PRIVACY POLICY

1. Introduction

This Privacy Policy ("Privacy Policy") describes how Dao Thuong ("we," "us," "our") collects, uses, stores, shares, and protects your personal data when you use Pocket English Daily (the "App"). This Privacy Policy also explains your rights regarding your personal data and how you can exercise them.

When we refer to "personal data" (or "personal information"), we mean any information relating to you as an identified or identifiable natural person. This includes information that can identify you directly or indirectly, such as by reference to a device identifier, IP address, or one or more factors specific to your physical, physiological, economic, cultural, or social identity.

This Privacy Policy applies to all users of the App, including free and premium subscribers.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE APP.

2. Who We Are

In this Privacy Policy, "we," "our," "us," and "Dao Thuong" refer to Dao Thuong, located at Trieu Dong, Thuong Phuc, Thuong Tin, Ha Noi, Viet Nam.

We act as the Data Controller for the personal data we process through the App. We are committed to protecting user privacy in compliance with:

The EU General Data Protection Regulation (GDPR)
The California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA)
The Virginia Consumer Data Protection Act (VCDPA)
The Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and other applicable US state privacy laws including those effective in 2025–2026 (Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and others as enacted)
The Children’s Online Privacy Protection Act (COPPA)
Apple’s App Store Review Guidelines and App Tracking Transparency (ATT) framework
Google Play Developer Program Policies, including the Data Safety Section requirements
Any other applicable data protection and privacy laws in the jurisdictions where our users are located

We are guided by the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

If you have any questions about this Privacy Policy, please contact us using the details in Section 17 below.

3. What Personal Data We Collect

We collect and process the following categories of personal data:

3.1. Data You Provide Directly

If you create an account or contact us, we may collect:

Account registration data: email address, username, password (stored in hashed form)
Profile information: display name, language preference, learning level
Communications: messages, feedback, or support requests you send us
Subscription and purchase data: records of in-app purchases and subscription status (payment processing is handled by Apple’s App Store or Google Play; we do not collect or store your credit card number, bank account details, or other financial payment information directly)

3.2. Data Collected Automatically

When you use the App, certain information is collected automatically through our systems and third-party SDKs:

Device information: device type, model, operating system and version, screen resolution, device language and region settings
Device identifiers: Identity for Advertisers (IDFA) on iOS (subject to your ATT consent), Advertising ID (Google Ad ID) on Android, and app-set identifiers
Network information: IP address, connection type (Wi-Fi, cellular), carrier name
App usage data: pages or articles viewed, features used, reading and listening time, session duration, frequency of use, in-app navigation patterns
Log data: crash logs, error reports, performance data, diagnostic information
Location data: coarse location derived from IP address (we do not collect precise GPS location)

3.3. Data Collected by Third-Party SDKs

Our App integrates third-party software development kits (SDKs) for advertising, analytics, and functionality. These SDKs may independently collect data as described below. We list all major third-party SDKs and their purposes:

[Ad Network, e.g., Google AdMob] — serving and personalizing ads; collects IP address, device identifiers, user interactions, and diagnostic data
[Ad Network, e.g., Meta Audience Network] — serving targeted ads; collects device identifiers and usage interaction data
[Analytics Provider, e.g., Firebase Analytics / Google Analytics for Firebase] — app analytics and performance monitoring; collects device info, usage events, crash data
[Attribution Provider, e.g., Adjust, AppsFlyer] — ad attribution and campaign measurement; collects device identifiers and referral data
[Other SDKs as applicable — update this list to match your actual integrations]

Important: You should review the privacy policies of each third-party SDK provider to understand how they process your data. We require that all third-party partners provide at least the same level of data protection described in this Privacy Policy.

4. Legal Bases for Processing

We process your personal data based on the following legal grounds:

Consent: For personalized advertising and cross-app tracking (including through Apple’s ATT framework and Android advertising preferences), for marketing communications, and for processing any sensitive personal information.
Performance of a Contract: To provide the App’s services including content delivery, account management, and subscription fulfillment.
Legitimate Interest: To improve the App, analyze usage trends, ensure security, prevent fraud, and provide non-personalized contextual advertising. Our legitimate interest does not automatically override your interests, and we conduct balancing tests where required.
Legal Obligation: To comply with applicable laws, regulations, court orders, or legal processes.

5. How We Use Your Personal Data

We use your personal data for the following purposes:

Service Delivery: To provide, maintain, and improve the App’s features, including English learning content (articles, audio), personalized content recommendations, and progress tracking.
Subscription and Purchase Management: To manage your premium subscription, process upgrades or downgrades, verify purchase status, and provide access to premium features.
Advertising: To display advertisements within the App. Depending on your consent choices, ads may be personalized (interest-based/behavioral) or non-personalized (contextual). See Section 8 for details.
Analytics and Improvement: To understand user behavior, detect technical issues, measure App performance, and improve user experience.
Communications: To send you service-related notifications (e.g., subscription renewal reminders, content updates) and, with your consent, marketing communications such as newsletters or promotional offers.
Security and Fraud Prevention: To detect, prevent, and investigate fraud, security breaches, or potentially prohibited or illegal activities.
Legal Compliance: To comply with applicable laws and respond to lawful government requests.

If we intend to use your personal data for a new purpose not covered by this Privacy Policy, we will update this policy and, where required, obtain your consent before doing so.

6. In-App Purchases and Subscriptions

The App offers premium features available through in-app subscription purchases. Here is what you need to know:

Payment Processing: All payments are processed through Apple’s App Store (via Apple In-App Purchase) or Google Play (via Google Play Billing). We do not directly collect, process, or store your payment card information, bank details, or other financial account data.
Subscription Data We Receive: We receive confirmation of your purchase, subscription type, subscription status (active, expired, cancelled), transaction ID, and purchase date from the platform provider.
Auto-Renewal: Subscriptions automatically renew unless cancelled at least 24 hours before the end of the current billing period. You can manage or cancel your subscription through your device’s App Store or Google Play Store settings.
Free Trial: If a free trial is offered, any unused portion of the trial period will be forfeited when you purchase a subscription.
Refunds: Refund requests are handled by Apple or Google in accordance with their respective refund policies.

For details on subscription pricing and terms, please refer to the subscription page within the App and our Terms of Use.

7. Sharing of Your Personal Data

We do not sell your personal data. However, under certain US state privacy laws (such as CPRA), the sharing of data with advertising partners for personalized advertising may be classified as "sharing" or "selling." You have the right to opt out of this type of sharing (see Section 12).

We may share your personal data with the following categories of recipients:

Advertising Partners: Ad networks and demand-side platforms that serve ads in the App (e.g., Google AdMob, Meta Audience Network). Data shared may include device identifiers, IP address, and usage data for the purpose of serving and measuring ads.
Analytics Providers: Services such as Firebase Analytics that help us understand App usage and performance. Data shared includes anonymized or pseudonymized usage and device data.
Cloud Hosting and Infrastructure: Hosting providers that store App data on our behalf (e.g., [AWS / Google Cloud / Azure]).
Attribution and Measurement Partners: Services that help us measure the effectiveness of advertising campaigns.
Legal and Regulatory Authorities: When required by law, court order, subpoena, or government request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your data may be transferred to the successor entity. We will notify you via in-app notice and/or email of any such change.

All third parties with whom we share data are contractually required to provide the same or equivalent level of data protection as described in this Privacy Policy.

8. Advertising

The App displays advertisements to support the free version of our service. This section explains how advertising works in the App.

8.1. Types of Ads

Personalized Ads: Ads tailored to your interests based on your usage patterns, device information, and data collected by our advertising partners. Personalized ads are only shown if you have provided consent.
Non-Personalized (Contextual) Ads: Ads based on the content you are currently viewing rather than your personal profile. These are shown if you decline personalized advertising or have not provided consent.

8.2. Ad SDKs and Data Collection

Our advertising partners’ SDKs may collect device identifiers, IP addresses, interaction data, and diagnostic information for ad serving, frequency capping, fraud prevention, and measurement. Please review the privacy policies of our ad partners:

[Google AdMob Privacy Policy: https://policies.google.com/privacy]
[Meta Audience Network: https://www.facebook.com/privacy/policy/]
[Add other ad network links as applicable]

8.3. How to Opt Out of Personalized Ads

On iOS: When prompted by the App Tracking Transparency (ATT) dialog, select "Ask App Not to Track." You can also go to Settings > Privacy & Security > Tracking to manage app tracking permissions.
On Android: Go to Settings > Google > Ads > "Delete advertising ID" or toggle "Opt out of Ads Personalization."
Premium Subscription: Premium subscribers may enjoy an ad-free experience, depending on the subscription tier.

9. App Tracking Transparency (iOS)

On iOS devices, we comply with Apple’s App Tracking Transparency (ATT) framework. Before tracking your activity across other companies’ apps and websites, we will display a system permission prompt requesting your consent.

If you allow tracking, we and our advertising partners may use your IDFA and other identifiers to provide personalized ads and measure ad effectiveness.
If you choose "Ask App Not to Track," your IDFA will not be available to us, and we will only serve non-personalized, contextual ads. Your ability to use the App is not affected by your tracking choice.

We do not use fingerprinting or any other means to track users who have opted out of tracking.

10. International Data Transfers

We operate internationally and may transfer your personal data to countries outside your country of residence, including the United States. These countries may have data protection laws that differ from those in your jurisdiction.

When transferring personal data from the European Economic Area (EEA), the United Kingdom, or Switzerland, we rely on:

The EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. Data Privacy Framework, where applicable
Standard Contractual Clauses (SCCs) approved by the European Commission
Other legally recognized transfer mechanisms as appropriate

We ensure that any third party receiving personal data provides adequate protection in accordance with applicable data protection laws.

11. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations. Specific retention periods are as follows:

Account Data: Retained for as long as your account is active, and for up to [30 days / 90 days] after account deletion to allow for account recovery or dispute resolution.
Usage and Analytics Data: Retained in identifiable form for up to [12 / 24] months, then aggregated or anonymized.
Subscription and Purchase Records: Retained for as long as required by applicable tax and accounting laws (typically [5–7 years]).
Advertising Data: Retained by our advertising partners in accordance with their respective retention policies.
Security and Fraud Prevention Data: Retained for up to [12 / 24] months or as required for legal proceedings.

After the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you.

12. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

12.1. Rights Under GDPR (EEA/UK Users)

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure: Request deletion of your personal data.
Right to Restrict Processing: Request that we limit how we use your data.
Right to Data Portability: Receive your data in a structured, machine-readable format.
Right to Object: Object to processing based on legitimate interest or for direct marketing.
Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint: File a complaint with your local data protection supervisory authority.

12.2. Rights Under CCPA/CPRA (California Residents)

Right to Know: Request the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
Right to Delete: Request deletion of your personal information.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt Out of Sale/Sharing: Direct us to stop selling or sharing your personal information for cross-context behavioral advertising. You may exercise this right via our "Do Not Sell or Share My Personal Information" link within the App or by contacting us.
Right to Limit Use of Sensitive Personal Information: Direct us to limit the use of your sensitive personal information to only what is necessary to provide the service.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

12.3. Rights Under Other US State Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, or other states with comprehensive privacy laws, you may have similar rights including the right to access, correct, delete, and port your data, as well as the right to opt out of targeted advertising, sale of personal data, and profiling. Please contact us to exercise these rights.

You or your authorized agent may submit a verifiable consumer request by contacting us using the information in Section 17. We will verify your identity before fulfilling your request and respond within the timeframes required by applicable law.

13. Account Deletion

If you have created an account in the App, you have the right to request deletion of your account and associated personal data. You may do so:

In the App: Go to Settings > Account > Delete Account. Follow the on-screen prompts to confirm deletion.
By contacting us: Send a request to thuongdaovan@gmail.com with the subject line "Account Deletion Request."

When you delete your account:

Your account record and associated personal data will be permanently deleted within [30] days.
If you have an active subscription, please cancel it through your device’s App Store or Google Play Store settings before requesting account deletion. Deleting your account does not automatically cancel your subscription.
Certain data may be retained as required by law (e.g., transaction records for tax or accounting purposes) or for fraud prevention, but will be isolated and protected.
Anonymized or aggregated data that can no longer identify you may be retained.

14. Children’s Privacy

Our App is not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If your App is available to users between 13 and 17, parental or guardian consent may be required depending on your jurisdiction.

If you are a parent or guardian and believe that your child has provided personal data to us without your consent, please contact us immediately at thuongdaovan@gmail.com. We will take steps to delete such information as promptly as possible.

We comply with COPPA, GDPR age-of-consent requirements, and applicable US state laws regarding children’s data, including the App Store Accountability laws enacted in Texas (effective January 2026), Utah, Louisiana, and other states.

Our App does not serve personalized advertisements to users identified as minors.

15. Data Security

We take the security of your personal data seriously and implement appropriate technical and organizational measures, including:

Encryption of personal data in transit using TLS/HTTPS
Encryption of sensitive data at rest
Hashing of passwords using industry-standard algorithms
Access controls limiting data access to authorized personnel
Regular security assessments and vulnerability testing
Incident response procedures for data breaches

Despite our efforts, no method of electronic transmission or storage is completely secure. In the event of a data breach that compromises your personal data, we will notify you and the relevant authorities in compliance with applicable laws.

16. Push Notifications

We may send you push notifications to inform you about new content, daily learning reminders, subscription updates, or promotional offers related to the App.

You can manage or disable push notifications at any time through your device’s notification settings (Settings > Notifications > Pocket English Daily on both iOS and Android).

17. Data Safety and Privacy Nutrition Labels

In compliance with Google Play’s Data Safety Section requirements and Apple’s App Privacy Details (Privacy Nutrition Labels), we disclose our data collection and sharing practices directly on our store listings. The information in this Privacy Policy is consistent with the disclosures made in our Data Safety form (Google Play) and Privacy Nutrition Labels (Apple App Store).

If you notice any discrepancy between this Privacy Policy and the information on our store listing, please contact us so we can resolve it.

18. Automated Decision-Making and Profiling

The App may use automated processing of your data, including profiling, to recommend content based on your reading level and interests, and to serve relevant advertisements. You have the right to object to automated processing, including profiling, where it produces legal effects or similarly significant effects concerning you. To exercise this right, please contact us using the details in Section 20.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

We will post the updated policy within the App and on our website.
We will update the "Last Updated" date at the top of this policy.
For significant changes, we will provide at least 30 days’ advance notice via in-app notification, push notification, or email before the changes take effect.
Where required by law, we will obtain your renewed consent.

Your continued use of the App after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree, you should stop using the App and delete your account.

20. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Email: thuongdaovan@gmail.com

Mailing Address: Dao Thuong, Trieu Dong, Thuong Phuc, Thuong Tin, Ha Noi, Viet Nam.

For GDPR-related inquiries, you may also contact our Data Protection Officer at thuongdaovan@gmail.com (if applicable).

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.