Privacy Policy

1. Introduction

CitrusLearn ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use it, and your rights regarding that information when you use the CitrusLearn application ("the App").

2. Data Controller

The data controller responsible for your personal data is CitrusLearn, based in the Netherlands. For any privacy-related inquiries, you can reach us at support@citruslearn.com.

3. Information We Collect

We collect the following types of information:

• Account information — email address and display name when you create an account.
• Learning progress — vocabulary lists, quiz results, spaced repetition schedules, and other data related to your study activity.
• Audio data — voice recordings captured during speech recognition exercises. These are processed in real time and are not permanently stored on our servers.
• Device information — basic device type and app version data for troubleshooting and compatibility purposes.

4. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your data on the following legal bases:

• Contract performance — processing your account and learning data is necessary to provide the App's core features, including syncing progress across devices and delivering quiz functionality.
• Consent — processing audio data for speech recognition exercises is based on your explicit consent, which you grant by using these features. You may withdraw consent at any time by stopping use of speech features.
• Legitimate interest — we process device information and anonymized usage data to maintain, troubleshoot, and improve the App.

5. How We Use Your Information

• To provide and maintain the App and its features
• To sync your learning progress across devices via your account
• To process speech input for pronunciation scoring and feedback
• To improve the App and develop new features
• To communicate with you about service updates or issues

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects. The spaced repetition algorithm uses your learning data to schedule reviews, but this is a core feature of the service and does not affect your rights.

6. Third-Party Services

We use the following third-party services to operate the App:

• Supabase — for authentication and database hosting. Your account and learning data are stored on Supabase's infrastructure.
• AI text-to-speech and speech recognition services — to generate audio pronunciations and evaluate your spoken Mandarin. Audio data sent to these services is processed in real time and not retained.

These services have their own privacy policies, and we encourage you to review them.

7. International Data Transfers

Some of our third-party service providers may process your data outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses or adequacy decisions, to protect your data in accordance with GDPR requirements.

8. Data Retention

We retain your account and learning data for as long as your account is active. If you delete your account, we will remove your personal data from our systems within 30 days. Anonymized, aggregated data may be retained for analytics purposes.

9. Data Security

We take reasonable measures to protect your information, including encryption in transit and at rest. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Your Rights

Under the GDPR and other applicable data protection laws, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Export your data in a portable format
• Object to or restrict certain processing of your data
• Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, please contact us at support@citruslearn.com. We will respond to your request within 30 days.

You also have the right to lodge a complaint with a supervisory authority. If you are in the Netherlands, you may contact the Autoriteit Persoonsgegevens (Dutch Data Protection Authority) at autoriteitpersoonsgegevens.nl. If you are located in another EU/EEA country, you may contact your local data protection authority.

11. Children's Privacy

CitrusLearn is available to users of all ages. If you are under 13 (or under 16 in the EU), you may only use CitrusLearn with the consent of a parent or legal guardian. By creating an account for a child, the parent or guardian agrees to these terms on the child's behalf and is responsible for the child's use of the App. We do not knowingly collect personal data from children without parental consent. If you believe a child is using CitrusLearn without parental consent, please contact us so we can take appropriate action.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of material changes through the App or by other reasonable means. Continued use of the App after changes take effect constitutes acceptance of the updated policy.

13. Contact

If you have questions about this Privacy Policy, please contact us at support@citruslearn.com.