Privacy Policy

Last updated: June 6, 2026

Effective date: June 6, 2026

1. Introduction

Codoha Ltd. ("Codoha," "we," "our," or "us") operates TingWo (聽我) — a mobile-first web application that turns Chinese text you paste or photograph into a personalized, spoken-first spaced-repetition vocabulary trainer (the "Service"), available at tingwo.app.

This Privacy Policy explains what information we collect, how we use and store it, who we share it with, and the choices and rights you have. We are committed to handling your data transparently and to data minimization: we collect what the Service needs to work, and nothing more.

Codoha Ltd. is a limited company registered in Taiwan (R.O.C.), located at Rm. 5, 4 F., No. 8, Guomin 8th St., Hualien City, Hualien County 970015, Taiwan (R.O.C.). The Service is available to users worldwide. This policy is designed to meet the requirements of the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and the Taiwan Personal Data Protection Act (PDPA).

2. Definitions

Service means the TingWo web application and website at tingwo.app.
Operator means Codoha Ltd.
You means the individual accessing or using the Service.
Personal Data means information relating to an identified or identifiable

individual.

Content means the material you provide to the Service — text you paste,

photos you submit for text extraction, and the vocabulary, sentences, and study data derived from it.

Usage Data means data collected automatically about how the Service is

accessed and used.

AI Provider means an artificial-intelligence service that processes Content

to produce results. TingWo routes AI requests through OpenRouter to AI models including Google Gemini.

Sub-processor means a third party that processes data on our behalf.

3. Information We Collect

3.1 Account data

TingWo is anonymous-first. When you first open the Service, we automatically create an anonymous account (a Supabase session) so your library and progress can be saved. This account is identified by a random identifier, not by your name or email.

Signing in is optional. If you choose to log in, we collect your email address to upgrade your anonymous account into a persistent one, so you can access your data across devices. Authentication is handled by our infrastructure provider, Supabase.

3.2 Content you provide and we store

To provide the trainer, we store the following in your account:

Chinese text and articles you paste or import.
Vocabulary you save (words, meanings, and phonetics) and AI-generated

example sentences associated with your words.

Your study history — review outcomes and self-grades, scheduling state, and

reading cards.

Your profile settings — such as script preference (simplified/traditional),

daily new-word limit, and interface language.

3.3 Content that is processed but NOT stored

Photos. When you photograph or upload an image to extract Chinese text, the

image is sent to our text-extraction service, processed in the request, and not persisted. We keep the extracted text (as part of your library), not the image.

Microphone audio. During Speaking practice, your recording is captured and

played back entirely on your device for self-comparison. It is never uploaded to or stored on our servers, and we never transmit it to any AI provider.

3.4 Usage and analytics data

If analytics are enabled, we use PostHog to collect product-usage events and technical information such as browser type and version, device characteristics, pages or screens viewed, and an approximate location derived from your IP address. This helps us understand how the Service is used and improve it. Analytics are optional and are disabled entirely when the relevant configuration is not set.

3.5 Cookies and local storage

We use a small number of strictly functional storage mechanisms:

An authentication token (stored by Supabase in your browser) that keeps you

signed in to your account.

Local storage for functional preferences such as your interface language.

We do not use advertising or cross-site tracking cookies.

4. How We Use Your Data

We use the data described above to:

Provide and maintain the Service and your personal library.
Run AI-powered features when you request them — analyzing pasted or photographed

text into vocabulary, generating example sentences, and producing audio (text-to-speech).

Schedule your reviews and track your learning progress.
Communicate with you about the Service, including responding to support

requests.

Understand usage, improve the Service, and ensure security and abuse prevention.

5. AI Processing and Sub-processors

To deliver TingWo we rely on a small set of trusted service providers. They access data only to perform services for us and are bound to protect it:

Supabase — database, authentication, and file storage; hosts your account

and stored Content.

Vercel — application hosting and serverless functions.
OpenRouter — routes our AI requests to AI models, including **Google

Gemini**, used for vocabulary analysis, sentence generation, text extraction from photos, and text-to-speech.

PostHog — product analytics (optional, as described above).

Important — AI and sensitive information. Text and photos you submit for analysis are sent to our AI Provider for processing. Please do not paste or photograph sensitive personal information — such as government identifiers, financial account details, health information, or login credentials — into the Service.

Shared audio cache. Generated text-to-speech audio is cached by a hash of the underlying text so the same phrase does not have to be regenerated. This cached audio is derived from text content and may be reused to serve audio efficiently across the Service.

We do not sell your personal information.

Where the GDPR applies, we process Personal Data on these bases:

Performance of a contract — to provide the Service you request.
Consent — for optional features such as AI processing of your Content and,

where applicable, analytics. You may withdraw consent at any time.

Legitimate interests — to secure, maintain, and improve the Service, where

not overridden by your rights.

Legal obligation — to comply with applicable law.

7. Your Privacy Rights

Depending on where you live, you may have the right to access, correct, delete, export (port), restrict, or object to the processing of your Personal Data, and to withdraw consent. We do not sell personal information, and we will not discriminate against you for exercising your rights.

GDPR (EU/UK) residents have the rights described above and the right to lodge

a complaint with a supervisory authority.

California (CCPA/CPRA) residents have the rights to know, access, delete, and

opt out of "sale" or "sharing" (we do neither), and to non-discrimination.

Taiwan (PDPA) residents may inquire about, review, obtain a copy of,

supplement, correct, request cessation of processing of, or request deletion of their Personal Data.

To exercise any right, email support@tingwo.app. You can also delete much of your stored Content directly within the app.

8. Data Retention and Deletion

We retain your account data and stored Content for as long as your account is active, or as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. Photos submitted for text extraction are not retained (see §3.3). Usage Data is retained for a shorter period unless needed for security or legal reasons.

You may request deletion of your account and associated data at any time by emailing support@tingwo.app.

9. International Data Transfers

Codoha operates internationally, and our sub-processors may process data in countries other than your own, including outside your jurisdiction. Where required, we rely on appropriate safeguards (such as standard contractual clauses) for these transfers. By using the Service, you understand that your information may be transferred to and processed in such locations.

10. Security

We take reasonable technical and organizational measures to protect your data, including access controls and row-level security that scopes stored Content to your account. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

11. Children's Privacy

The Service is not directed to children under 16, and we do not knowingly collect Personal Data from children under 16. If you believe a child has provided us with Personal Data, contact us and we will take steps to delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy on this page and revise the "Last updated" date above. Material changes will be communicated where appropriate. Changes are effective when posted.

13. Contact Us

If you have questions about this Privacy Policy or your data, contact us:

Email: support@tingwo.app
Address: Codoha Ltd., Rm. 5, 4 F., No. 8, Guomin 8th St., Hualien City, Hualien

County 970015, Taiwan (R.O.C.)