sell or Share My Personal Information" request at https://myadcenter.google.com More details on how Google uses data with partner apps: https://support.google.com/admob/answer/7666335 (How Google uses data when you use our partners' sites or apps) Google's full Privacy Policy: https://policies.google.com/privacy

Right to Know What Personal Information Is Shared You have the right to know whether your personal information is being shared with third parties and for what purpose. Yes, we share the following personal information with third parties: • Device advertising ID • IP address (approximate location) • App usage data (via Firebase Analytics) • Crash logs and performance data • AI tutor chat messages you send • Notification (messaging) token These are shared with: • Google AdMob (for showing ads) • Adjust (for measuring ad performance and app installs) • Google Firebase (for analytics, crash reports, notifications, and remote configuration) • Google Gemini API (for generating AI tutor replies) • Google Play Services (for core app functionality) Purpose of sharing: – To display relevant ads – To improve app performance and fix bugs – To provide AI tutor conversations and learning reminders You can see exactly what data Google receives from apps like ours here: https://support.google.com/admob/answer/7666335 You can stop all sharing for advertising at any time using the opt-out methods listed above.

Right to Know Whether Your Personal Information Is Sold You have the right to know if we sell your personal information. We do NOT sell your personal information in the traditional sense. However, sharing your Device Advertising ID and usage data with Google AdMob for personalized ads may be considered a "sale" or "sharing" under certain US state privacy laws (California CCPA, Colorado CPA, Virginia VCDPA, etc.). Therefore, YES — this specific sharing for personalized ads is legally treated as a "sale" in some states. You can stop this "sale" instantly using any of these methods:

1. Device settings → Google → Ads → Delete advertising ID / Opt out of Ads Personalization

2. Online: https://myadcenter.google.com (click "Do Not Sell or Share My Personal Information")

3. Online: https://adssettings.google.com After opting out, you will only see non-personalized ads and no further "sale" occurs.

Right to Lodge a Complaint with a Supervisory Authority (GDPR – EU/UK users) If you are in the European Union, European Economic Area, or United Kingdom, you have the right to lodge a complaint about our data processing with your local supervisory authority. You can find your country's authority here: https://edpb.europa.eu/about-edpb/board/members_en For example: • France → CNIL (cnil.fr) • Germany → each state has its own (e.g., Bayern: lda.bayern.de) • Netherlands → Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl) • Spain → AEPD (aepd.es) We always prefer you contact us first at nguyenhoangminhkhoi2301@gmail.com so we can fix any issue immediately, but you are free to go straight to your authority anytime.

Legal Basis for Processing Your Personal Data (GDPR – EU/EEA/UK users) We only process your personal data when we have a valid legal basis under GDPR Article 6:

1. Legitimate Interests (Art. 6(1)(f)) – This is our main legal basis for: • Showing you non-personalized ads via Google AdMob • Collecting crash logs and analytics via Firebase • Measuring app performance and fixing bugs • Detecting fraud or abuse → These are necessary for running a free, ad-supported language learning app and are proportionate to your privacy rights.

2. Consent (Art. 6(1)(a)) – We rely on your consent for: • Personalized ads (you can withdraw consent anytime using the opt-out methods above) • Microphone access for voice input • Push notifications

3. Contract (Art. 6(1)(b)) – Processing needed to provide the core learning features you requested, such as lessons, speaking practice, and AI tutor replies. You can withdraw consent or object to legitimate interests processing at any time by emailing nguyenhoangminhkhoi2301@gmail.com – we will stop within 24 hours.

4. Device ID and Data Collection We may collect Device ID data (such as UUID, Advertising ID) and other device-specific information automatically when you use our Service. This information is used for: App functionality and user experience. Analytics, performance monitoring, and error reporting. Advertising and targeted content. Security and fraud prevention. We may share Device ID data with third-party services like Google Play Services, AdMob, Firebase, and Adjust. Please refer to their privacy policies (linked in Section 3) for more details.

5. Data Retention We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including providing you with our services, complying with legal obligations, and resolving disputes. Log Data and Device ID may be retained for up to 12 months to help us improve the Service, troubleshoot errors, or comply with legal obligations. Learning progress and AI tutor chat history are stored only on your device and are kept until you clear the app's data or uninstall the app. If you request the deletion of your personal data, we will remove it from our systems, except where retention is necessary for legal or operational reasons.

6. Data Controller and Contact Information The data controller for your personal data under applicable data protection laws (GDPR, CCPA, VCDPA) is: Khoi Nguyen Tien Hai ward, Hung Yen province, Vietnam Email: nguyenhoangminhkhoi2301@gmail.com

7. Data Protection Officer (DPO) If you have any questions regarding the processing of your personal data or wish to exercise your rights under GDPR, you can contact our Data Protection Officer (DPO) at: Khoi Nguyen Tien Hai ward, Hung Yen province, Vietnam Email: nguyenhoangminhkhoi2301@gmail.com

8. Changes to This Privacy Policy We may update this Privacy Policy from time to time. When we make changes, we will post the updated policy here and update the "Effective Date" at the top of the page. We encourage you to review this policy periodically for any changes. Significant updates will also be notified in-app.

9. Children's Privacy Our Service does not address anyone under the age of 13. We do not knowingly collect personal data from children under 13. If we discover that a child under 13 has provided us with personal data, we will immediately delete this information from our systems. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us so we can take appropriate action.

10. Security We strive to use commercially acceptable means to protect your personal data, including encryption in transit (e.g., TLS for data sent to third-party services such as the Gemini API and Firebase). However, please remember that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Links to Other Sites Our Service may contain links to other websites. If you click on a third-party link, you will be directed to that site. We encourage you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Contact Us If you have any questions or suggestions about this Privacy Policy, please feel free to contact us at: Email: nguyenhoangminhkhoi2301@gmail.com