Effective date: 18 September 2026
This Privacy Policy explains how EdTechVN JSC ("EdTechVN", "Palingo", "we") collects, uses, retains, protects and shares personal data when You use Palingo's application, website and related services. This Policy applies together with the Terms of Use and the Cookie Policy.
1. SCOPE, RESPONSIBLE ENTITY AND CONTACT
a. Responsible entity: EdTechVN JSC, business registration number 0318781147, registered address at 1025/1A Cach Mang Thang Tam, Tan Son Nhat Ward, Ho Chi Minh City, Vietnam.
b. Scope: This Policy applies to data collected through the Palingo application, the Palingo website, support activities, Premium transactions and any other online channel where this Policy is published.
c. Contact channel: Requests relating to personal data may be sent to [email protected]. Palingo may request information necessary to verify identity before processing a request.
2. DATA PALINGO MAY COLLECT
a. Account and contact data: May include your full name or display name, email, login information, profile information, age or date of birth where needed for a relevant feature, language and other information You voluntarily provide.
b. Learning data: May include vocabulary learned, answers, scores, XP, Streaks, progress, lesson history, retention level, learning goals, feedback and engagement metrics.
c. Voice data used for pronunciation scoring: When You use the pronunciation-scoring feature, your voice is used solely to score pronunciation. Palingo does not collect or store voice recordings as account data.
d. Transaction and payment data: May include the plan purchased, the time of the transaction, the billing cycle, payment status, transaction code, the platform of purchase and information necessary for reconciliation. Card information may be processed directly by Apple, Google or a payment provider.
e. Device and technical data: May include device type, operating system, application version, Device ID or a similar identifier, IP address, browser, time zone, network information, error logs and access times.
f. Usage and analytics data: May include screens viewed, features used, actions taken, duration, frequency of use, installation or access source and application performance.
g. Support and feedback data: May include the content of communications with support, surveys, feedback, bug reports, images or documents You voluntarily submit.
h. Data from other sources: Palingo may receive data from Apple, Google, payment providers, technical service providers or other sources where necessary to provide the Service, process transactions, prevent fraud or comply with a legal obligation.
3. PURPOSES OF PROCESSING
a. Providing the Service: Creating and maintaining accounts, delivering lessons, syncing progress, authentication, support and operating the Service's functions.
b. Personalising learning: Adjusting content, review schedules, lesson recommendations and the experience based on learning data, to the extent permitted.
c. AI and pronunciation recognition: Processing the input data necessary to provide AI features and pronunciation scoring according to the function the User uses.
d. Payment and Premium: Confirming transactions, activating benefits, processing renewals, cancellations, refunds, reconciliation and transaction support.
e. Analytics and product improvement: Measuring performance, detecting errors, researching usage behaviour, improving content and the learning experience, and developing the product.
f. Safety and fraud prevention: Detecting abnormal accounts, fraud, or abuse of Premium, Free Trials, rewards, leaderboards or Refer-a-Friend.
g. Communications: Sending technical, account, security, transaction, product-update and other Service-related notices.
h. Marketing: Sending information about products, offers or marketing programmes to the extent permitted by law and according to the User's choices where required by law.
i. Legal compliance: Fulfilling legal obligations, responding to lawful requests and protecting legitimate rights and interests.
4. LEGAL BASIS AND CHOICES
a. Legal basis: Palingo processes data on a basis consistent with applicable law, including consent, performance of an agreement, legal obligation, and other cases permitted or required by law.
b. Withdrawing consent: Where processing is based on consent, You may withdraw it through the mechanism Palingo provides. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal and may affect certain functions.
c. Opting out of marketing: You may opt out of marketing communications by following the instructions in the relevant email or through the applicable settings; necessary account, security or transaction notices may still be sent.
d. Mandatory information: Certain information is necessary to create an account, provide a function or complete a transaction. Not providing necessary information may prevent certain features from working.
5. SHARING AND DISCLOSURE OF DATA
a. Service providers: Palingo may share data with hosting, analytics, email, support, security, AI, IT and other providers that process data on Palingo's behalf.
b. Apple, Google and payments: Necessary data may be shared with Apple, Google, a payment gateway or a payment provider to process transactions and carry out reconciliation.
c. Partners and affiliates: Data may be shared, to the extent necessary, with group companies, partners or affiliates to operate the Service, provide support or maintain security.
d. Competent authorities: Palingo may disclose data where required by law or in response to a lawful request from a competent authority.
e. Business transactions: In the event of a restructuring, merger, or transfer of business or assets, data may be transferred in accordance with applicable law and policy.
6. RETENTION AND DELETION OF DATA
a. Retention period: Palingo deletes account data upon request or account deletion and in accordance with the applicable retention policy; data that must continue to be retained for legal, transactional or other valid purposes is handled according to the corresponding retention period.
b. Deleting data: When data is no longer necessary for the purpose of processing and does not fall within a case where Palingo must continue to retain it, Palingo will delete or dispose of the data through an appropriate process and technical means.
7. RIGHTS OF THE DATA SUBJECT
a. Rights: Depending on the circumstances and applicable law, You may have the right to access, correct, update, delete, restrict, object to, withdraw consent regarding, and exercise other rights over your data.
b. How to exercise these rights: A request may be sent to [email protected]. Palingo may request identity verification.
c. Limitations: Certain requests may be limited or refused where the law permits or requires Palingo to continue retaining or processing the data.
d. Complaints: You may submit a complaint relating to the processing of data to Palingo and exercise your right to complain under applicable law.
8. CHILDREN AND MINORS
a. Protection of minors: Palingo applies measures appropriate under applicable law to the collection, use and processing of minors' data.
b. Consent of a representative: Where the law requires the consent or confirmation of a parent or guardian, Palingo applies a mechanism appropriate to the case and the feature concerned.
c. Requests from a parent or guardian: A parent or guardian may contact Palingo about the data of the person they represent, together with the information necessary for verification.
d. Data minimisation: Palingo does not intentionally require a minor to provide more data than is necessary for a specific function, within the scope of applicable law.
9. DATA SECURITY
a. Protective measures: Palingo applies technical, organisational and administrative measures appropriate to reduce the risk of unauthorised access, loss, alteration or disclosure of data.
b. Providers: Palingo only uses data-processing providers to the extent necessary for the Service and applies appropriate security requirements to them.
c. Security limitations: No method of electronic transmission or storage is completely secure. Where an incident falls within the scope requiring notification, Palingo fulfils its obligations under applicable law.
10. COOKIES, ANALYTICS AND ADVERTISING
a. Cookies: The website may use cookies and similar technologies in accordance with the Cookie Policy.
b. Analytics: Palingo may use analytics tools to understand how Users use the Service, detect errors and improve the product.
c. Advertising: Where Palingo or a partner uses advertising or marketing technology, the related data processing is carried out in accordance with the Privacy Policy, the Cookie Policy and the applicable choice mechanism.
d. Third-party tools: Certain third-party tools may process data directly on the website or the device in accordance with their own policies.
11. CHANGES TO THIS POLICY AND CONTACT
a. Changes: Palingo may update this Policy to reflect changes to the Service, its providers, legal requirements or its data-processing methods.
b. Material changes: Where a change materially affects how Palingo processes data, Palingo will provide notice and take other steps required by law.
c. Contact: Email: [email protected].
12. ANONYMISED DATA, AGGREGATION AND RESEARCH
a. Anonymised/aggregated data: Palingo may use data that has been anonymised or aggregated for product analysis, research into learning effectiveness, statistics and feature development, to the extent permitted by law.
b. Publishing research: When publishing research results, Palingo applies appropriate measures to limit the ability to identify individuals.
13. USER PROFILES, COMMUNITY AND PUBLIC CONTENT
a. Displayed profiles: Palingo provides profiles, leaderboards, a community and certain information such as a display name, profile picture, achievements or interaction data may be displayed as designed for that feature.
b. Sharing controls: Palingo provides appropriate information so that Users know the scope of information that may be displayed to others.