Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (the “Policy”) serves to explain what information [Lingo Desk]and its affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.

1. What Information Do We Collect?

I. Device information

We collect your device and network connection information in order to provide you better experience when you use our app.

This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, the terminal manufacturer, the terminal device operating system version, the location of the language, the time zone and the network state (Wi-Fi and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim card country, Application release status in google play, Ad loading strategy, Ad platform and advertising placement id. Phone height and width, sim operator name, os version etc

We store the information collected through the Android ID tied to the device you are using. In this way, we can retain your advertising behavior while you are using the app. We will treat this information as personal information

II. Data about your use of the Services

Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed page.

Permissions status.

Whether the function is running normally.

first open time timestamp

app brand

app net status

firebase_device_id

app model

sim country

system language etc

Advertisers may store or read cookies

These data only be passed to the certified third-party statistical platform: Firebase, Google Analytics and Flurry.

The above information is only used to improve the product experience and will not be sold or share to any third parties. We will not use this information for purposes other than improving the product experience and ad performance.

III. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated in our app may access your information, including:

Google Advertising ID

Demographic data (e.g. determination of your IP address)

Data to fight against fraud (e.g. click fraud in advertising)

Data associated with your device (e.g. device type, technological information, country)

Data to do advertising, marketing and analysis

Advertisers may store or read cookies

The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google Admob, Facebook Audience Network, Unity, Applovin MAX, Smaato, IronSource, etc., and also analytical tools partners, such as Firebase, Google Analytics and Flurry. The links to the above-mentioned platforms’ privacy policy are attached in the section “Third-party Privacy Policy”.

IV. Android Advertising ID

We use your Android advertising identifier in order to provide you with customized advertisement experience. It is used exclusively for advertising and analytics. Please note that the advertising identifier does not contain any user sensitive information that can be used to identify you as a user or your device. It is not connected to personally-identifiable information or associated with any persistent device identifier (for example: SSAID, MAC address, IMEI, etc.).

V. Other Information

We may collect information that you directly and voluntarily provide to us. The information includes but is not limited to: your email address, the content of feedback, and the content of the questionnaire answered by you.

VI. Designated Countries

For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

2. How Do We Use the Information?

I. To improve and optimize the Services

To provide better Services to you, we have a legitimate interest to collect and process necessary data to:

Update and develop the Services

Develop and improve your experience

Manage the relationship with you

Customize your service experience

Respond to your comments and questions and provide support to you

Provide offers in the Services as well as in other websites and services

Send related information (e.g. updates, security alerts, support messages) to you

II. To provide the Services

To provider the Services, we process data necessary to:

Allow you to use the Apps and the Services

Operate the Services

Provide and deliver products and services that you request

III. To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, used applications, information related to the interaction of you with the Services and with other users, and so forth.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to:

Track the content you access in connection with the Services and your online behavior

Deliver, target and improve our advertising and marketing materials

Pass the information collected from you to third party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

IV. To secure the Services

Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Services

Prevent cheating, crime or fraud

Take action against fraudulent or misbehaving users

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post related to our apps will be publicly available.

V. Designated Countries

For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

3. What Information Do We Share?

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.

4. What Are the Important Permissions We Request?

Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we can ask are listed below:

Storage

read the contents of your USB storage

modify or delete the contents of your USB storage

All files access

Location

approximate location (network-based)

precise location (GPS and network-based)

Device ID & call information

read phone status and identity

Wi-Fi connection information

view Wi-Fi connections

Photos/Media/Files

read the contents of your USB storage

modify or delete the contents of your USB storage

Camera

take pictures and videos

Phone

read phone status and identity

Accessibility

In order to better optimize the memory usage and reduce repetitive operations, we needs Accessibility API to automatically force stop apps.

Other

bind to an accessibility service

update component usage statistics

receive data from Internet

notifications

full network access

close other apps

control vibration

measure app storage space

install shortcuts

view network connections

reorder running apps

draw over other apps

prevent device from sleeping

uninstall shortcuts

run at startup

connect and disconnect from Wi-Fi

5. Legal Basis of Your Personal Data

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our apps.

6. Your Rights

We provide you with the rights described below when you use our Services. Please contact us at phuongpham.20092000@gmail.com. if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

Where denial of access is required or authorized by law;

When granting access would have a negative impact on other's privacy;

To protect our rights and properties

Where the request is frivolous or burdensome.

I. Right to withdraw c­onsent

If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

II. Right of access and rectification

If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

IIII. Right to data portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

IV. Notification to third-parties

If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

V. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

VI. Right to lodge a complaint

If you believe we have infringed or violated your privacy rights, please contact us at phuongpham.20092000@gmail.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

7. Third-party Partners’ Privacy Policy

Here we list the links to the third-party partners’ privacy policy. Please note that these policies are governed by third-parties and we have no control over them. Check the following links to get details about how user data is collected, used and shared.

1. Firebase

https://firebase.google.com/support/privacy

2. Facebook Audience Network & Facebook Analytics

https://www.facebook.com/about/privacy

3. Applovin

https://www.applovin.com/privacy/

4. InMobi

https://www.inmobi.com/privacy-policy/

5. Pangle

https://ad.oceanengine.com/union/media/privacy

6. AdMob

https://policies.google.com/privacy?hl=en

7. Unity

https://unity3d.com/legal/privacy-policy

8. Google Analytics

https://policies.google.com/privacy?hl=en-US

8. California Residents’ Privacy Rights

We prepare this separate Privacy Notice for California Consumers to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.This notice is designed to supplement the information described in our Privacy Policy and applies solely to users who reside in the State of California (“consumers” or “you”).

IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY TO YOU. PLEASE REFER TO OUR MAIN PRIVACY NOTICE HERE INSTEAD.

I. Your Right to Request for Information

As required by CCPA, you( or your authorized agent) have the right to request us to disclose information to you about how we collect, use and share your personal information over the past 12 months.These information include: the categories of personal information we collected; the categories of sources for personal information we collected; our business purpose for collecting that personal information; the categories of third parties with whom we share that personal information.

II. Your Right to Delete Information

Under the CCPA, You( or your authorized agent) have the right to opt out of having your information sold or shared.You (or your agent)have the right to request that we delete your specific personal information that we collected from you and retained, except in the following cases Such cases include:

We need your information to detect security incidents, protect against malicious, or illegal activity;

We need your information to identify and repair application errors that impair existing intended functionality;We need your information to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

We need your information to conduct internal uses that are reasonably aligned with your expectations based on your relationship with us;and other cases provided by CCPA and other California laws.

III. How You Exercise Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by phuongpham.20092000@gmail.com

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for request for information twice within a 12-month period. A verifiable consumer request must:Provide sufficient information that allows us to reasonably verify you identity and make us confirm we collected personal information about you.Describe your request with sufficient details that allows us to understand and respond to it.

We cannot respond to your request accurately if we cannot verify your identity.

IV. How We Respond Your Request

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period by email ,telephone or other electronic means.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

V. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include: denying you our services; charging you different prices or rates for our services; providing you a different level or quality of our services; suggesting that you may receive a different price or rate for services or a different level or quality of services.

VI. Data collection instructions for minors

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are the parent or guardian of users who are aged 13~16, you can also contact us.

9. Children's Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

10. Changes to the Policy

Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.

11. Contact Us

If you have any questions or concerns about the Policy, you may contact us at email: phuongpham.20092000@gmail.com