Privacy Policy

Last updated: July 16, 2026

Effective date: July 15, 2026

1. Introduction

Codoha Ltd. ("Codoha," "we," "our," or "us") operates TingWo, a mobile-first application that turns Chinese text you paste or photograph into a personalized, spoken-first spaced-repetition vocabulary trainer (the "Service"). The Service is available as a web application at tingwo.app and as an Android application distributed through the Google Play Store.

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 application, comprising the website and web app at

tingwo.app and the TingWo Android app on the Google Play Store.

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 to third-party AI providers.

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 (an anonymous 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 authentication provider.

Sign-in may be offered through a third-party identity provider such as Google. If you choose to sign in with Google, Google shares your basic Google profile information (your email address, name, and profile picture) with us so we can create and identify your account. We use this information only to operate your account; your use of Google sign-in is also subject to Google's own privacy policy. We request only basic, non-sensitive profile information and do not request access to your Gmail, contacts, files, or other Google services.

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.

Practice content you create, such as journal entries you write, roleplay

and dialogue conversations you have with the trainer, and phrasing you submit for improvement. This can be free text, so please treat it like anything else you type into the Service.

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.

3.2a Push-notification data

If you turn on reminder notifications, we store a push subscription so we can send them: a device push endpoint provided by your browser or operating system, the associated public encryption keys, your device time zone (to send the reminder at a sensible local hour), and your chosen reminder time. This data is used only to deliver the reminders you asked for, and is deleted when you turn notifications off or delete your account.

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,

played back on your device for self-comparison, and sent to our speech-recognition service to check which characters you said correctly. Like photos, the audio is processed in the request and not stored on our servers. It is transmitted to our AI provider solely for transcription and is not used for any other purpose.

3.4 Usage and analytics data

If analytics are enabled, we use a third-party product-analytics provider 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.

Visitors in the EEA and the UK. We do not run product analytics for visitors we detect in the European Economic Area or the United Kingdom. For those visitors the analytics provider is not loaded at all, so no analytics identifier is stored on your device and no analytics events or IP-based location are processed. Detection is based on the approximate country of your network connection.

3.5 Cookies and local storage

We use a small number of strictly functional storage mechanisms:

An authentication token (stored by our authentication provider in your

browser or app) 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. Mobile App and Device Permissions

The TingWo Android app provides the same Service as the website. To deliver specific features, the app may ask for device permissions. These permissions are optional, are requested only when a feature needs them, and can be granted or revoked at any time in your device settings:

Camera, used only when you choose to photograph Chinese text to extract. As

described in §3.3, the image is processed in the request and is not stored.

Microphone, used only during Speaking practice. As described in §3.3, the

audio is processed in the request and not stored on our servers.

Notifications, used only if you enable them, to deliver reminders such as

when reviews are due. You can turn notifications off at any time.

Declining a permission only disables the feature that needs it; the rest of the Service continues to work.

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:

Hosting & infrastructure provider, for application hosting and compute.
Database, authentication & storage provider, which hosts your account and

stored Content.

AI providers, which process the text and photos you submit to deliver

vocabulary analysis, sentence generation, text extraction from photos, and text-to-speech.

Product-analytics provider, optional, as described above.
Support and contact-form provider, which receives the name, email address,

and message you enter when you contact us or report content through an in-app or on-site form, so we can deliver and respond to it.

We engage these providers only to operate the Service, and they are bound to protect data and use it solely on our behalf. A current list of our sub-processors is available on request at support@tingwo.app.

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 and keyed to 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.

6. App Stores

When you install or use the TingWo Android app through the Google Play Store, the store operator may collect and process limited information, such as installation, usage, and crash statistics, under its own privacy policy and terms, which are independent of this Privacy Policy. We may receive aggregated or de-identified app statistics from the store to understand installs and diagnose crashes. Your relationship with the app store is governed by that store's policies, not by us.

7. 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.

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.

We do not carry out solely automated decision-making that produces legal effects concerning you or similarly significantly affects you. Your review scheduling is computed automatically to time your practice, but it has no legal or similarly significant effect.

9. 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. If you use the Service without signing in, your account is not linked to an email address, so include your Account ID (open Settings and tap Copy ID under Account ID) in your message so we can locate your data and action your request.

EU representative (GDPR Article 27). Codoha has no establishment in the European Union. We are currently in the process of appointing a representative in the EU under Article 27 of the GDPR. Until that appointment is finalized, EU and EEA residents can contact us directly at support@tingwo.app for any request or complaint, and you retain the right to lodge a complaint with your local supervisory authority. We will update this policy with the representative's contact details once the appointment is complete.

10. 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 can delete your account and all associated data at any time directly in the app: open Settings, scroll to the Danger zone, and choose Delete account and all data. Deletion is immediate and permanent. You may also request deletion by emailing support@tingwo.app (if you are not signed in, include your Account ID from Settings so we can identify the account). For step-by-step instructions and details of what is removed, see tingwo.app/delete-account.

11. 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.

12. Security

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

13. 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.

14. 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.

15. 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.)