Contents

  1. Who We Are
  2. What Data We Collect
  3. How We Use Your Data
  4. Third-Party Services
  5. Audio & Microphone
  6. Camera & Photos
  7. Data Storage & Retention
  8. Your Rights (GDPR & CCPA)
  9. Children's Privacy
  10. Security
  11. Changes to This Policy
  12. Contact Us
01

Who We Are

SinoSpark ("we", "us", or "our") is a Chinese language learning application available on iOS and Android. We are the data controller for personal data collected through the SinoSpark app and this website.

If you have questions about this policy, you can reach us at contact@sinospark.app.


02

What Data We Collect

We collect only what is necessary to provide you with the best Chinese learning experience. Here is a full breakdown:

Data Type Source Linked to You? Used for Tracking?
Email address Account registration / Google Sign-In Yes No
Display name Profile settings Yes No
Profile photo URL Google Sign-In (your Google avatar) Yes No
Study progress & flashcard data App usage Yes No
Purchase history RevenueCat (subscription manager) Yes No
Audio recordings Pronunciation grading / Shadowing Studio No No
Camera images Universal Scanner / AR Lens No No
App usage analytics Firebase Analytics (anonymous) No No
Crash reports Firebase Crashlytics (anonymous) No No
We do not sell your personal data. We never share your data with advertisers or data brokers.

03

How We Use Your Data

We use the data we collect exclusively to:


04

Third-Party Services

SinoSpark relies on the following third-party services to function. Each has its own privacy policy:

Service Purpose Data Sent
Firebase (Google) Authentication, database (Firestore), analytics, crash reporting User ID, email, study data, anonymous events
OpenRouter AI language features (Scholar's Desk, definitions, grammar) Text inputs — no personally identifying information
Azure Speech (Microsoft) Pronunciation grading and speech assessment Short audio clips — processed in real-time, not retained
RevenueCat Subscription & in-app purchase management User ID, product IDs, transaction IDs
Google Sign-In OAuth authentication Email address, display name, profile photo URL
Google ML Kit On-device OCR and handwriting recognition Processed entirely on-device. No data sent to Google.
🔒 Zero Data Retention policy: For our AI providers (OpenRouter / Azure Speech), we explicitly request that data is not retained or used for model training. We use API tiers and configurations that enforce this.

05

Audio & Microphone

SinoSpark requests microphone access for the following features:

Audio is evaluated in real-time and immediately discarded. We do not store, archive, or retain your voice recordings on our servers. Audio sent to Azure Speech for grading is processed under a Zero Data Retention agreement.

06

Camera & Photos

SinoSpark requests camera and photo library access for:

✅ Camera frames and imported images are processed entirely on-device using Google ML Kit. Images are not uploaded to our servers or any third-party service.

07

Data Storage & Retention

On-device storage: Your flashcard library, spaced-repetition schedules, and app settings are stored locally on your device using Hive (an encrypted local database).

Cloud storage: Your study progress and account data are synced to Firebase Firestore so you can restore them if you switch devices. This data is associated with your Firebase User ID.

Retention: We retain your account data for as long as your account is active. If you delete your account, all cloud data is permanently deleted within 30 days. Local data can be removed by uninstalling the app.

Audio: Not stored. Discarded immediately after processing.

Camera images: Not stored. Processed on-device and discarded.


08

Your Rights (GDPR & CCPA)

Depending on where you live, you may have the following rights over your personal data:

To exercise any of these rights, contact us at contact@sinospark.app. We will respond within 30 days.

🇨🇭 Swiss residents (nDSG): You may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC / EDÖB) at www.edoeb.admin.ch, Feldeggweg 1, 3003 Berne.

🇪🇺 EU residents (GDPR): You may lodge a complaint with your local EU data protection supervisory authority.

09

Children's Privacy

⚠️ SinoSpark is not directed at children under the age of 13 (or 16 in the European Union). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately and we will delete it.

10

Security

We implement industry-standard security measures to protect your data:

While we take security seriously, no method of transmission over the internet is 100% secure. We encourage you to use a strong, unique password for your account.


11

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. For significant changes, we will notify you via an in-app notification.

Your continued use of SinoSpark after any changes constitutes your acceptance of the updated policy.


12

Contact Us

For any privacy-related questions, data requests, or concerns, please reach out. We aim to respond to all inquiries within 30 days.

Questions about your privacy?

We're committed to transparency. Don't hesitate to ask.

contact@sinospark.app