This Privacy Policy explains how we (CCT LTD) collect, use, disclose, and safeguard your information when you use our mobile application ("App"). We are committed to protecting your privacy and being transparent about our data practices.

Please read this Privacy Policy carefully. By using our App, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Personal Information

We collect minimal personal information to provide our services:

  • Email address (collected via Google Sign-In or Apple Sign-In)
  • Your learning progress and activity within the App

1.2 Authentication Information

When you sign in using Google or Apple:

  • Google Sign-In: We receive your email address from Google
  • Apple Sign-In: We receive your email address (or private relay email) from Apple
  • We do not receive or store your Google or Apple passwords

1.3 Usage and Analytics Information

We use analytics services to improve the App experience:

  • App usage patterns and feature interactions (via Mixpanel)
  • Device type and operating system version
  • App version and crash reports
  • Session duration and frequency

1.4 Subscription Information

We use RevenueCat to manage in-app subscriptions. RevenueCat may collect:

  • Subscription status and purchase history
  • Device identifiers for subscription validation
  • We do not process or store payment card information directly

2. How We Use Your Information

We use the collected information for the following purposes:

  • To create and manage your account
  • To save and sync your learning progress across devices
  • To provide personalized learning experiences
  • To process and manage your subscription
  • To improve App features and user experience
  • To analyze usage patterns and fix technical issues
  • To send important updates about the App
  • To provide customer support when needed
  • To ensure the security and integrity of the App

3. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We share information with the following third-party service providers:

  • Google Sign-In: For authentication services
  • Apple Sign-In: For authentication services
  • RevenueCat: For subscription management and payment processing
  • Mixpanel: For analytics and App usage tracking
  • Database providers: For secure data storage and retrieval

These providers are bound by their own privacy policies and confidentiality obligations.

3.2 Business Transfers

In connection with any merger, sale of company assets, financing, or acquisition, your information may be transferred to the acquiring entity.

3.3 Legal Requirements

We may disclose your information if required by law, court order, or governmental request, or to protect our rights, property, or safety.

3.4 With Your Consent

We may share your information with third parties when we have your explicit consent to do so.

4. Data Security

We implement appropriate technical and organizational measures to protect your information:

  • Encryption of data in transit (SSL/TLS)
  • Secure authentication via Google and Apple Sign-In
  • Secure database storage with access controls
  • Regular security updates and monitoring
  • Industry-standard security practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Data Retention

We retain your personal information for as long as necessary to provide the App services and fulfill the purposes outlined in this Privacy Policy:

  • Account information: Retained while your account is active
  • Learning progress: Retained while your account is active
  • Analytics data: Retained according to Mixpanel's retention policy
  • Subscription data: Retained according to legal and tax requirements

If you delete your account, we will delete your personal information within a reasonable timeframe, except where we are required to retain it by law.

6. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your personal information
  • Portability: Request transfer of your information
  • Restriction: Request restriction of processing
  • Objection: Object to processing of your information
  • Withdraw Consent: Withdraw previously given consent

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within a reasonable timeframe.

7. Third-Party Services

Our App integrates with the following third-party services, each with their own privacy practices:

  • Google Sign-In: Subject to Google's Privacy Policy
  • Apple Sign-In: Subject to Apple's Privacy Policy
  • RevenueCat: Subject to RevenueCat's Privacy Policy
  • Mixpanel: Subject to Mixpanel's Privacy Policy

We encourage you to review the privacy policies of these third-party services to understand their data practices.

8. Data Storage and Security

Your data is stored securely in our databases with industry-standard security measures:

  • Encrypted data transmission (SSL/TLS)
  • Secure database storage with access controls
  • Regular security updates and monitoring
  • Limited employee access to user data

Payment information is processed by Apple and Google through their respective payment systems. We do not store your credit card or payment information.

9. Children's Privacy

Our App is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

If we become aware that we have collected personal information from children under 13 without parental consent, we will take steps to delete such information from our servers.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws different from those in your jurisdiction.

When we transfer your information internationally, we take appropriate safeguards to ensure your information remains protected in accordance with this Privacy Policy and applicable laws.

11. Email Communications

We may send you service-related emails to your registered email address, such as:

  • Account verification and security notifications
  • Subscription updates and payment confirmations
  • Important App updates and changes to our policies
  • Customer support responses

These communications are necessary for providing our services. For optional marketing emails, you can opt out at any time by contacting us.

12. Data Breach Notification

In the event of a data breach that may compromise your personal information, we will notify affected individuals and relevant authorities as required by applicable law. We will provide information about the breach, potential impact, and steps being taken to address it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make changes, we will update the policy on this page and may notify you through other means such as email.

Your continued use of our services after changes are posted constitutes your acceptance of the updated Privacy Policy.

14. California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal information is collected
  • Right to know if personal information is sold or disclosed
  • Right to opt-out of the sale of personal information
  • Right to request deletion of personal information
  • Right to non-discrimination for exercising your rights

15. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

  • Right to be informed about data processing
  • Right of access to your personal data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Rights related to automated decision-making

You also have the right to lodge a complaint with a supervisory authority.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through the App or via email.

By using our App, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

Last Updated: December 10, 2025