GoSpeak-AI companion language learning platform user privacy policy

Update and effective date of this agreement: March 1, 2026

This "GoSpeak-AI Companion Language Learning Platform User Privacy Policy" (hereinafter referred to as "this policy") applies to the services provided by the "GoSpeak-AI Companion Language Learning Platform" App product (hereinafter referred to as the "App" or "Product") released by Shenzhen Octopus Times Technology Development Co., Ltd. (hereinafter referred to as the "Company"), except for other third-party products or services you access through the product or access. Please be sure to read carefully and fully understand the contents of each clause before clicking to agree to this policy, especially the clauses exempting or limiting liability, legal application and dispute resolution clauses. Terms disclaiming or limiting liability will be marked in bold and you should read them carefully. If you have any questions about this policy, you can contact Shenzhen Octopus Times Technology Co., Ltd. according to the contact information listed in this policy.

When you click to confirm and agree to this policy, it means that you have fully read, understood and accepted all the contents of this policy, and have reached an agreement with the company. This policy is legally binding on you and the company.

1. Collection and use of personal information

(1) Collection of necessary information

Account related information:When you register and log in, you need to provide your mobile phone number for verification, or log in through third-party accounts such as WeChat and QQ. We only obtain the nickname and avatar of the third-party account for account identification, and do not obtain other private information. This type of information is the basis for ensuring your normal use of your account and related services.

Basic equipment information:Automatically collect your device model, operating system version, device unique identifier (such as OAID, IDFA), IP address, network type, etc. to ensure the stability of the APP operation, adapt to different devices, and prevent account theft and other security risks.

(2) Special information collection on AI English learning scenarios

Voice related data:When you use AI spoken dialogue, follow-up and other functions, you need to authorize microphone permission, and we will collect your voice data. Voice data is only used for real-time AI recognition and transcription, pronunciation error correction, and dialogue matching. Voice clips can be cached locally for repeated listening and review. You can manually clear the cache. Raw voice data will not be used for any purpose other than this Agreement.

On-site behavioral data:Daily data (main scene dialogue, bilingual chat, practical exercises), learning data (vocabulary book, daily sentence, diary).

(3) Information use restrictions

All collected information will only be used to provide and optimize English accompanying learning services. If learning data needs to be used for market research or product development, the data will be anonymized to ensure that specific users cannot be identified.

If we push you learning-related promotions, new course notifications and other information, we will provide you with a clear unsubscribe entry, and you can turn off such push at any time.

2. Special instructions for AI data processing

The AI interactive function of this APP relies on the technical support provided by [Microsoft, Huoshan AI, Alibaba Qianwen, etc.], and we only transmit to it the necessary data such as voice and text required to implement the function. Both parties have signed a confidentiality agreement, and third-party service providers are not allowed to use your data for their own business or disclose it to other entities.

AI processing processes such as speech recognition and text analysis are first completed locally on your device. If cloud processing is really required, encryption technology is used during the transmission process. After the processing is completed, only the necessary structured learning data is retained. The original voice and text data are automatically deleted or anonymized after the service is completed.

This APP will not use your learning data to train a general AI model. It will only be used to optimize the AI interaction effect of this APP's exclusive English learning scenario, and the data will be desensitized during the optimization process.

3. Information storage and security

Your personal information and learning data are stored in compliance servers in China, and the storage period is while you are using this APP and for 15 working days after your account is canceled. After the account is canceled, all data will be completely deleted or anonymized, except for information that is required to be retained by law.

Measures such as HTTPS encrypted transmission, data access permission control, regular security vulnerability scanning, and data backup are adopted to protect information security. If a security incident such as an information leak occurs, we will immediately activate an emergency plan, take remedial measures, and promptly notify you through APP pop-ups, text messages, etc.

Implement strict information confidentiality management for employees and partners, and only authorize relevant personnel to access user data within the necessary scope. Anyone who leaks information in violation of regulations will bear legal responsibility.

4. Sharing, transfer and disclosure of information

We strictly follow the principles of "minimum necessity, legal compliance, and express consent" and implement strict control over the sharing, transfer, and disclosure of your personal information. Your personal information will never be disclosed, shared or transferred to any third party unless in compliance with this agreement or legal requirements.

(1) Information sharing rules

1. Sharing restrictions and prerequisites

In principle, we will not share your personal information (including voice data, learning records, account information, etc.) with any third party. Limited sharing will only occur if all of the following conditions are met:

In order to realize the core service functions of this APP (such as payment, AI voice processing, etc.), and there is no other alternative;
Only share the minimum scope of information necessary to implement the function, and do not provide additional irrelevant personal information;
A legally binding "Data Security and Confidentiality Agreement" has been signed with a third party, clearly stipulating the scope, duration and security obligations of its information use. Require third parties not to use the shared information for any purpose other than this agreement, and not to share it with other parties;
If the sharing of sensitive personal information (such as voice data, mobile phone number) is involved, your express consent has been obtained separately (such as a pop-up window to confirm), and you have the right to withdraw this consent at any time.

2. Specific sharing scenarios and instructions

[Payment Service Sharing]:When you use paid functions such as recharging and purchasing courses, you need to connect to third-party payment platforms such as Alipay and WeChat Pay. We only share necessary transaction information with the payment platform, including transaction amount, order number, payment account identification (such as Alipay user ID, WeChat ID), and do not share your bank card number, payment password, learning data and other private information. The information processing rules of the payment platform follow its own privacy policy, and we will supervise its fulfillment of confidentiality obligations.

[AI technology service sharing]:The AI spoken language recognition, pronunciation correction, dialogue interaction and other functions of this APP may rely on the technical support provided by third-party AI service providers (Microsoft, Huoshan AI, Alibaba Qianwen). We only transmit necessary data such as voice clips and text content required to implement functions, and the transmission process uses end-to-end encryption technology to ensure security. Third-party AI service providers can only use the received data for real-time processing (such as speech transcription, grammar analysis), and may not store original speech or text data, nor use it for training general AI models or other commercial purposes. The two parties have clarified these restrictions through an agreement.

[Compliance Audit and Supervision Sharing]:In order to respond to compliance inspections and audit requirements of regulatory authorities, or to meet industry self-regulatory regulations, we may share necessary information with relevant regulatory agencies and audit institutions, but will require them to comply with confidentiality obligations and only use it for compliance review purposes.

[Advertising and Operations Analytics Service Sharing]：To conduct ad delivery, ad attribution, ad performance monitoring, anti-fraud, operational statistical analysis, and product experience optimization, we may integrate third-party SDKs or services such as Ocean Engine and Volcano Engine. The relevant service providers may collect necessary information such as device information, device identifiers, network information, app usage logs, and ad impression/click/conversion data. We will require the relevant service providers to process personal information in accordance with the principles of legality, legitimacy, and necessity, not to use it beyond the agreed purposes, and not to use it for purposes unrelated to this service.

(2) Information collection and sharing instructions embedded in the SDK

In order to ensure the stable operation of the APP and optimize the service experience, this APP will embed a small number of third-party SDKs (software development kits) that have undergone strict compliance audits. The information collection and sharing rules for relevant SDKs are as follows:

1. SDK list and core information

We have organized all embedded third-party SDKs into a "Third-Party SDK Usage Checklist", which clearly lists the following information:

(1) SDK name: WeChat OpenSDK Android

Developer:Shenzhen Tencent Computer Systems Co., Ltd.

Purpose of use:Used for registration authentication and helping users use WeChat Pay within the app

Types of information collected:Imei, imsi, mac, conversationAccount, device model, operating system, unique device identifier (such as Android ID/OAID on Android, IDFA before iOS 14.5 on iOS), login IP address, WeChat software version number, WeChat nickname, WeChat avatar, network access method, type and status, network quality data, device accelerator (such as gravity sensing device), operation log, service log information

Privacy Policy Link:https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8

(2) SDK name: APP payment client SDK

Developer:Alipay (Hangzhou) Information Technology Co., Ltd.

Purpose of use:Help users use Alipay to pay within the app

Types of information collected:System unique identifier, external storage status, network type, device model, device manufacturer, SIM card serial number, IMEI, imsi, MAC address, ANDROID_ID, IP address, WiFi information, application installation list, OpenUDID, used for payment-related services, including order payment, transaction behavior verification, income settlement, payment information summary statistics, software version, service log information

Privacy Policy Link:https://opendocs.alipay.com/open/54/01g6qm#%E6%94%AF%E4%BB%98%E5%AE%9D%20App%20%E6%94%AF%E4%BB%98%E5%AE%A2%E6%88%B7%E7%AB%AF%20SDK%20%E9%9A%90%E7%A7%81%E6%94%BF%E7%AD%96

(3) SDK name: Number authentication

Developer:China Mobile Internet Co., Ltd.

Purpose of use:Used to realize one-click login/number authentication service with mobile phone number

Types of information collected:Mobile phone number (identification information returned after operator authentication), device information, network information, application log information (necessary information for the purpose of one-click login/number authentication)

Privacy Policy Link:https://wap.cmpassport.com/resources/html/contract2.html

(4) SDK name: Growth Marketing Kit SDK

Developer:Beijing Volcano Engine Technology Co., Ltd.

Purpose of use:Used for statistical analysis of user behavior, fault diagnosis and operational effect evaluation to optimize product experience

Types of information collected:Device information, device identifiers (such as OAID/Android ID, etc.), network information, application usage/behavior log information

Privacy Policy Link:https://www.volcengine.com/docs/84129/1261812

(5) SDK name: JiVerify Identity One-click login/number authentication SDK

Developer:Wuhan Jiyi Network Technology Co., Ltd.

Purpose of use:Used to achieve one-click login/number authentication capabilities and improve login security and efficiency

Types of information collected:Mobile phone number (identification information returned by operator authentication), device information, network information, application log information (necessary information for the purpose of authentication)

Privacy Policy Link:https://www.geetest.com/Private

(6) SDK name: China Unicom Certification SDK

Developer:Unicom Online Information Technology Co., Ltd.

Purpose of use:Used to implement one-click login/number authentication service for China Unicom mobile phone number

Privacy Policy Link:https://msv6.wosms.cn/html/oauth/protocol2.html

(7) SDK name: Voice Evaluation SDK

Developer:Suzhou Chisheng Information Technology Co., Ltd.

Purpose of use:Used to implement voice assessment functions, including voice recognition, score analysis and result feedback, to improve the voice interaction experience and assessment accuracy of applications.

Types of information collected:Device audio data (voice input), device model, operating system version, network type (Wi-Fi/mobile network), SDK running log information, application package name and version number, device language setting

Privacy Policy Link:https://www.chivox.com/privacyPage/chivoxIndex.html

(8) SDK name: Microsoft Azure Voice Assessment

Privacy Policy Link:https://privacy.microsoft.com/zh-cn/privacystatement

(9) SDK Name: Ocean Engine SDK

Developer: Beijing Ocean Engine Network Technology Co., Ltd.

Purpose of Use: Used for ad delivery, ad attribution, ad performance monitoring, user behavior statistical analysis, anti-fraud, fault diagnosis, and operational effectiveness evaluation, helping us optimize product experience and advertising display performance.

Types of Information Collected: Device brand, device model, operating system version, system language, application package name and version number, device identifiers (such as OAID, Android ID, IDFA, IDFV, subject to system authorization and the actual collection by the SDK), IP address, network type, carrier information, sensor information, screen size, device time zone, application usage logs, ad display/click/conversion data, crash logs, and performance data.

Privacy Policy Link:https://www.oceanengine.com/extra/legal

2. SDK usage compliance guarantee

All embedded SDKs have been upgraded to the latest versions that comply with national regulatory requirements, and unnecessary information collection fields have been eliminated (for example, sensitive device information such as IMEI and IMSI will no longer be collected);
We will regularly review the compliance qualifications and data security capabilities of SDK service providers, and require them to submit data security compliance reports. If we find that the SDK has problems such as illegal collection of information, security vulnerabilities, etc., we will immediately suspend access and urge rectification;
The SDK will only initialize and collect information when you use the corresponding functions (such as payment, voice practice, number verification, etc.).

(3) Information transfer rules

We will not actively transfer your personal information to any third party.

Your personal information can only be transferred when the following statutory or agreed circumstances occur, and the transfer process must comply with Article 22 of the "Personal Information Protection Law":

Situations such as company merger, division, dissolution, declaration of bankruptcy, etc. that lead to changes in subject qualifications;
Before the transfer, you have been fully informed of the name, contact information, privacy protection responsibilities and other information of the recipient, and your express consent has been obtained (unless otherwise provided by law);
Sign a "Personal Information Protection Responsibility Transfer Agreement" with the recipient, clearly agreeing that the recipient must continue to perform its privacy protection obligations under this agreement, and its privacy protection standards shall not be lower than those agreed in this agreement;
If the recipient is an overseas entity, it must comply with relevant regulations such as personal information export security assessment to ensure that your information is protected at the same level overseas.

(4) Information disclosure rules

We will only disclose your personal information under the following legal circumstances, and the scope of disclosure is strictly limited to the minimum scope required by law:

Receipt of legal requisition notices, rulings or decisions issued by judicial agencies and administrative agencies (such as courts, procuratorates, public security departments, regulatory agencies);
In order to protect your or other natural persons' rights to life, body, health and other major legitimate rights and interests, your consent cannot be obtained in time in an emergency;
To safeguard public interests (such as responding to public health events, investigating illegal and criminal activities), and the disclosure of information is necessary and reasonable;
Personal information that you publicly disclose on your own (such as learning content posted in the APP public community), but we will reasonably protect the parts involving sensitive information;
Other circumstances that should be disclosed as stipulated by laws and administrative regulations.

(5) Exceptions

Information sharing, transfer, and disclosure under the following circumstances do not require your consent, and we do not assume relevant responsibilities:

The information shared, transferred, and disclosed has been anonymized and de-identified so that the specific natural person cannot be identified and cannot be reversely restored;
Information obtained by third parties from public channels on their own, and the acquisition does not violate laws, regulations and this Agreement;
Necessary disclosures to comply with legal obligations, respond to public health events, protect public interests or the legitimate rights and interests of others.

5. User’s rights

According to the "Personal Information Protection Law of the People's Republic of China", "Cybersecurity Law" and other relevant laws and regulations, you, as the subject of personal information, have the right to inquire, correct, supplement, delete, withdraw consent, cancel your account, complain and report your personal information and learning data in accordance with the law. We provide you with a convenient and clear path to exercise your rights to ensure that your legitimate rights and interests are fully protected.

(1) Right to information inquiry

You have the right to query all personal information and learning data related to you collected, stored and used by this APP at any time. The query scope and operation path are as follows:

Basic personal information: including account nickname, mobile phone number, avatar, bound third-party account information, etc., which can be viewed directly through the APP "Personal Page";
Learning-related data: including planet recovery progress, daily signals, word folders, diaries, study reports, outfits and my files, etc., can be viewed through the APP personal page;
Written inquiry application: If you need to obtain a more detailed information list (such as complete information storage logs, data processing records), you can submit a written inquiry application through the customer service email. You need to provide your account number and identity proof materials (such as mobile phone number verification code, real-name authentication information), and we will feedback the query results to you via email within 15 working days.

(2) Right to information correction and supplementation

When you find that your personal information is incorrect or incomplete, you have the right to apply for correction or supplementation. The specific methods are as follows:

Self-correction: Basic personal information (such as nickname, avatar, and bound mobile phone number) can be modified directly through the personal page;
Assistance with corrections: If you are unable to make corrections on your own (such as voice record annotation errors, system statistical learning data deviations), you can submit a correction application through the customer service phone or email. Explain the information items that need to be corrected, the reasons for the errors and relevant supporting materials. We will complete the review within 7 working days. After passing the review, we will make corrections to you and inform you of the results through an on-site letter.

(3) Right to withdraw permission and right to delete data

You have the right to withdraw authorization for unnecessary permissions at any time, or delete some/all personal information and learning data. The operation path and rules are as follows:

1. Withdrawal of permissions

System permission withdrawal: can be done through the phone system settings (such as iOS "Settings - Privacy and Security - GoSpeak", Android "Settings - Applications - GoSpeak - Permissions"), Turn off non-essential permissions such as microphone, photo album, storage, location, etc. After withdrawal, it will not affect the use of core functions of the APP (such as account login, basic learning);
Account unbinding process: If you need to unbind the account, you can unbind the account through the "Personal Page - Account Management - Account Management" page. After unbundling, we will stop sharing new information to the third party, but this will not affect the legality of the sharing behavior completed before unbundling.

(4) Right to cancel account

You have the right to apply to cancel your APP account at any time. After the account is cancelled, we will stop providing you with all services and process your information as agreed. The specific rules are as follows:

Cancellation conditions: To apply for account cancellation, you must meet the following conditions: ① There are no uncompleted transactions on the account (such as unpaid orders, unrefunded courses); ② The account has no outstanding debts (such as membership subscription fees and liquidated damages); ③ There are no ongoing complaints, appeals or disputes on the account;
Logout path: You can go through the "Personal Page - Account Management - Account Security - Account Cancellation" page, follow the prompts to complete identity verification (such as mobile phone number verification code, password verification), and submit a cancellation application; If you cannot find the cancellation entrance, you can contact customer service to assist in initiating an application;
Logout review and processing: We will complete the logout review within 7 working days. After passing the review, your account information, personal information, learning data, etc. will be completely deleted or anonymized within 15 working days. (Except information that needs to be retained by law, such as transaction records that need to be retained until the statutory retrospective period);
Consequences of cancellation: After the account is canceled, your account will not be able to be logged in or retrieved, and the relevant membership rights, learning progress, and purchased courses (unused and non-transferable) will automatically become invalid. We will no longer provide you with any data query and recovery services, please operate with caution;
Cancellation and withdrawal: During the cancellation review period (7 working days), you can submit a cancellation and withdrawal application through customer service channels. After passing the review, the cancellation process will be terminated and the account will resume normal use; If the review has been passed and the data processing stage has been entered, it cannot be withdrawn.

(5) Protection and restrictions on the exercise of rights

We will not reduce your service quality, restrict your use of core functions, or charge you unreasonable fees because you exercise the above rights;
In order to protect the security of your account, when you exercise your rights to inquire, correct, cancel, etc., we may require you to perform identity verification to ensure that the application is initiated by you;
We may not be able to fulfill your request to exercise your rights under the following circumstances: ① Involving national security, public interests or the legitimate rights and interests of others; ② The information has been anonymized and the specific subject cannot be identified; ③ Other special circumstances stipulated in laws and administrative regulations;
If you are the guardian of a minor and need to exercise the above rights on behalf of the minor (such as querying, deleting the minor's learning data, canceling the account), You need to provide proof of your identity and guardianship relationship (such as household registration book, birth certificate), and we can only operate on your behalf after we review and approve it.

6. Protection of minors

Minors under the age of fourteen (hereinafter referred to as "minors") must contact their guardians (including parents and other persons who perform guardianship duties in accordance with the law) before using the services covered by this policy. Read this policy together under the full supervision and guidance of the guardian, and only use the service and submit personal information with the guardian's express consent; Before using this service, minors who are over 14 years old but under 18 years old (hereinafter referred to as "minors") should confirm their agreement with this policy together with their guardians. And submit personal information under the guidance of the guardian to ensure that the information submission behavior complies with their cognitive abilities and legal regulations.

We strictly comply with relevant laws and regulations such as the "Minor Protection Law of the People's Republic of China", "Regulations on the Internet Protection of Minors", "Personal Information Protection Law", etc. Implement special protection for the personal information of minors. Only to the extent permitted by law, with the explicit consent of the guardian, or when necessary to protect the legitimate rights and interests of minors. Only the personal information of minors will be collected and used, and the scope of information collection is strictly limited to the minimum scope necessary for the service, and no additional irrelevant information will be collected.

If we find that we have improperly collected minors’ personal information without obtaining verifiable guardian consent in advance (including but not limited to registering with a false identity, concealing the fact that they are minors), The verification process will be started immediately, and relevant personal information and learning data will be deleted as soon as possible after verification (except those that are required to be retained by law), and the provision of services to the minor will be stopped at the same time. Ensure the security of minors’ information.

7. Amendments and Notices to the Agreement

In order to adapt to objective circumstances such as updates to laws and regulations, adjustments to regulatory requirements, iterative upgrades of product functions, optimization of service models, etc., we have the right to revise the contents of this Privacy Agreement (hereinafter referred to as "this Agreement"). The revised agreement will more comprehensively protect your personal information security and legitimate rights and interests. The relevant revision procedures, notification methods and effective rules are as follows:

(1) Conditions for revision

We may revise this agreement when one of the following circumstances occurs:

If relevant national laws and regulations, departmental rules, judicial interpretations or industry norms change, this agreement will need to be adjusted accordingly to comply with compliance requirements;
This APP adds or optimizes service functions, involving changes in rules for the use and sharing of personal information;
Major adjustments to the way personal information is processed (such as storage server migration, replacement of third-party AI service providers, data encryption technology upgrades, etc.);
Regulatory agencies have put forward clear rectification requirements or updated industry standards, and the terms of the agreement need to be improved to comply with regulatory guidance;
In order to improve the level of user privacy protection, optimize the path for exercising user rights (such as adding new data query channels, simplifying the logout process, etc.).

(2) Revision process and publicity

Before revising this Agreement, we will organize an internal compliance review and seek advice from legal counsel or third-party privacy protection agencies when necessary. Ensure that the revised content is legal, compliant, fair and reasonable, and does not increase users’ obligations or restrict users’ legal rights (unless otherwise provided by law);
The revised agreement will be clearly marked with the "revision date" and "effective date", and the complete revised text will be provided in a prominent position in the APP for your convenience;
We will simultaneously produce an "Agreement Revision Instructions" to clearly list the core content of this revision and the reasons for the revision (such as which laws and regulations are updated and which functional iterations correspond). And a comparison of the terms before and after the revision to ensure you intuitively understand the changes.

(3) User rights and choices

After receiving the amendment notice, you have the right to read the amendments carefully before the agreement takes effect and decide whether to agree to the revised agreement;
If you agree to the revised agreement, you can continue to use all services of this APP normally, and subsequent use will be governed by the revised agreement;
If you do not agree to the revised agreement, you have the right to refuse to accept and stop using all services of this APP, And you can submit an account cancellation application through the "Personal Page - Account Management - Account Security - Account Cancellation" path before the agreement takes effect. We will process your account and related data in a timely manner in accordance with this agreement;
If you continue to use this APP after the revised agreement takes effect, it will be deemed that you have fully read, understood and agreed to all the revised terms. It shall not be claimed that the amendment of the agreement is invalid on the grounds that the notice has not been received or the amendment has not been read.

8. Contact information

When you have questions about personal information or other complaints or suggestions, you can contact the company through the following methods, and the company will review the content involved as soon as possible. And respond to your questions, complaints, and suggestions within 15 working days:

Customer service email:gospeakai@gmail.com

Mailing address: 11th Floor, VIA Technology Building, Nanshan District, Shenzhen City, Guangdong Province, China