This Privacy Policy applies to the word synthesis game application (hereinafter referred to as the "App") developed by SHENG SUN. It is designed to explain the rules regarding how the App collects, uses, stores, protects, and processes your personal information, as well as to clarify your related rights. This Policy is formulated in compliance with applicable global data protection laws and regulations, including the "Personal Information Protection Law (PIPL)," the "General Data Protection Regulation (GDPR)," and the "California Consumer Privacy Act (CCPA)."
Section 1: Information We Collect and Purposes of Collection
To implement the core features of word synthesis and review, while ensuring account services, data synchronization, and product optimization, the App collects the following types of information. We do not engage in excessive or irrelevant data collection:
- Account Registration and Login Information: When you register and log in to the App, you are required to provide relevant account information (such as phone number/email and a self-set password). This is used solely for account creation, identity verification, maintaining login status, and password recovery. No other account-related information is collected.
- Device Data: To conduct product data analysis, optimize the app experience, and troubleshoot operational issues, we collect non-identifiable basic device data, such as device model, system version, device brand, and network type. We do not collect unique device identifiers such as ATT, IDFA, or IMEI, and we do not perform device fingerprinting.
- Business Data Generated by User Activity: This includes word synthesis records, word review data, and learning preferences generated while you use the App. These are core learning data used to enable the App's synthesis and review features and to support cloud storage synchronization.
- Data Related to Cloud Storage Synchronization: To enable cross-platform synchronization of your learning data, the aforementioned business data is synchronized to the cloud storage module on the developer's self-built server and is associated solely with your account.
- Data Related to Third-Party API Calls: The App utilizes third-party APIs to implement certain features. During these calls, necessary business data (such as the text of words to be synthesized or reviewed) is transmitted in accordance with the service requirements of the third-party API. Your personal information, such as account details and device data, is not transmitted. Data transmission complies with this Policy and the privacy rules of the third-party services.
Section 2: How Information is Used
- To implement the App's core features: account login, word synthesis, word review, and cloud storage/cross-platform synchronization of learning data;
- For product optimization: analyzing collected device data and non-identifiable usage behavior data to troubleshoot app issues and optimize functionality. The results of this data analysis are aggregated, non-personal statistical information and are not linked to specific users;
- To comply with legal and regulatory requirements: cooperating with legitimate information requests from regulatory or judicial authorities within the scope permitted by law;
- Without your explicit authorization, your personal information will not be used for any purposes other than those stated in this Policy.
Section 3: Information Storage and Protection
Storage Entity and Duration
Your account information and business data are stored by the developer on a self-built server for the duration of your account's existence. If you request to delete your account, the developer will delete all your personal information within 15 business days and will not retain it.
Device data is used solely for real-time data analysis and troubleshooting; there is no requirement for long-term storage, and it is not persistently saved.
Storage Security Measures
The developer employs industry-standard information security measures, including but not limited to: using TLS encryption protocols for data transmission, deploying security protection mechanisms on servers, and restricting data access permissions to prevent the leakage, tampering, or loss of personal information;
The App does not use Cookies, does not implant analytics SDKs, and does not conduct behavioral tracking, thereby reducing information security risks.
Cross-Platform/Cross-Border Storage Explanation
If your cloud-stored data involves cross-border storage, the developer will comply with the cross-border data transfer laws and regulations of the relevant countries and regions and fulfill necessary compliance procedures to ensure the security of your information.
Section 4: Third-Party Services
The App calls third-party APIs to implement certain features. The data processing behavior of third-party service providers is governed by their respective privacy policies. The developer only transmits data to third parties to the extent necessary and has reasonably reviewed the information security capabilities of these third-party services.
You may review the privacy policies of third-party service providers through their official channels to understand their data processing rules.
Section 5: Information We Do Not Collect
The App does not collect or process the following information and has no relevant data acquisition permissions:
- Your sensitive personal identity information, such as name, ID number, home address, and bank card information;
- Information related to device permissions such as your contacts, calendar, SMS, photo album, microphone, and camera;
- Your precise or approximate geolocation information;
- Unique device identifiers such as ATT, IDFA, and IMEI;
- Information associated with third-party platforms, such as your social media accounts and chat records.
Section 6: Legal Basis for Data Processing
- For users in the EU and related regions subject to GDPR: The legal basis for the App processing your personal information is your explicit consent (such as authorization during account registration, enabling cloud storage, or third-party API calls). You may withdraw your consent at any time;
- For California users subject to CCPA: The App will not sell or share your personal information with any third parties. You enjoy all rights stipulated by the CCPA, including the right to know, the right to delete, and the right to opt-out;
- For users in China: The App processes your personal information following the principles of legality, propriety, and necessity, based on legal grounds such as your consent, performance of contractual obligations, product optimization, and compliance with laws and regulations.
Section 7: Your Rights
According to the laws and regulations of your region, you enjoy the following rights regarding your personal information. The developer will respond to your reasonable requests within 15 business days:
- Right of Access: You may query your account information and learning business data through the account settings within the App;
- Right to Rectification: If your personal information is incorrect, you may request to correct the relevant information;
- Right to Deletion / Right to Account Deletion: You may request to delete partial business data or directly delete your account. After deletion, all your personal information will be permanently removed;
- Right to Withdraw Consent: You may withdraw your authorization for features such as cloud storage and third-party API calls through the App settings or your device system settings. After withdrawal, the App will stop the relevant data processing, but this will not affect the legality of data processing based on your consent prior to the withdrawal;
- Right to Lodge a Complaint: If you have objections regarding the processing of personal information, you may file a complaint with the developer or initiate a complaint with your local data protection regulatory authority.
Section 8: Children's Privacy Protection
The App is a word learning application suitable for users of all ages and does not intentionally collect the personal information of children. If a guardian discovers that a child has used the App and submitted personal information without authorization, they may contact the developer. The developer will verify and delete the relevant information at the earliest opportunity.
Section 9: Updates to the Privacy Policy
The developer may revise this Privacy Policy in response to adjustments in product features or updates to laws and regulations. In the event of material changes to the Policy, the developer will notify you via in-app pop-ups or notifications. The revised Privacy Policy will take effect from the date of notification. Your continued use of the App constitutes acceptance of the revised Privacy Policy. Non-material adjustments to the Policy will be posted within the App without separate notification.