LingoFly Privacy Policy

Welcome to LingoFly.

LingoFly is a multilingual learning product that combines short-video consumption, language learning, community interaction, and creator services. This LingoFly Privacy Policy (the "Policy") is issued by Shenzhen Bilingguo Technology Co., Ltd. ("we," "us," or "our") and applies to the Chinese and overseas versions of the LingoFly App, as well as related services we provide that expressly state that this Policy applies. Where different personal information processors, legal bases, cross-border mechanisms, age thresholds for minors, or response periods for rights apply in different countries or regions, we will provide regional supplemental terms before the relevant service is launched.

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 may exercise the related rights. Please read and fully understand this Policy carefully before using LingoFly, especially the provisions concerning sensitive personal information, personalized recommendations, third-party processing, account cancellation, your rights, and the protection of minors. We will draw your attention to content that materially affects your interests through bolding, contextual notices, or other prominent means.

You may use basic video browsing, playback, and search functions without registering or logging in. You may refuse to provide personal information that is not necessary for basic functions; doing so will not affect basic functions, but may make corresponding additional functions unavailable. For processing activities for which consent or separate consent is legally required, we will separately obtain your consent through an independent page, pop-up, or an option that is not preselected, using a clear affirmative confirmation action. Displaying a policy link, continuing to browse, or enabling a device permission does not by itself mean that you consent to other personal information processing activities.

If you do not agree to this Policy, please stop using functions that require the processing of the relevant personal information. For new processing purposes, methods, or categories of personal information introduced after an update to this Policy, we will not treat your continued use of the service alone as consent; where renewed consent is legally required, we will obtain it separately.

We follow the principles of lawfulness, propriety, necessity, and good faith, and process only personal information that matches the relevant function for the purposes described in this Policy.

1. Basic Browsing, Playback, and Search

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

We use the foregoing information for content loading, playback, search, resume playback, troubleshooting, security, and basic statistics. Guests may also use basic browsing, playback, and search functions; we will endeavor to process guest records using anonymous session identifiers.

Search history currently stores up to the 10 most recent entries, and you may clear it on the search page. Resume playback requires us to retain the video identifier, exit progress, and record time. If you do not wish to continue generating the relevant records, you may refrain from using additional capabilities such as search history and resume playback, or clear the records through the entry points provided in the product.

2. Registration, Login, and Account Security

We provide different login methods depending on the version you download and use: the Chinese version supports carrier one-tap login, WeChat login, and mobile-number login; the overseas version supports Google login and email login. The application version is determined by the download channel or app-store region and is not switched according to runtime IP address or system language.

If you choose to register or log in, we process the following information to create your account, verify your identity, maintain your login status, and protect account security:

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

For a new identity, we first complete identity verification and invitation-code verification, then create the account and bind the invitation relationship. Invitation codes are used for account creation, invitation attribution, one-time invitation rewards, and anti-cheating; invitation levels or upstream/downstream relationships are not displayed in the user interface.

We retain necessary login tokens on your device to maintain login status and enable silent login. You may skip login and enter the home page as a guest.

3. Profile, Follow Relationships, and Public Display

If you create or edit a profile, we process the avatar, nickname, account identifier, bio, default View (视界), following relationships, follower relationships, and visibility scope you set, in order to save and display the information you choose to provide.

Your avatar, nickname, account identifier, bio, public follow relationships, publicly posted content, and related interaction data may be displayed to other users. Your mobile number, email address, login credentials, LingoCoins balance, wallet balance, payment information, and invitation-attribution relationship will not be displayed as public profile information.

You may manage the visibility of certain relationships, blocked users, and the range of direct-message recipients in the privacy settings provided in the product. The specific settings available are subject to the pages in the version you use.

4. Content Posting, Drafts, and Content Governance

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

You may set content to public or visible only to yourself. Other users may browse, comment on, like, save, or share public content through the system share panel. Please do not publish personal information about yourself or others in public content if you do not want it to be public.

Up to 50 posting drafts may be retained, each for 30 days; you may delete them earlier. To save drafts, continue uploads, and handle network anomalies, we temporarily store drafts and upload status on the device or server side.

When you select a content label such as "contains real-person appearances," "AI-generated content," "contains virtual items," "derivative work," or "personal opinion," the applicable label name will be shown in the content playback layer as an "Author Statement." For AI-generated or synthetic content, we also process markings in the file related to generation or synthesis, statements you submit, necessary detection results, and dissemination markings, in order to add legally required explicit notices, write necessary implicit markings, and prevent malicious removal or tampering with such markings. Related records are retained only for the period necessary to fulfill content-labeling, governance, and audit obligations.

5. Other People Appearing in Content

Photos, videos, audio, text, comments, direct messages, or reporting materials that you upload may contain the likeness, voice, name, contact information, or other personal information of other users or individuals not registered with LingoFly. Before uploading or providing such information, you must have a lawful basis and respect the lawful rights and interests of the relevant persons.

If you find that your personal information appears in content provided by another user, you may contact us using the methods specified in this Policy to request access, correction, deletion, or to lodge a complaint. We will handle the request in light of the nature of the content, scope of disclosure, interests of both parties, and applicable law.

6. Community Interactions, Comments, Direct Messages, Reports, and Blocking

If you like, save, follow, comment, post, send a direct message, report, or block, we process the following information to carry out your action and maintain community safety:

Comments and the associated avatar and nickname may be public to other users. Direct messages are displayed only to users participating in the conversation. However, where necessary to protect safety, process reports, govern unlawful content, or resolve disputes, we may review or retrieve the relevant information through automated or manual means within the necessary scope.

The current community scope includes posts, comments, and one-to-one chats between language partners; it does not include discussions, group communities, or group-chat functions. If new processing activities are added later, we will update the corresponding notice and security measures before enabling the function.

7. Subtitles, Dictionary Lookup, Vocabulary Book, and Faye Learning Services

If you use subtitles, dictionary lookup, the vocabulary book, sentence-by-sentence shadowing practice, word shadowing practice, speech-to-text, or Faye intelligent analysis, we process the following information to provide the relevant learning functions:

Voice you actively submit and information that may reflect pronunciation characteristics are relatively sensitive information. We invoke the microphone and process the relevant voice only after you tap the recording, voice-input, or shadowing-practice button.

Shadowing-practice recordings are processed temporarily on a per-session basis: the device retains only the temporary recording for the current session and current sentence, and clears it when you close the shadowing panel, leave learning, switch videos, or re-record; the server processes original audio only for the time required to complete speech recognition or Faye scoring, and does not provide searchable recording history. After processing is completed, canceled, or finally fails, we delete the original audio and temporary copies created for retries. To demonstrate processing and deletion results, we may retain task identifiers that do not include audio content, processing time, and result logs. The processing rules of third-party voice service providers are described in the Third-Party Information Processing List and relevant contextual notices.

A temporary recording for a speech-to-text comment is deleted after you send the text or cancel input; what you send is confirmed text, not the temporary recording. Unless a page clearly states otherwise and obtains your consent, we will not use learning voice for training general-purpose speech models or creating a voiceprint identity template for you.

8. Personalized Content Recommendations

To help you discover more relevant content, we may generate recommendation results based on interests you actively select, the View you are in, viewing and search records, likes, saves, follows, comments, negative feedback, language-learning behavior, and content characteristics. We will prominently inform you that personalized recommendations are being used and explain the purpose, basic principles, and main operating mechanisms in an appropriate manner.

We will not use personalized recommendations to apply unreasonable differential treatment to you, nor will we present unreasonable differentiated transaction terms based on your ability to pay. You may select, modify, or delete recommendation tags, and turn off or reset personalized recommendations, in LingoFly's recommendation or privacy settings. After you turn them off, we will stop providing content recommendations based on personal characteristics and show content results not directed to personal characteristics.

In minor mode, we restrict interactions with strangers and voice comments, and reduce the scope in which minors' interaction behavior is used for social dissemination.

9. Membership, LingoCoins, Payments, and Transaction Records

If you purchase membership, top up LingoCoins, use LingoCoins to make a one-time purchase of learning capabilities, or tip, we process the following information to complete the transaction, grant entitlements, reconcile accounts, and handle disputes:

Payments are processed by the payment service providers identified on the purchase page according to the applicable region, application platform, and product type. We do not obtain or retain your third-party payment password, full bank-card number, or card security code. Payment service providers return account identifiers, order status, or masked information that is necessary to complete the transaction and reconciliation. The specific service providers, processing roles, and information categories are subject to the Third-Party Information Processing List.

Where a transaction result is unknown, timed out, or lacks a callback, we mark the order as "Processing" and verify it with the payment channel, restricting duplicate submissions until a final status is confirmed. To fulfill obligations relating to transactions, reconciliation, tax, audit, anti-money laundering, and dispute handling, some transaction facts may be retained as required by law after account deletion, with de-identification or pseudonymization measures.

10. Creator Wallets, Withdrawals, and Identity Verification

If an eligible creator views a wallet or applies for withdrawal, we process earnings, withdrawable balance, withdrawal amount, handling fee, collection channel, collection-account identifier and masked summary, withdrawal status, order ledger, tax status, and risk-verification results in order to display and settle earnings, verify identity, and fulfill tax and risk-control obligations.

For a first withdrawal, an account anomaly, or where laws and regulations require it, we may need to verify your real identity and receiving account, including your name, identity-document number, identity-document image, facial-recognition information, receiving account, and tax information required by law. This information may be sensitive personal information. Before processing, we will separately inform you of the necessity, processing method, and impact on your rights and interests, and obtain your separate consent.

Identity verification may be completed directly by a third-party authentication service provider. We process the identity information you submit only within the scope necessary to complete verification, and use measures such as encrypted transmission, access controls, and retention for the shortest period. Except where legally necessary, we do not independently retain identity-document images or facial images long-term; we may retain an authentication task identifier, authentication result, time, consent version, and necessary audit records. The specific provider, processing role, information categories, and retention rules are subject to the separate notice provided when the function is enabled and the Third-Party Information Processing List.

11. Customer Service, Feedback, Complaints, and Dispute Handling

If you contact us or submit feedback, a complaint, or an appeal, we process your account information, contact information, communications, relevant screenshots or screen recordings, order information, issue-handling records, and other supporting materials you actively provide in order to verify identity, identify the issue, respond to the request, and retain necessary processing evidence.

Please do not submit identity documents, bank cards, passwords, or other sensitive information unrelated to the issue in feedback.

12. Notifications

After you authorize notification permission, we may send you direct-message, comment, follow, order, withdrawal, review-result, security, and learning reminders. You may turn off the relevant notifications in your device system settings or LingoFly's notification settings. Necessary notices concerning account security, transaction results, or service changes may still be sent through in-app messages, email, or SMS.

13. Security, Troubleshooting, and Statistical Analysis

To protect account, content, transaction, and system security, diagnose failures, and conduct necessary statistics, we process device and application information, IP address, network status, operation logs, request identifiers, crash logs, API responses, login and transaction risk features, and cleansed usage events.

We endeavor to avoid recording content bodies, passwords, full mobile numbers, full email addresses, identity-document numbers, payment credentials, and other sensitive information in diagnostic logs. We also truncate free text such as search terms and filter sensitive patterns. Raw product-analytics events are retained for 180 days and are then deleted or aggregated into statistical results that cannot directly identify an individual.

We do not use algorithms or automated accounts to generate fake likes, comments, reposts, follows, ratings, transactions, or traffic. If we use operational or automated accounts to provide system notices, product guidance, learning assistance, or security reminders, we will mark them in an identifiable manner and isolate system behavior from counts of real-person interactions, rankings, recommendation weights, transactions, creator earnings, and invitation rewards. Related logs are used only for function fulfillment, security, risk control, and audit.

14. Exceptions to Obtaining Consent

To the extent permitted by applicable law, prior consent may not be required for the processing of personal information in the following circumstances:

We request device permissions only when you use the relevant function. You may withdraw authorization in your system settings. After withdrawal, the relevant function may be unavailable, but other functions that do not depend on that permission will not be affected.

The current version does not request precise location, contacts, call-log, or SMS-reading permissions for the purpose of providing basic functions. If related functions are added in the future, we will explain their purpose before invocation and update this Policy where necessary.

Connecting to the network, reading basic network status, and maintaining secure connections are system capabilities required to provide online services; they are not sensitive device permissions such as the camera or microphone that users enable individually. We will nevertheless process IP address, network type, request time, and error information in accordance with the principle of minimum necessity.

The LingoFly App uses necessary local storage to retain login tokens, language and subtitle settings, privacy settings, search history, drafts, cache, temporary media, message queues, and failed-retry status, in order to maintain login, improve loading speed, and ensure the integrity of operations. You may clear certain records through product entry points. Uninstalling the App will generally clear local device data, but will not automatically delete accounts and content already synchronized to our servers.

Our website or H5 pages use Cookies or similar technologies necessary to maintain login, protect security, return from payment, and save preferences. If we use analytics, advertising, or other non-essential Cookies, we will provide appropriate notice and choice mechanisms before use. You may also manage or clear Cookies through browser settings.

Third-party SDKs process device, network, account, or transaction information directly related to a disclosed function only when necessary to implement that function; they do not process information unrelated to the current function merely because the App starts. You may review the names of actually enabled service providers, processing roles, purposes and methods, information categories, trigger times, permissions, retention periods, data regions, and privacy-policy links in LingoFly's Third-Party Information Processing List.

1. Entrusted Processing and Provision to Third Parties

We do 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-tap-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. Where it is necessary to provide personal information to a third party that independently determines the purposes or methods of processing, we will inform you as required by law of the recipient's name and contact information, purposes and methods of processing, and categories of information, and obtain any necessary consent. The Third-Party Information Processing List distinguishes roles such as entrusted processors, joint processors, independent personal information processors, app stores, and payment channels.

We constrain entrusted parties through contracts, security assessments, permission controls, audits, and other measures, and require them to process information only according to our instructions. Where separate consent is legally required, we will obtain it separately.

2. Information You Publicly Disclose or Share

Personal profile information, videos, posts, comments, likes, or tipping-display information that you publicly publish will be disclosed to other users according to your actions and the visibility scope. When you share content to an external app through the system share panel, subsequent processing is governed by the rules of the third-party app you select; please choose the sharing recipient carefully.

3. Transfer

If a merger, division, reorganization, asset transfer, bankruptcy liquidation, or similar transaction involves a transfer of personal information, we will notify you of the recipient's name and contact information and require it to remain bound by this Policy. If the recipient changes the original purposes or methods of processing, it will obtain your consent again as required by law.

4. Public Disclosure

Except where you actively disclose information, where we lawfully carry out a platform-governance decision, or where laws and regulations provide otherwise, we will not publicly disclose your personal information. Where separate consent is legally required, we will obtain it before public disclosure.

We will identify third-party services actually enabled by LingoFly through a separate Third-Party Information Processing List. The list includes the provider's legal name, processing role, purposes and methods, categories of personal information, trigger scenarios, device permissions, retention period, data region, and privacy-policy link, and will be updated promptly according to actual integrations.

You may view this list in LingoFly's privacy settings or on the page where this Policy is displayed. Before using a function independently provided by a third party, please also read that third party's service rules and privacy policy. Where consent or separate consent is legally required, we will obtain it separately before processing begins.

We may use automated technology for content recommendations, content-safety review, account or transaction risk assessment, voice scoring, and learning feedback. If an automated decision materially affects your rights and interests, you have the right to ask us for an explanation and to refuse a decision made solely through automated decision-making; we will provide an appeal or human-review channel.

Faye may call the AI or voice services listed in the Third-Party Information Processing List to process words, sentences, text, voice, or contextual excerpts you actively submit. Before sending them, we remove account identifiers not needed to complete the task, and restrict providers by contract and technical measures from processing input beyond our instructions. Unless we give you a separate clear notice and obtain your consent as required by law, we will not allow providers to use your input for their general-model training or independent marketing. Provider name, processing role, whether it is used for model improvement, sub-processors, storage region, and retention period are subject to the Third-Party Information Processing List and relevant contextual notices.

AI-generated example sentences, analyses, and scores are for learning assistance only, may be inaccurate or incomplete, and do not constitute professional advice. Generative AI output will not be the sole basis for handling appeals, account bans, withdrawals, or matters materially affecting your rights and interests.

1. Storage Location

We determine the storage location of personal information based on the actual operating entity, production deployment, and applicable law. Information required by law to be stored domestically will be stored accordingly. If cross-border provision is necessary, we will complete applicable security assessments, personal-information protection certification, standard contracts, or other statutory procedures; inform you of the overseas recipient, purpose and method of processing, categories of information, retention period, and means of exercising rights; and obtain your separate consent where required.

Specific storage regions and overseas-recipient information are subject to the regional supplemental terms applicable where you are located and the Third-Party Information Processing List.

2. Retention Period

We retain personal information only for the shortest period necessary to achieve the processing purpose, unless laws and regulations require otherwise or you separately consent. Where a specific period can be determined, we follow the table below. Where it is difficult to determine a specific period, we determine it by the time needed to complete the relevant function, maintain accounts and content, protect security, fulfill legal obligations, and handle disputes, and delete or anonymize the information after the purpose is achieved.

After the retention period expires, we delete or anonymize personal information. If immediate deletion is technically difficult, we stop all processing other than storage and necessary security-protection measures.

3. Account Deactivation and Cancellation

After you initiate account cancellation, there is a 30-day recovery period. During that period, the account is deactivated; if you recover it using the original login method, the account and necessary data can be restored. When the recovery period expires, we start the final deletion process, release login identity and contact information, delete or anonymize deletable account and analytics data, and stop using it for routine product analytics. Temporary deactivation without entry into the final deletion process does not constitute completed 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. The content may continue to be retained within a limited scope only where laws and regulations expressly require retention, where necessary to handle another person's lawful rights and interests or a dispute, or where you actively choose during the deletion process to retain public content. If it continues to be publicly displayed, identifiable account information must be removed and it must be labeled "Cancelled Account User." Where the applicable region or app-store rules require deletion of associated user content, those rules prevail. Transaction, tax, audit, risk-control, unlawful-content evidence, and dispute-handling records may be retained in a restricted manner for statutory or necessary periods and will not be used for routine recommendations, marketing, or user profiling.

You may withdraw your cancellation request before the 30-day recovery period expires. You may submit a request through LingoFly's Account & Security or Cancel Account entry. Where law or app-store rules require an off-platform entry point, we will also provide a public entry point on the official website or the page where this Policy is displayed.

We adopt technical and management measures proportionate to risk, including access control, least privilege, encrypted transmission, encryption or hashing of sensitive fields, log desensitization, environment isolation, backup and recovery, security monitoring, vendor management, and employee confidentiality management.

Internet services are not absolutely secure. Please keep your account, verification codes, and password safe and do not disclose them to others. If you discover abnormal use of your account, please contact us promptly.

If a personal-information security incident occurs, we will immediately take remedial measures and report it to the competent authorities as required by applicable law. If the incident may harm your rights and interests, we will notify you through the App, SMS, email, announcement, or other means of the basic circumstances, possible impact, measures taken, preventive measures you may take, and our contact information.

Within the scope provided by applicable law, you have rights to be informed, make decisions, restrict or refuse processing, access, copy, correct, supplement, delete, withdraw consent, cancel your account, request an explanation of automated decisions, and request data portability in relation to your personal information.

You may exercise certain rights in the following ways:

To protect account security, we may first verify your identity. We will respond within the period provided by applicable law; where the law does not provide a shorter period, we will respond within 15 working days. If a request is complex, numerous, or may lawfully be extended, we will explain the reason for the extension. We may lawfully refuse requests that are groundlessly repetitive, exceed reasonable limits, infringe others' rights and interests, or may be refused under law, and will explain the reason.

Withdrawal of consent does not affect processing activities already carried out based on consent before its withdrawal. Deletion of particular information may make functions that depend on that information unavailable.

LingoFly is not a product specifically designed for children under the age of 14. If you are a child under 14, please use functions that require personal information under a guardian's guidance after the guardian has read and agreed to this Policy and the dedicated children's personal-information protection rules. Before the children's personal-information protection rules, guardian-consent mechanism, and age-identification mechanism are formally launched, users under 14 should not independently register an account or use functions that require submitting personal information.

If you are at least 14 but under 18, please read and use this service under a guardian's guidance, and use posting, direct-message, top-up, membership, one-time-purchase, tipping, withdrawal, and other paid or high-risk functions prudently. Minor mode restricts stranger interactions and voice comments. All paid activities must also comply with applicable law, platform rules, and guardian-authorization requirements.

If we discover that we processed a child's personal information without valid guardian consent, we will stop the relevant processing after verification and delete or anonymize it as required by law. A guardian may contact us using the methods listed in this Policy to request access, correction, or deletion of the ward's personal information.

Age thresholds and guardian-consent requirements for minors using the overseas version must also comply with the law where the user is located. We will supplement the relevant regional rules before launching in a specific target market.

If you use LingoFly outside China, you may also have rights under the law where you are located to access, correct, delete, restrict processing, object to processing, data portability, withdraw consent, lodge a complaint with a supervisory authority, or opt out of the sale, sharing, or targeted advertising of personal information.

Before formally entering a particular country or region, we will provide applicable regional supplemental terms according to the target market, operating entity, server region, third-party services, and local law. At a minimum, regional supplemental terms will explain the local personal information processor or representative, legal bases for processing, sensitive-information and minors' rules, cross-border transfer mechanisms, retention periods, scope of rights and response periods, supervisory authority, and complaint method. If regional supplemental terms conflict with this Policy, the provision applicable in that region and providing more specific protection prevails. Before supplemental terms are completed, this Section's general statements do not replace information that must be provided under local law.

We may update this Policy due to changes in functions, processing activities, laws and regulations, or regulatory requirements. If a material change occurs, we will notify you prominently through App pop-ups, in-app messages, push notifications, email, announcements, or other means, and provide a reasonable period to read it.

Material changes include substantial changes to processing purposes, methods, or categories of personal information; the addition of sensitive-personal-information processing; a change in recipients of personal-information sharing, transfer, or public disclosure; material changes to your rights or the way you exercise them; or a material change in personal-information security risks.

Where consent or separate consent is legally required, we will obtain your consent again before the relevant processing begins. You may view the current and historical versions on this page.

If you have questions, comments, complaints, or appeals regarding this Policy, personal-information processing activities, or your rights, you may contact us in the following ways:

We will verify your identity and handle your request within the period provided by applicable law. If you are dissatisfied with the outcome, you may complain to the competent authorities for personal-information protection, cyberspace administration, consumer-rights protection, or other matters, or seek other remedies in accordance with law.