Privacy Policy
Effective Date: May 3, 2026
This Privacy Policy describes how your personal information is collected, used, and shared when you use the Orange: Chinese Study Tools mobile application (the “App”), created by Blue Otter Studio (the “Service Provider”). We are committed to protecting your privacy and handling your data in an open and transparent manner.
By using the App, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use the App.
1. Information We Collect
We only collect the minimal information necessary to provide and improve the App’s features.
a) Information You Provide Directly
- Email Address. When you create an account (e.g., by signing in with Apple, Google, or an email-based login), we may receive your email address from the authentication provider. We use your email solely to identify your account, sync your subscriptions across devices, and provide customer support.
- Purchase Information. All payments are processed by the official app store (Apple App Store or Google Play). We do not collect or store your credit card details, billing address, or full payment information. We receive a non-identifiable transaction identifier and a record of the purchase from the app store to unlock the paid content within the App.
b) Information Collected Automatically (Camera & Photos)
- Camera & Pictures. The App may request access to your device’s photos to let you put photos for study purposes (e.g. flashcard creation). When you grant permission, the App captures and stores these photos exclusively on your device. The images are processed entirely on-device; they are never uploaded to our servers, shared with third parties, or transmitted over the internet. You can revoke camera access at any time through your device’s settings.
c) AI Features & Third-Party Message Processing
The App offers optional AI-powered study features (e.g., intelligent explanations, grammar analysis, sentence generation, or conversation practice). When you choose to use these AI features:
- Message Transmission to Third Party: Your input (such as questions, Chinese sentences, vocabulary lists, or study prompts) is transmitted to a third-party artificial intelligence service provider (the “AI Provider”) to generate a response. This transmission is required to provide the requested AI functionality. The AI Provider acts as a subprocessor of your data solely for the purpose of delivering the feature’s output.
- No Storage of Your Messages: We do not store, log, retain, or backup copies of your messages or the AI-generated responses on our servers or any systems we control. Once the AI response is delivered to you within the App, the message content is immediately discarded from our systems and is not kept for any purpose.
- No Training or Model Improvement: We do not use any of your messages, prompts, or responses for training, fine-tuning, improving, or developing our own artificial intelligence models or the AI Provider’s models. We have contractually instructed the AI Provider to prohibit the use of your data for any training, model retention, or product improvement purposes. Your messages are processed ephemerally and are not used to improve any third-party AI system.
- AI Provider’s Role: The AI Provider receives your message in order to generate a real‑time response. Their processing occurs on their infrastructure and is subject to their own security practices. However, we restrict their ability to store, retain, or train on your data as described above. We encourage you to review the AI Provider’s privacy policy for transparency (e.g., OpenAI’s API data usage policy, or the applicable provider). Nevertheless, our contract with the AI Provider ensures that your messages are not used for training.
- Your Consent for AI Features: By using the AI-powered features within the App, you expressly agree to the transmission of your messages to the third-party AI Provider under the terms of this section. If you do not agree with this processing, you may choose not to use the AI features — the core study tools (flashcards, dictionary, offline learning) remain fully available without AI functionality.
d) Information We Do NOT Collect
- We do not use analytics, tracking, or advertising tools (such as Google Analytics).
- We do not collect device identifiers, IP addresses, location data, or logs of your activity.
- We do not send marketing or promotional emails. If you contact us by email, we will only use your email address to respond to your inquiry.
- We do not show ads or use remarketing services.
- We do not retain or store your AI conversations/messages after the response is generated (as detailed in section 1(c)).
2. How We Use Your Information
We use the collected information for the following purposes:
- To create and maintain your account.
- To process in-app purchases and unlock paid features.
- To communicate with you regarding support requests you initiate.
- To provide optional AI features: When you opt to use AI tools, we transmit your message to the third‑party AI Provider solely to generate a helpful response. No other use is made of those messages.
- To comply with legal obligations and enforce our terms.
3. Data Sharing and Disclosure
We do not sell, rent, or trade your personal information. We may share your information only in the following limited circumstances:
- Service Providers (including AI Provider). We engage a third‑party AI Provider to deliver the AI features you request. Your message is shared exclusively for the purpose of generating an AI response. This provider is contractually prohibited from storing your data, using it for training, or any purpose other than responding to your immediate request. Additionally, we use the official app store’s payment systems (Apple/Google) to process transactions. These providers may collect data according to their own privacy policies. We do not receive your full payment details.
- Legal Requirements. We may disclose information if required to do so by law or in response to valid legal requests (e.g., a court order).
- Business Transfers. In the event of a merger or acquisition, your information may be transferred as part of the transaction, provided the successor agrees to honor this Privacy Policy.
We do not share personal information for cross-context behavioral advertising.
4. Children’s Privacy
Our App is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately. We will take steps to delete such information from our records.
No part of the App is designed to attract anyone under 13, and we fully comply with the Children’s Online Privacy Protection Act (COPPA).
5. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal data.
a) For European Economic Area (EEA) and UK Residents – GDPR
If you are located in the EEA or the UK, you have the right to:
- Access – Request a copy of the personal data we hold about you.
- Rectification – Ask us to correct inaccurate or incomplete data.
- Erasure (“Right to be forgotten”) – Request deletion of your data, subject to legal retention requirements.
- Restriction of Processing – Ask us to limit how we use your data in certain circumstances.
- Data Portability – Receive your data in a structured, commonly used format.
- Objection – Object to processing based on legitimate interests (we do not rely on legitimate interests for any processing; we process data only with your consent or to fulfill our contract).
- Withdraw Consent – Where processing is based on consent (e.g., account creation or use of AI features), you can withdraw it at any time without affecting the lawfulness of prior processing. Withdrawing consent for AI features simply means you stop using those features; no retroactive effect on past transmissions.
Lawful Basis for Processing:
- Performance of a Contract: We process your email and purchase information to provide the services you requested (account, access to paid features).
- Consent: Camera access is based on your explicit consent, which you grant through the device permissions. AI feature processing is also based on your consent when you voluntarily use those tools. You may revoke consent by simply not using AI features.
To exercise any of these rights, please contact us at orange-app@outlook.com. We will respond within one calendar month. You also have the right to lodge a complaint with your local data protection authority.
b) For California Residents – CCPA & CPRA
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), California residents have the following rights:
- Right to Know / Access: You can request that we disclose the categories and specific pieces of personal information we have collected about you in the past 12 months.
- Right to Delete: You can ask us to delete personal information we have collected from you, subject to certain exceptions.
- Right to Correct: You can request correction of inaccurate personal information.
- Right to Opt-Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising. Therefore, there is no need to opt out. We will treat any browser “Do Not Track” signal as a valid opt-out preference, though we do not track you.
- Right to Limit Use of Sensitive Personal Information: We do not collect or process sensitive personal information (as defined by CPRA). The AI feature messages are ephemeral and are not retained or used for training; they do not constitute sensitive personal information under CPRA because we do not infer characteristics and we discard them immediately.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
Categories of Personal Information Collected in the Last 12 Months:
- Identifiers (e.g., email address)
- Commercial Information (records of products/services purchased)
- Audio, electronic, visual, or similar information (photos you take within the App; stored solely on your device)
- Internet or other electronic network activity information – ephemeral AI messages (not stored, transmitted in real‑time to AI Provider and not retained).
We have not sold or shared personal information in the preceding 12 months. We only use and disclose information for the business purposes described in this policy.
To exercise any California privacy rights, please email us at orange-app@outlook.com with the subject “CCPA Request.” We will verify your identity before processing the request. You may also designate an authorized agent to submit a request on your behalf.
c) For California Residents – CalOPPA
In accordance with the California Online Privacy Protection Act (CalOPPA), we make the following disclosures:
- Do Not Track (DNT): We do not track users over time and across third-party websites. Therefore, we do not respond to DNT signals differently, as no tracking occurs.
- Third-Party Tracking: We do not permit third parties to collect personally identifiable information about your online activities when you use the App, except for the limited and ephemeral transmission to the AI Provider when you actively use AI features. That provider is contractually bound not to track, retain, or use the data for any independent purpose.
- Effective Date & Updates: This policy will be reviewed and updated as necessary. The “Effective Date” above indicates the latest revision.
6. Data Retention
- Email & Account Data: Retained as long as your account remains active. If you request deletion or your account is inactive for 24 months, we will delete your email and associated records.
- Camera Photos: Stored only on your device. We never possess or retain copies; deletion is under your control via the App or device gallery.
- AI Feature Messages: We do not retain any messages or responses. They are transmitted to the AI Provider for real‑time response and are not logged, stored, or backed up by us. The AI Provider is also required to delete the message immediately after generating the response and may not use it for training or any other purpose.
- Purchase Records: Kept for the period required by applicable tax and accounting laws, after which they are securely deleted.
7. Security
We take reasonable administrative, technical, and physical measures to protect your personal information. However, no method of electronic storage is 100% secure. Your camera photos never leave your device, and we do not store them on any server. AI feature messages are transmitted over encrypted connections (TLS) to the AI Provider, and we ensure the provider maintains industry‑standard security. Account data is protected using industry-standard encryption.
8. International Data Transfers
The App and its operations are based in Qatar, but your data may be processed in any country where we or our service providers operate. For EEA/UK users, we ensure that any transfer of personal data to a third country is subject to appropriate safeguards, such as Standard Contractual Clauses. Since we collect limited data, the main transfers involve (i) your email via authentication providers (subject to their policies), and (ii) ephemeral AI messages sent to the AI Provider.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the effective date. We encourage you to review this policy periodically.
10. Your Consent
By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by the Service Provider. Specifically, by using any AI-powered feature in the App, you acknowledge and agree that your messages will be transmitted to a third‑party AI Provider for the sole purpose of generating a real‑time response, and you confirm your understanding that we do not store or train on your messages. If you do not agree with the AI feature terms, you may refrain from using those features without affecting the core functionality of the App.
11. Contact Us
For questions about this Privacy Policy, or to exercise your data protection rights, please contact us:
Email: orange-app@outlook.com
We will respond to all legitimate requests within the timeframe required by applicable law.
This Privacy Policy is drafted to comply with GDPR, CCPA/CPRA, CalOPPA, and COPPA, and includes specific disclosures for AI feature data handling.