[IMPORTANT] This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use the Services, and your rights in relation to it. Jurisdiction-specific terms, including for users in Singapore, are set out in the Appendix. By using the Services, you acknowledge this Privacy Policy.
1. Who We Are
The organisation responsible for your personal data is MANJI NETWORK PTE. LTD. (Singapore). For any privacy request or question, contact our data protection contact at support@dolphingo.app.
2. Personal Data We Collect
- Account data: such as your email address and the identifier from any third-party sign-in you use.
- Learning data: your learning records, progress, and pronunciation practice.
- Voice data: audio you provide for pronunciation and conversation features, where you have granted microphone permission. Voice data is stored temporarily in secure object storage and automatically deleted within 7 days; we do not extract voiceprints from it for identity recognition, and we do not use it to train models.
- Device and usage data: such as language, log, and usage information.
- Payment data: purchase records; card and payment-account details are collected and processed by the applicable payment channel, not stored by us.
3. How We Use Personal Data
We use personal data to: provide, maintain, and improve the Services; deliver AI conversation, pronunciation, learning-plan, and review features; process purchases and provide customer support; ensure security and prevent abuse; and comply with legal obligations.
4. Basis for Processing
We process your personal data on the basis of your consent and, where applicable, another basis permitted under applicable law (such as processing necessary for the performance of a contract with you, or for our legitimate interests). Where we rely on your consent, you may withdraw it as described in Section 8.
5. Disclosure and Third-Party Sharing
We disclose personal data only as needed to provide the Services and as permitted by law. We do not sell your personal data. We may share personal data with the following categories of recipients (the "Third-Party Sharing List"):
- AI model providers — to process your input and generate outputs.
- Payment channels — to process purchases, subscriptions, and refunds.
- Cloud hosting and infrastructure providers — to host and operate the Services.
- Analytics and diagnostics providers — to understand usage and improve the Services.
- Professional advisors, authorities, or parties to a corporate transaction — where necessary for legal compliance, to protect rights, or in connection with a merger, acquisition, or other business transfer.
6. International Data Transfer
Your personal data is primarily stored and processed in Singapore. Certain third-party providers — in particular AI model providers — may process your data outside Singapore. Where we transfer personal data outside Singapore, we take steps to ensure that the recipient provides a standard of protection comparable to that required under applicable law.
7. Retention
We retain personal data only for as long as necessary for the purposes described here or as required by law, after which we delete or anonymise it.
8. Your Rights
- Access and correction: you may request access to, or correction of, the personal data we hold about you.
- Withdraw consent: for processing based on your consent (such as microphone and other device permissions), you may withdraw consent by turning off the relevant system permission or by contacting us using the details in this policy. Withdrawal does not affect processing already carried out before withdrawal, and may mean we can no longer provide certain features.
- Deletion: you may delete your account through the in-app option, after which we delete or anonymise your personal data except where retention is required by law.
To exercise any right, contact our data protection contact at support@dolphingo.app. We will respond within the time required by law after verifying your identity.
9. Security
We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Children
The Services are intended for users aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us personal data, contact us and we will take appropriate steps.
11. Cookies and Similar Technologies
On the web, we and our providers may use cookies and similar technologies to keep you signed in, remember preferences, and understand usage. You can control cookies through your browser settings; disabling some may affect functionality.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Where a change is material, we will notify you by an appropriate means before it takes effect.
Effective date: 7 August 2026; last updated: 7 August 2026.
Appendix: Jurisdiction-Specific Additional Terms
A. Notice to Users in Singapore (PDPA)
This section applies to individuals in Singapore and is subject to the Personal Data Protection Act 2012 (the "PDPA"). MANJI NETWORK PTE. LTD. is the organisation responsible for your personal data (the data controller) under the PDPA. We process personal data on the basis of your consent and, where applicable, deemed consent or another basis permitted under the PDPA. If a notifiable data breach occurs, we will notify the Personal Data Protection Commission (PDPC) and affected individuals where required by law. When we transfer personal data outside Singapore, we take steps to ensure the recipient provides a standard of protection comparable to that under the PDPA. For any privacy request, contact our data protection contact at support@dolphingo.app.