Privacy Policy

Last updated: September 26, 2026
Effective Date: September 26, 2026

Welcome to LingoMate：AI English Tutor !

This Privacy Policy (” Policy “) applies to LingoMate mobile application, official website, in-app features and related services (collectively, the “Service”). FUNCONNECT PTE.LTD. (”we”, “us” ,“our”) is the service provider and operator of LingoMate Services. We value and respect your privacy, and we are committed to protecting it in compliance with this Privacy Policy and applicable laws and regulations. This Policy aims to provide you (” you “,” User “) with an understanding of our practices concerning the collection, use, share and storage of personal information we collect from or about you when you interact with us, as well as your rights regarding the information you provide and how we safeguard those rights. By accessing and using LingoMate Services, you agree to be bound by this Policy. If you do not agree with this Policy, in whole or in part, you should not use the LingoMate Services.

We strongly advise you to read this Policy carefully to understand our practices regarding your personal information. We also recommend visiting this Policy frequently to stay informed of any updates. If you have any questions, please feel free to contact us at lingomate@funconnectsg.com.

This Policy will help you understand the following contents:

1.What Information We Collect About You

2.How We Use Your Information

3.How We Share Your Information

4.Minimum Age Requirements for Our Sites and Services

5.Your Rights and Choices

6.Data Retention and Security

7.Third-Party Services

8.International Data Processing and Transfer

9.Update of this Policy

10.How to Contact Us

1. What Information We Collect About You

We will follow the principles of what is rightful, legal and necessary to collect and use the personal information that you voluntarily provide to us, obtained by us from third parties and automatically collected during your use of our Platform and Services. If we want to process your personal information for other purposes not specified in this policy, or use the information we have collected for other purposes based on a particular purpose, we will notify you in a reasonable manner and seek your consent (when required by applicable data protection laws) again before using it.

We collect information about you through various means when providing the LingoMate Services. Please note that certain types of information are necessary for us to provide the LingoMate Services to you. If you choose not to provide us with such information or request its deletion, you may no longer be able to access or use the LingoMate Services. We collect your information in the following ways:

1.1 Information You Provide Directly:

• Account Information: The information you provide when registering for and using an account, such as username, profile picture. This information is used to create and manage your account, ensuring that you can access and use our services smoothly.
• User Content: The prompts and other content that you input and generate while using our products and services. This information helps us understand your needs and preferences, so that we can provide you with more accurate services and support.
• Payment Information: Please note that we use third-party payment processors (such as the Apple App Store) to handle your payments. Consequently, we do not retain any personally identifiable information related to payments; all such information is provided by you directly to our third-party payment processors. The payment processors’ use of your personal data is governed by their respective privacy statements.
• Marketing Contact Information: If you request LingoMate to contact you, or sign up for marketing materials or events, LingoMate may collect information such as name, address, email address, telephone number. This may be collected through the Website as well as through the use of the LingoMate Services.
• Copyright Complaint nformation: If you submit a copyright complaint, counter-notice, or other rights request, or if your content is the subject of such a complaint, we may collect your name, email address, phone number, rights documentation, electronic or physical signature, information identifying the disputed content, statements, authorization documents, and communications related to the request.
• Troubleshooting Information: If you contact LingoMate’s customer support, we will collect information about you related to your account and the requests you are making.
• Any Information You Voluntarily Provide to Us.

1.2 Information We Collect Automatically:

• Device and Log Information: such as IP information, device model, operating system, browser type, app version, mobile network, language settings, time zone, device identifiers, advertising identifiers, installation ID, crash logs, diagnostics, and access timestamps.
• Usage and Interaction Data: such as feature clicks, generation counts, parameter selections, time spent, saves, downloads, shares, conversation records, and safety-review records.
• Anti-fraud and Security Data: such as device fingerprints, abnormal requests, login risk, automation signals, proxy or VPN risk, repeated-account linkage signals, and content-safety review results.
• Web Logs: such as pages visited, referring pages, click paths, browser events, session status, cookie-consent status, checkout events, and web error diagnostics.
• Cookies and Tracking Technologies: When you visit the LingoMate website or web application we may use cookies, local storage, session storage, pixel tags, SDKs, device identifiers, and similar technologies to collect or store information. You can clear or block cookies through your browser settings and may manage non-essential cookies through any cookie preference tool we provide. Disabling necessary cookies may prevent login, checkout, security verification, project saving, or other web features from working properly.

1.3 Information We Obtain from Other Sources:

• Vendors and Partners: We may receive information about you from third-parties such as vendors, resellers, or partners. For example, our sales and marketing teams may receive access to third-party databases containing information to enrich business contacts and other corporate data. We will explain this to you at the time of collection and obtain your consent.
• Payment Status: Apple or other payment processors may provide order numbers, subscription status, payment confirmations, refund status, chargeback status, billing email address, billing country or region, transaction tokens, customer or subscription identifiers and anti-fraud status. We do not receive or store complete card numbers, login credentials, or complete bank account information.
• Legal, Safety, and Platform Information: When handling unlawful content, fraud, security incidents, or legal requests, we may receive information from regulators, law enforcement, platform providers, or security service providers.
• Other Methods. We may also use other methods to collect additional information about you, your device, or your use of the services. We will explain these methods to you at the time of collection and obtain your consent if required by applicable laws.

1.4 Device Permission Access

When you use our products and/or services, we need/may need to collect and use some of your personal information. The types of personal information we collect and use include: Information required for the core business functions of our products and/or services: This type of information is necessary for the normal operation of the products and/or services, and you must authorize us to collect it. If you refuse to provide it, you will not be able to use our products and/or services normally. In order to provide services, we will call some of your system permissions. Below we list the business functions corresponding to the requested permissions, the purpose of the call, and the actual request. For the permissions below, you can choose to turn them off in the system settings function, but if you turn off the call of basic business functions, you may not be able to use this related function.

• Microphone/recording permissions

  • Purpose of use: Send voice messages
  • Usage scenarios: Send voice messages in the chat window
  • Access method: Obtain after the user actively agrees
  • Please note that before you input your voice, we will request access to your microphone to collect your voice information for providing you with speaking practice services. Human voice audio is sensitive personal information. Please note that the aforementioned process does not involve voiceprint extraction. Microphone access is a sensitive permission; you can choose not to agree to or refuse microphone access authorization. Refusing this permission will affect your interaction with this product via voice, but will not affect your normal use of other functions of this product. Furthermore, any audio you agree to send to this platform will be anonymized upon arrival at our servers to ensure that your other personal information is not associated with the audio.

• File and media access permissions

  • Purpose: Store conversation messages
  • Use scenarios: Store historical messages in user conversation tasks in the APP; change user avatars, etc.
  • Access method: Obtain after the user actively agrees

1.5 Third-Party AI Service Providers

To support AI dialogue and interaction, this service may integrate with or invoke the services of trusted third-party artificial intelligence service providers (hereinafter referred to as “AI service providers”). When you use the above functions, your text prompts and related input (including your input dialogue records or other text, your input voice content, images or other media, if applicable) may be securely transmitted to the corresponding AI service provider for real-time or near real-time processing. AI Providers include: ElevenLabs Inc. (ElevenLabs for real-time voice, speech recognition, and speech synthesis), OpenAI, L.L.C. (GPT for text chat and learning feedback), Google LLC (Gemini for conversation text processing and reply generation), Anthropic, PBC (Claude for conversation text processing and reply generation), and BytePlus Pte. Ltd. (Dola-Seed series for speech recognition).

AI Provider data retention. We require and have confirmed that the aforementioned third-party AI service providers provide the same or equal data privacy protection as this Policy. We require AI Providers to retain user data only for the shortest period necessary to complete the processing request and to delete it from temporary processing systems after the task is completed, unless limited retention is required for legal, regulatory, security, abuse-prevention, audit, or dispute-handling purposes. Unless you separately and expressly consent or applicable law permits otherwise, we do not authorize AI Providers to use your non-public User Inputs, private project files, original voice recordings, personal voice models, or private Content from minor accounts to train their general foundation models.

Please note that we are not responsible for the privacy practices of our service providers and business partners, and their information practices are not covered by this Policy. We may aggregate or de-identify the information described above, and such aggregated or de-identified data is not subject to this Policy.

1. How We Use Your Information

We use the information we collect from you to ensure the operation, maintenance, enhancement, and development of all features, functionality, and services offered on LingoMate Services. Here is an overview of how we use your information:

• Security and Fraud Prevention. We use your information to provide security for our websites, products, software, and applications. This includes preventing fraud and abuse.
• Service Provision and Support. We use your information to fulfill your requests for services, support, and information. This includes internal operations such as troubleshooting, testing, research, statistical analysis, data analysis, and soliciting your feedback.
• Content Review and Compliance. Including reviewing content that may violate these Terms, involve child-safety risks, non-consensual intimate content, infringement, fraud, hate, violence, unlawful conduct, or other high-risk activity. Legal bases may include legitimate interests, legal obligations, and protection of important public interests.
• Improving and Developing LingoMate Services. We use your information to improve and develop LingoMate Services, ensuring that we continue to enhance the platform based on user feedback and needs.
• Communication and Feedback. We use your information to communicate with you and respond to your feedback. This enables us to address your inquiries, provide support, and keep you informed about updates and developments.
• Enforcement of Policies. We utilize your information to enforce our Terms of Service and other policies to maintain a safe and positive environment for all users.
• Sales and User Support. We use your information to facilitate sales, promotions, and purchases of goods and services on LingoMate Services.
• Legal Requests and Rights Protection. Including handling appeals, law-enforcement requests, regulatory communications, disputes, claims, audits, compliance records, and legal defenses. Legal bases may include legal obligations and legitimate interests.
• Copyright Complaints and Rights Protection. Including receiving, verifying, and processing copyright complaints, DMCA notices, counter-notices, infringement disputes, repeat-infringer determinations, notice forwarding, record retention, and related legal defenses. Legal bases may include legal obligations, legitimate interests, and, where applicable, processing necessary to protect rights holders and the platform.

In certain cases, we may seek your consent to process your personal information for specific purposes. If you provide consent, you can withdraw it at any time, and we will cease processing your data for that purpose.

1. How We Share Your Information

LingoMate does not sell your personal information to third parties. We only disclose information on a need-to-know basis where appropriate safeguards and contractual arrangements are in place and as described below.

3.1 Delegation to Affiliates

We may delegate the processing of your personal information to our affiliates to fulfill the purposes described in this Policy. Such delegation will be within the scope of the purposes described, and we ensure that our affiliates comply with the provisions of this Policy regarding the retention of personal information.

3.2 Service Providers and Business Partners

• Service Providers. Including cloud storage, computing, content delivery, databases, crash analytics, customer support, email, cookie management, web analytics, anti-fraud, content safety, log analytics, and other technical service providers. These providers may process data only according to our instructions and must follow confidentiality and security obligations.
• Third-Party AI Service Providers. The selected AI service provider will process your text prompts and other inputs as needed to support AI conversations and interactions.
• Third-Party Payment Processors and App Stores. Including Apple or other payment processors, which independently process payment information, payment-account information, anti-fraud signals, refunds, chargebacks, and accounting records. We only receive the limited transaction status and subscription information necessary to provide the service.

3.3 Corporate Transactions

In the event of a substantial corporate transaction such as the sale of a website, merger, consolidation, asset sales, or bankruptcy, we may share all the information we collect.

3.4 Legal Compliance and Protection

We may disclose your information when required by law, subpoena, or other legal process, or when we have a good faith belief that disclosure is reasonably necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, assist government enforcement agencies, enforce our agreements with you, investigate and defend against third-party claims or allegations, protect the security or integrity of our services, or exercise or protect the rights and safety of LingoMate, our users, personnel, or others. We strive to notify users about legal demands for their personal information unless prohibited by law or court order, or in case of emergencies. We may choose to challenge such demands when we believe they are overbroad, vague, lack proper authority, but we do not guarantee to challenge every demand.

We may disclose your information with other third parties with your consent.

3.5 Copyright Complaints and Rights-Protection Records

To process copyright complaints, counter-notices, infringement disputes, repeat-infringer matters, or other rights-protection requests, we may disclose relevant notice contents, contact details, content-location information, and processing records to complainants, affected users, authorized agents, legal advisors, service providers, courts, regulators, or law enforcement authorities as necessary.

1. Minimum Age Requirements for Our Sites and Services

The Sites and Services are not directed or intended for use by individuals under the age of 14 (or the higher minimum age required by the law where you live) . To use LingoMate’s Sites and Services, you must be old enough to consent to the processing of your information in your jurisdiction. We do not knowingly collect personal information from anyone under the age of 14. If you are a parent or guardian and you become aware that your child has provided us with personal information, please contact us.

If we discover that a minor under the age of 14 (or the higher minimum age required by the law where you live) has provided us with personal information in violation of applicable laws, we will delete the information collected and terminate the minor’s account, unless we are legally obligated to retain such information.

1. Your Rights and Choices

5.1 Your Rights Relating to Your Personal Data

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your Personal Data held by us;
• Know more about how we process your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
• Erase your Personal Data;
• Restrict our processing of your Personal Data;
• Transfer your Personal Data to another controller, to the extent possible;
• Object to any processing of your Personal Data;
• Opt out of certain disclosures of your Personal Data to third parties;
• If you’re under the age of 14, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt-in to certain disclosures of your Personal Data to third parties;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
• Not be discriminated against for exercising your rights as described above.

Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

5.2 How to Exercisey Your Rights

To exercise your rights, please contact us by using the information in Section 10 Your Personal Data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive, we will provide you with a clear explanation at that time.

5.3 Users in the European Economic Area, the United Kingdom, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may exercise rights of access, rectification, erasure, restriction, data portability, objection, withdrawal of consent, and complaint to a supervisory authority under applicable data protection laws. Our legal bases for processing personal data include contract performance, your consent, legitimate interests, legal obligations, and, in limited cases, protection of vital interests or public interests.

5.4 U.S. State Privacy Rights

If you are located in California, Texas, or another U.S. state with an applicable privacy law, you may have rights to know, access, correct, delete, receive data portability, opt out of sale or sharing, opt out of targeted advertising, limit use of sensitive personal information, appeal, and be free from unlawful discrimination for exercising privacy rights. We will not treat you in an unlawfully discriminatory manner because you exercise your privacy rights.

1. Data Retention and Security

6.1 Data Retention

We retain your information for the minimum necessary period to fulfill our legal and contractual obligations, develop our Sites and Services, resolve disputes, enforce our rights, for legitimate business purposes, such as tax or accounting requirements, as described in this Notice and as recommended by industry standards.

When we no longer have an ongoing legitimate business need to process your information, we will either delete or anonymize it. When we choose to anonymize information, we strive to make sure that the information cannot be linked back to you or any specific user. If deletion is not possible (e.g., backups), we will store it securely.

6.2 Data Security

We employ various managerial, technical, and physical measures to safeguard the integrity and security of your information. The specific measures used may depend on the sensitivity of the information. However, it’s important to understand that no security measures or systems can provide absolute guarantee of protection. We evaluate these measures on a regular basis to ensure the security of the processing.

Please remember that you control what personal information you provide while using the LingoMate Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the LingoMate Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through the LingoMate Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the LingoMate Services, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the LingoMate Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.

If you have any questions about the security of our Sites and Services, please feel free contact us.

1. Third-Party Services

Our Sites and Services may contain links to or integrations with other websites or applications not operated or controlled by LingoMate (“Third-Party Services”). Certain Third-Party Services used to navigate to and from our Sites and Services have separate user terms and privacy notices that are independent of this Notice. We are not responsible for the content, accuracy, or opinions expressed in such Third-Party Services. We do not monitor or check these Third-Party Services for accuracy or completeness. We recommend carefully reviewing the terms and privacy notices of each Third-Party Service prior to use in alignment with your specific compliance, privacy, and security requirements.

1. International Data Processing and Transfer

To provide our Sites and Services, LingoMate may store, process and transmit your information outside of your country of residence, which may have different data protection laws and may not offer the same level of protection or guarantees as in your country or the country where you initially provided the information. We ensure that all transfers comply with applicable laws using appropriate safeguards, such as:

• Adequacy Decisions: Transferring data to countries recognized as providing an adequate level of data protection by relevant authorities (e.g., the European Commission for EEA users).
• Standard Contractual Clauses: Using approved contractual protections for transfers where adequacy decisions do not apply.
• User Consent: Obtaining your explicit consent where required by law.

We take appropriate measures to ensure recipients protect your information in line with this Policy and applicable laws.

1. Update of this Policy

We reserve the right to periodically update or modify this Policy to reflect changes in our business, technology, and relevant laws and practices. Whenever we make updates to the Policy, we will notify you by updating the “Last Updated” date at the top of the revised Policy, or providing any other notice as required by applicable law. We strongly recommend that you review the Policy each time you visit LingoMate to stay informed about our current privacy practices .

1. How to Contact Us

If you have any comments, questions, concerns or requests regarding this Policy or our practices related to the protection of personal information, please feel free to contact us at lingomate@funconnectsg.com. To ensure a prompt and efficient response, please label your email subject line as “LingoMate Privacy Policy request.” Our Data Specialist is responsible for overseeing and implementing our personal information protection strategy, as well as ensuring compliance with applicable laws and regulations. We will make every effort to review your requests promptly, verify your user identity, and respond within the timeframe required by any applicable law. If your request involves complex or significant issues, we may require additional information.