Privacy Policy — Master Chinese (English)

Last revised: 10 October 2025

1. Introduction and Scope

1.1. This Privacy Policy explains how Master of Languages (“Master of Languages”, “we”, “us”, “our”) collects, uses, discloses, and protects personal data when you access or use the Master Chinese mobile application and related services (collectively, the “Service”).

1.2. By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you should not use the Service.

1.3. The Service is intended for individuals who are at least 13 years old. We do not knowingly collect data from children under 13.

2. Controller and Contact Details

2.1. For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the data controller is: Master of Languages, based in Sofia, Bulgaria.

2.2. Contact for all privacy matters: legal@masteroflanguages.com.

2.3. We have not appointed a Data Protection Officer. All privacy correspondence should be directed to the contact above.

3. Definitions

3.1. “Personal data” has the meaning given in Article 4(1) GDPR.

3.2. “Processing” means any operation performed on personal data, as defined in Article 4(2) GDPR.

3.3. “Applicable law” means GDPR and relevant national law in Bulgaria and the EU.

4. Changes to this Privacy Policy

4.1. We may amend this Privacy Policy to reflect changes in law, technology, or our practices. The “Last revised” date indicates the latest version.

4.2. Substantive changes will take effect upon publication in the Service or on our website.

5. Categories of Personal Data We Process

5.1. Account Registration and Authentication Data. When you create an account, we process your email address and password. If you register via social login (e.g., Google, Facebook, Apple), we receive identifiers (such as your email address and profile information) from the provider, subject to your settings with that provider.

5.2. Profile and Service Use Data. We process data generated through your use of the Service, including your chosen interface language, learning goals, lesson history, progress metrics, achievements, challenge participation, and leaderboard placement, as applicable.

5.3. AI Interaction Data. Where you use in-app AI chat or conversational features, we process your submitted text and generated responses. If voice input features are introduced, we may process audio for recognition and transcribe it for product operation and quality assurance in accordance with Section 10.

5.4. Device, Log, and Diagnostic Data. We process technical data such as device type and operating system, app version, crash logs, performance metrics, and general event logs, including through Firebase services and Google Play Console.

5.5. Communication Data. We process your email address and information you provide when contacting us. We currently send functional communications (e.g., verification and password reset). If we introduce marketing emails, we will only send them with your prior consent and provide you with withdrawal options at any time.

5.6. Payment and Subscription Data (Future). If subscriptions are introduced, payment processing will be handled by the relevant app store (Google Play or Apple App Store) or by a third-party processor such as Stripe or PayPal. We will not store your full payment card details on our systems.

5.7. Cookies/SDKs (Web properties only). If you access our web pages, we may use cookies and similar technologies for essential operation and, with consent where required, for analytics and improvements.

5.8. Special Categories of Personal Data. We do not seek to collect special categories of personal data within the meaning of Article 9 GDPR. Please do not submit such information through the Service.

6. Purposes of Processing and Legal Bases

6.1. Provision of the Service (Article 6(1)(b) GDPR). We process account, authentication, profile, learning, and technical data to create and maintain your account, deliver lessons and features, record progress, and ensure the Service functions as intended.

6.2. Service Improvement, Safety, and Quality (Article 6(1)(f) GDPR). We process usage analytics, diagnostics, and log data to maintain performance, detect faults, prevent abuse, and improve user experience. Our legitimate interests include operating an effective, reliable, and secure Service.

6.3. AI Features (Article 6(1)(b) and 6(1)(f) GDPR). We process your AI chat content to provide requested features and to ensure quality and safety. Where optional enhancements or personalization requiring consent are offered, we will rely on Article 6(1)(a) GDPR and provide clear controls.

6.4. Communications (Article 6(1)(b) and 6(1)(f) GDPR). We send essential service messages. Marketing emails will only be sent where you have provided consent (Article 6(1)(a) GDPR), which you may withdraw at any time.

6.5. Compliance with Legal Obligations (Article 6(1)(c) GDPR). We may process data as necessary to comply with applicable law, court orders, or regulatory requirements.

7. Sources of Data

7.1. We collect data directly from you through the Service and, where you use social login, from the relevant provider subject to your permissions.

7.2. We also generate data automatically through your use of the Service.

8. Sharing and Disclosure

8.1. Processors. We engage trusted processors to support Service operation, such as:

a) Firebase (Google) for authentication, analytics, Firestore Database, Storage, Crashlytics, and related functions;

b) Google Play Console for app performance;

c) Hotjar Ltd. (planned) for product analytics and user experience research.

These processors act under written contracts meeting Article 28 GDPR.

8.2. Payments (Future). If subscriptions are introduced, transactions will be handled by the relevant app store or a certified payment processor. Their privacy notices will apply in addition to this Policy.

8.3. Legal Compliance and Protection. We may disclose data if required by law, regulation, legal process, or governmental request, or to protect our rights, users, or the public.

8.4. Corporate Events. In the event of a reorganization, merger, or transfer of assets, personal data may be transferred subject to this Policy and applicable law.

8.5. We do not sell personal data.

9. International Data Transfers

9.1. We store and process personal data within the European Union.

9.2. If a future transfer outside the EU becomes necessary, we will implement appropriate safeguards under Chapter V GDPR (e.g., Standard Contractual Clauses) and will update this Policy accordingly.

10. AI, Voice, and Automated Decision-Making

10.1. AI Chat and Personalization. We use AI to deliver learning assistance and conversational practice. AI outputs may not always be accurate and should not be relied upon for professional advice.

10.2. Voice and Speech Processing (If Enabled). If voice features are offered, audio may be processed for recognition and transcribed for feature delivery. Voice recordings, where used, will be limited to the purposes described herein. We do not use voice data to develop voice cloning technology.

10.3. Automated Decision-Making. We do not make decisions producing legal effects solely by automated means within the meaning of Article 22 GDPR.

11. Data Retention

11.1. We retain personal data for as long as your account remains active.

11.2. When you delete your account through the in-app function, associated personal data is permanently erased without undue delay, subject to any retention required by law (e.g., for fraud prevention or record-keeping).

12. Security

12.1. We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, alteration, or destruction.

12.2. While we strive to protect your data, no system can be guaranteed to be fully secure.

13. Your Rights (GDPR)

13.1. You have the rights of access, rectification, erasure, restriction, objection (including to processing based on legitimate interests), and data portability, as set out in Articles 15–21 GDPR. Where processing is based on consent, you may withdraw consent at any time.

13.2. To exercise your rights, contact legal@masteroflanguages.com. We may need to verify your identity.

13.3. You have the right to lodge a complaint with a supervisory authority. Without limitation, you may contact the Bulgarian Commission for Personal Data Protection. We encourage you to contact us first so we can address your concerns.

14. Children

14.1. The Service is not directed to children under 13, and we do not knowingly collect their data. If you believe a child under 13 has provided personal data, please contact us so we can delete it.

15. Advertising and Marketing

15.1. The Service currently does not display advertising or engage in remarketing.

15.2. If we introduce advertising in the future, we will comply with applicable law and provide required consent and opt-out controls before enabling personalized advertising.

16. Subscriptions and Payments (Future)

16.1. If we introduce paid subscriptions, the applicable terms will be presented at purchase. Payments will be handled by Google Play and Apple App Store or, where used, a certified payment processor. Refunds and cancellations will follow the respective store’s rules.

16.2. We do not directly store full payment card details.

17. Community and Social Features (Future)

17.1. If we introduce challenges, leaderboards, or instructor-AI chat with social features, your display name, progress indicators, and related metrics may be visible to other users, subject to your settings.

17.2. We may moderate content to enforce our rules and applicable law.

18. Language and Precedence

18.1. This Policy is published in English and Bulgarian. In the event of inconsistency, the Bulgarian version prevails.

19. Contact

For any questions or to exercise your rights, contact: legal@masteroflanguages.com.