Privacy Policy

1. General

This Privacy Policy explains how EUP TECHNOLOGY.,JSC (“EUP”, “we”, “us”) collects, uses and shares personal information when you use the AI Kit Tutor mobile app (“AI Kit” or the “App”), the website aikit-legal.web.app and related services (together, the “Service”). By using the Service, you agree to the collection, use and sharing of your information as described in this Privacy Policy. If you do not agree, please do not use the Service.

AI Kit is a 1-on-1 AI tutor for foreign languages and school subjects, made for secondary school and university students. The App shows no advertising, has no in-app purchases and does not track you across apps or websites owned by other companies.

EUP keeps testing and improving the Service. Some features described here may not be available to all users or in all countries.

2. Information we collect

a. Guest and account information

When you first open the App, we create a guest account with a random user ID so that your progress can be saved. You do not need to give us your name or email address to use the App.

If you choose to sign in with email and password, Google or Apple, we receive your email address and, from Google or Apple, the name on that account if you share it. With Sign in with Apple you can hide your real email address. We do not ask for your phone number.

b. Information you give during setup

Your age (required, so that we can ask a parent to confirm when needed and choose suitable examples), an optional nickname, your school grade or level, the languages and subjects you study, your goals, exam dates and preferred pace, and the language of the App. If you are under 14, we also keep a record that a parent or guardian confirmed, with the date and the age entered.

c. Your learning data

Your chats with Kit, learning paths, lessons and answers, test results, the mistakes Kit remembers, flashcards, notes, study materials you add and pronunciation results. AI Kit has no public profile and no social features: other users cannot see your learning data.

d. Photos, files and voice you choose to send

You can choose to send Kit a photo (from your camera or photo library), a document such as a PDF, or your voice (talking with Kit, pronunciation practice, recording a lecture). This content is sent to our AI service providers to answer your request (see Section 4). We do not store the photo, file or audio on our servers; your chat history keeps only a label, such as a file name, and Kit’s reply. Lecture recordings stay on your device.

Some speech-to-text features use the speech recognition built into your device’s operating system, which is provided under the terms of your device maker.

e. Handwriting, text scanning and dictionary lookups

Handwriting practice is checked on your device, and text in photos you scan for lookups is recognized on your device. When you look up a word or character, the search text is sent to dictionary services operated by EUP (Mazii and Hanzii) to return results. It is not sent with your user ID.

f. Support, feedback and surveys

When you message support, send feedback or answer a survey in the App, we receive your message, your user ID, the App version and the App language. If you email us, we receive your email address and what you write.

g. Usage, device and diagnostic data

When you use the App, we receive:

• which screens and features you use and when (usage statistics);
• the App version, device model, operating system, language and an approximate location (country or city) derived from your IP address;
• app and device identifiers that are not used for advertising, such as an installation ID, a notification token and a random ID used to sync your devices;
• crash reports and performance measurements. Crash reports include your user ID so that we can fix problems with your account.

You can turn off usage statistics and error reports at any time in Settings › Privacy › App usage data. We do not collect your precise location or your contacts, and we do not use advertising identifiers.

h. Notifications

If you allow notifications, we receive a notification token and subscribe your device to topics based on your App language and the subjects you study, so that we can send study reminders and news about AI Kit. Reminders you set are scheduled on your device.

i. Our website

Our website does not use cookies or analytics. It remembers your language choice in your browser’s local storage and loads fonts from Google Fonts, which receives your IP address when the page loads.

3. How we use your information

We use your information to:

• provide the tutoring service: build your learning path, lessons and tests, answer your questions, check your answers and pronunciation, and remember your mistakes and progress;
• personalize the Service: adapt explanations, examples and difficulty to your age, level, goals and past work;
• save and sync your learning data, including across devices when you sign in;
• provide support and respond to your feedback;
• keep the Service safe and working: sign you in, prevent abuse and fraud, fix crashes and measure performance;
• understand, in aggregate, how the App is used so that we can improve it;
• send the notifications you allowed;
• comply with the law and protect our rights and the rights of others.

Where the GDPR or a similar law applies, we rely on these legal bases: performance of our contract with you (providing the Service), our legitimate interests (security, improving the Service, aggregated statistics), your consent or your parent’s consent (for example notifications, and parental confirmation for users under 14), which you can withdraw at any time, and our legal obligations.

We do not sell your personal information, we do not use it for advertising, and we do not share it for cross-context behavioral advertising.

4. How AI processes your information

Kit is powered by artificial intelligence models from third-party AI service providers. When you chat with Kit, send a photo, file or voice, or when the App builds a lesson, test or learning path, we send the content of that request to an AI service provider through our cloud platform. We include the learning context needed to answer well, for example your level, goals, age, nickname, the subjects you study and the mistakes Kit remembers.

• We do not send your email address, password or sign-in details to AI service providers, and requests are not sent with your user ID.
• AI service providers process this content to generate Kit’s responses. They may keep it for a limited time under their terms, for example to detect and prevent abuse.
• EUP does not use your chats, photos, files or voice to train AI models.
• AI responses can be wrong or incomplete. Check important information, such as exam dates and rules, with your teacher, your school or the official organizer.
• Do not include sensitive information, such as passwords, ID numbers, health details or other people’s personal information, in chats, photos or recordings. The App reminds users under 18 about this before they send a photo.

To show real pictures and facts in lessons, the App searches public sources such as Wikipedia, Wikimedia Commons, iNaturalist, NASA, PubChem, The Metropolitan Museum of Art, the Cleveland Museum of Art and Openverse using the lesson topic. These searches do not contain your personal information, but those sites receive your device’s IP address.

You can delete your chats with Kit by erasing your learning data or deleting your account (see Section 9).

5. Children and parental consent

AI Kit is designed for secondary school and university students. During setup, the App asks your age.

• If you are under 14, a parent or legal guardian must confirm in the App that they agree to this Privacy Policy and to the Service using the child’s information before the child can continue. We keep a record of that confirmation.
• Where the law of your country requires a parent’s consent for children older than 14, a parent or guardian should set up and use the App together with the child and give that consent.
• Parents and guardians can ask to review, download or delete their child’s information, or withdraw their consent, by emailing minhnt@eupgroup.net. After we verify the request, we will act on it, and withdrawing consent means we delete the child’s data.
• If we learn that we collected information from a child without the parental consent required by law, we will delete it.
• We do not show ads to anyone, and we do not sell children’s information.

6. How we share information

We share personal information only in these cases:

a. Service providers that work for us

• Firebase, for our cloud database, sign-in, hosting, usage statistics, crash reporting, performance monitoring, remote configuration and notifications;
• third-party AI service providers (see Section 4);
• EUP’s dictionary services (Mazii, Hanzii).

These providers may use the information only to provide services to us and must protect it.

b. Sign-in providers

If you sign in with Google or Apple, they handle your sign-in under their own privacy policies.

c. YouTube

Some features play YouTube videos inside the App through YouTube’s embedded player, which uses YouTube API Services. When you watch a video, YouTube may collect information about your device and viewing. This is governed by the YouTube Terms of Service and the Google Privacy Policy.

d. Legal requirements and protection

EUP may process and share personal information if necessary to comply with legal requests, such as subpoenas or court orders. EUP may share personal information when we believe it is necessary to comply with the law, to protect our interests or property, to prevent fraud or other illegal activity, to assist law enforcement, or to prevent imminent harm. This may include sharing information with other companies, lawyers, agents or government agencies.

e. Business transfers

If EUP is involved in a merger, acquisition or sale of assets, personal information may be transferred as part of that transaction. We will tell you before your information becomes subject to a different privacy policy.

f. With your consent

We share information in other ways when you ask us to or agree, for example when you export your data and send the file to someone.

g. Anonymous information

EUP may process aggregated, de-identified or otherwise anonymous information for any purpose. Such information is not personal information.

7. Data storage and international transfers

Our cloud database is located in the United States, and our service providers may process data in other countries. EUP is based in Vietnam. These countries may not provide the same level of data protection as your home country. When we transfer your information, we take steps required by applicable law to protect it.

EUP is responsible for the processing of personal information it receives under the Vietnamese law on personal data protection, including Decree No. 13/2023/ND-CP on Protection of Personal Data, and remains responsible when a third party processes that information on its behalf. The Ministry of Public Security of Vietnam has jurisdiction over EUP’s compliance. EUP may disclose personal information in response to lawful requests by Vietnamese authorities, including to meet national security or law enforcement requirements.

8. Data retention

• Profile, learning data and chats with Kit: until you erase your learning data or delete your account.
• Support chats, feedback and survey answers: until you delete your account, or earlier when we no longer need them.
• Parental confirmation record: as long as we keep the child’s learning data.
• Crash reports: up to 90 days. Usage statistics: up to 14 months.
• Content sent to AI service providers: for the limited time allowed by their terms.
• Guest data: if you uninstall the App without erasing your learning data, the data stays linked to a guest ID that we cannot connect to you. We may delete guest data that has not been used for a long time.

We may keep certain information longer if necessary to comply with legal requirements, resolve disputes, investigate misuse of the Service or enforce our agreements. We may keep anonymous data indefinitely.

9. Your choices and rights

In the App

• Settings › Privacy › App usage data: turn usage statistics and error reports on or off.
• Settings › Privacy › Download your data: get a copy of your learning data as a file.
• Settings › Erase all learning data: delete your learning data on the device and on our servers, and keep your account.
• Settings › Account › Delete account: delete your account, your learning data, your support chats, feedback and survey answers.
• Notifications: turn them off in your device settings.

Without the App, you can ask us to delete your account by emailing us from your account’s email address (see the Support page).

Your rights

Depending on where you live, you may have the right to:

• know what personal information we have collected about you, and with whom we have shared it;
• access and receive a copy of your personal information, in a format you can transfer to another service;
• correct inaccurate personal information;
• delete your personal information;
• restrict or object to our processing of your personal information;
• withdraw any consent you gave us;
• not be discriminated against for exercising your rights;
• lodge a complaint with a data protection authority.

To make a request, email minhnt@eupgroup.net. We may need to verify your identity first. These rights are not absolute: EUP may refuse a request if there is a legitimate reason, for example if we cannot verify your identity, if the request would violate the rights of others or the law, or if it would prevent us from delivering a service you asked for.

10. Security

We protect your information with measures such as encryption in transit, access controls and security rules that let each account read only its own data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

11. Do Not Track

The Service is not designed to respond to “Do Not Track” signals sent by some browsers.

12. Links to third-party websites

The Service may contain links to other websites, such as video pages or official exam websites. EUP is not responsible for the content or privacy practices of other websites. This Privacy Policy applies only to information collected by EUP. When you open a link to a third-party website, that website’s privacy policy applies.

13. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If the changes are material, we will post a notice on our website, and where appropriate in the App, at least seven (7) days before the changes take effect, and we will update the date at the top of this page.

14. Information for certain regions

In some jurisdictions, the Service may be subject to supplemental privacy terms or local laws. Where they conflict with this Privacy Policy, they take precedence for users in those jurisdictions.

European Union, United Kingdom and Switzerland (GDPR): you have the rights in Section 9, including access, correction, deletion, portability, restriction and objection, and the right to complain to your supervisory authority.

California (CCPA): California residents have the right to know, access, delete and correct their personal information. We do not sell or share personal information as those terms are defined by the CCPA, and we do not use sensitive personal information for purposes that require an opt-out.

Virginia (VCDPA) and other U.S. states: residents have the right to access, correct, delete and obtain a copy of their personal data, and other rights provided by their state law.

Brazil (LGPD): Brazilian users have the right to access, correct, delete and port their data, and other rights provided by the LGPD.

To exercise any of these rights, email minhnt@eupgroup.net.

15. Contact us

EUP TECHNOLOGY.,JSC is the data controller of your data for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation. EUP’s headquarters are located in Vietnam at: Room 802, 8th Floor, 315 Truong Chinh Building, Khuong Mai Ward, Thanh Xuan District, Hanoi City, Vietnam.

For all privacy questions or concerns about this Privacy Policy, contact us at minhnt@eupgroup.net or visit https://eupgroup.net/.

Data Protection Officer (DPO): we have appointed a Data Protection Officer to oversee compliance with data protection regulations.

• Name: Mr. Nguyen Tuan Minh
• Email: minhnt@eupgroup.net
• Phone: (+84) 386 171 800