Privacy Policy

Fluvo: Speak English with AI

Last updated: October 27, 2026

This Privacy Policy applies to the mobile application Fluvo: Speak English with AI (package name: com.fluvo.learn.speak.english) (the "Application"), developed and published by KIN CHUNG INVESTMENT GROUP LIMITED (hereinafter referred to as the "Service Provider"). The Application is provided as an ad-supported service and is provided "AS IS". By using the Application, you consent to the practices described in this Privacy Policy, and continued usage constitutes acceptance of any changes.

Definitions

For the purposes of this Privacy Policy:

• Application / App refers to Fluvo: Speak English with AI, the software program provided by the Company.
• Company (referred to as "the Company", "We", "Us" or "Our") refers to KIN CHUNG INVESTMENT GROUP LIMITED.
• Device means any device that can access the Service, such as a mobile phone or a digital tablet.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes data on behalf of the Company, including third-party companies or individuals employed to facilitate the Service, provide the Service, perform Service-related tasks, or assist in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of learning sessions or feature interactions).
• You means the individual accessing or using the Service, or the legal entity on behalf of which such individual is accessing or using the Service.

What information does the Application obtain and how is it used?

User-Provided Information

The Application does not require you to create an account or log in. You may use the Application without registration. In the course of using the Application, you may provide the following information:

• Voice / Audio Recordings: If you use the pronunciation and speaking-practice features, the Application requests access to your device's microphone to record your voice. Your speech is converted to text by your device's speech-recognition service (provided by Google), and the resulting text may be sent to our AI service to generate pronunciation and speaking feedback. The Application does not store or upload your audio recordings to our servers. Microphone access is optional and used only when you activate a voice feature.
• Text and Conversation Content: The questions, messages, and text you enter are transmitted securely through our server to OpenAI in order to generate tutoring responses, corrections, and learning content. This content is used only to deliver the core functionality of the Application and is retained only as long as necessary to provide the service. Please do not include sensitive personal information in your messages.
• App Preferences: Learning settings, language choices, and progress within the Application.
• Feedback & Communications: Ratings, feedback, bug reports, inquiries, or support communications you submit directly.

Automatically Collected Information

The Application may collect certain information automatically, including but not limited to:

• Device information, such as device type, model, manufacturer, operating system, and application version.
• Device identifiers, including advertising identifiers (such as the Google Advertising ID) and analytics-related identifiers.
• IP address and approximate (coarse) location derived from IP address, for analytics and service-optimization purposes.
• Application usage data, including session start and end times, features used, frequency of usage, crash logs, diagnostics, and performance data.

This automatically collected information is used to improve application performance, monitor system reliability, diagnose technical issues, provide analytics, support advertising, and enhance the overall user experience.

The Application does not use your device's camera, and does not collect precise real-time GPS location. Only coarse location derived from IP address may be collected for analytics and service optimization.

Do third parties see and/or have access to information obtained by the Application?

Yes. To provide its features, the Application shares certain data with third-party services that have their own privacy policies governing how they handle data. These include:

• Google Play Services & Google Play Billing – https://policies.google.com/privacy
• Google AdMob (advertising) – https://policies.google.com/technologies/ads
• Firebase (Analytics, Crashlytics, Firestore, Remote Config) – https://firebase.google.com/support/privacy
• AppsFlyer (install attribution and analytics) – https://www.appsflyer.com/legal/privacy-policy/
• Meta / Facebook SDK and Meta Audience Network – https://www.facebook.com/privacy/policy/
• Unity Ads – https://unity.com/legal/privacy-policy
• ironSource (Unity) – https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
• InMobi – https://www.inmobi.com/privacy-policy
• Pangle – https://www.pangleglobal.com/privacy
• Mintegral – https://www.mintegral.com/en/privacy
• Liftoff (Vungle) – https://liftoff.io/privacy-policy/
• OpenAI (AI tutoring responses) – https://openai.com/policies/privacy-policy

Advertising and attribution partners may receive device information, advertising identifiers, IP address, and ad-interaction data in order to serve, measure, and attribute ads. These third-party services may collect, process, or store your information independently of the Service Provider. All data transmitted by the Application is encrypted in transit. The Service Provider does not sell your personal information to third parties under any circumstances.

Disclosure of Information

The Service Provider may disclose User-Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena or similar legal process;
• when they believe in good faith that disclosure is necessary to protect their rights, your safety or the safety of others, investigate fraud, or respond to a government request;
• with trusted service providers who work on their behalf, do not have independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this Privacy Policy.

Advertising

The Application is supported by advertising provided through Google AdMob and its mediation partners listed above. These partners may use device and advertising identifiers to serve and measure ads, including personalized ads where permitted. Where required by law (for example, in the EEA and UK), the Application asks for your consent through a consent form before personalized ads are shown. You can manage or reset your advertising identifier through your device settings. For more information about how Google uses data when you use our Application, please see https://policies.google.com/technologies/partner-sites.

Subscriptions and Premium Services

If premium features are offered within the Application, all payments and billing are handled solely by the store platform (Google Play). The Service Provider does not collect or store your full payment credentials. The Service Provider may process subscription status, start, renewal, and expiration dates in order to manage access to premium features.

Data Retention

The Service Provider retains User-Provided data for as long as you use the Application and for a reasonable time thereafter. Automatically collected information is retained for up to 24 months, after which it may be stored in aggregated or anonymized form for analytics purposes only. To request deletion of data you have provided, contact the Service Provider at the email below.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13. The Application does not address anyone under the age of 13. If the Service Provider discovers that a child under 13 has provided personal information, that information will be deleted. If you are a parent or guardian and believe your child has provided us with personal information, please contact the Service Provider at the email below.

Security

The Service Provider is committed to safeguarding the confidentiality of your information and provides physical, electronic, and procedural safeguards to protect the information it processes and maintains, including limiting access to authorized personnel. However, no method of transmission over the internet is completely secure, and transmission of information is at your own risk.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time. The Service Provider will notify you of any changes by updating this page with a revised "Last updated" date. You are advised to consult this Privacy Policy regularly, as continued use of the Application constitutes acceptance of all changes.

Your Consent

By using the Application, you consent to the Service Provider's processing of your information as set forth in this Privacy Policy now and as amended by us.

Your Choices and Rights

• You can opt out of personalized ads or reset/delete your advertising ID at any time in your device settings (Settings > Google > Ads). Users in the EEA and UK can also change their consent by contacting us.
• You can revoke microphone permission at any time in your device settings.
• Uninstalling the Application removes data stored locally on your device.
• You may request access to, correction of, or deletion of data we hold about you by emailing duongdaihanh3576@gmail.com. We will respond within 30 days.

Contact Us

If you have any questions regarding privacy while using the Application, please contact the Service Provider by email at duongdaihanh3576@gmail.com.

KIN CHUNG INVESTMENT GROUP LIMITED