PRIVACY POLICY – LORO

Effective Date: August 30, 2026

Last Updated: August 30, 2026

This Privacy Policy describes how the Loro application ("Loro", the "App", "we", "us", or "our") handles information when you use the Loro vocabulary and language-learning application.

Loro is developed and operated by:

Developer: NGÔ NGỌC THỂ

Type: Individual Developer

Country: Vietnam

Contact Email: ngothe.genz@gmail.com

Website: tramchuyenke.com

Privacy Policy Page: tramchuyenke.com/loro/privacy

Protecting user privacy is an important principle in the development of Loro. Loro is designed to prioritize storing learning data on the user's device and to limit the transfer of learning data outside the device.

1. Scope

This Privacy Policy applies to versions of Loro distributed through official application stores such as the Apple App Store and Google Play, as well as online services directly operated by Loro.

Certain third-party services integrated into the App, particularly Google AdMob advertising services, have their own privacy policies.

The processing of data by third parties is also governed by their own policies, terms, and legal obligations.

2. Age Requirements

Loro is designed for users 13 years of age or older and is not designed or intentionally marketed to children under the age of 13.

In countries or regions where applicable law requires a higher minimum age for a person to independently consent to the processing of personal data, the applicable minimum age under local law will apply.

Loro does not require users to provide their date of birth in order to use its core learning features.

We do not intentionally ask children below the age permitted by applicable law to provide personal information such as their name, email address, phone number, physical address, or other personally identifying information.

If a parent or legal guardian believes that a child has provided personal data to Loro in violation of applicable law, they may contact us at:

ngothe.genz@gmail.com

We will review the request and take appropriate action in accordance with applicable law.

3. Loro Does Not Require a User Account

The current version of Loro does not require or support the creation of a user account.

Accordingly, Loro does not require users to provide information such as:

• full name;
• username or nickname;
• email address;
• password;
• phone number;
• gender;
• date of birth;
• residential address;
• profile picture;
• identification document information.

Loro also does not create user account profiles on our servers.

If Loro introduces an account system in the future, this Privacy Policy will be updated before or at the same time that such functionality is made available.

4. Learning Data Stored on the Device

Loro may store information necessary for the learning process directly on the user's device.

This information may include:

• vocabulary already learned;
• saved vocabulary;
• courses;
• learning history;
• learning progress;
• scores;
• number of correct or incorrect answers;
• results from learning sessions;
• learning statistics;
• memory or retention levels;
• data used for review algorithms;
• streaks or similar progress information, if implemented;
• course data created by the user;
• learning settings;
• App language and preferences.

This data may be used to:

• display progress;
• calculate learning results;
• select content that should be reviewed;
• personalize the learning experience on the device;
• generate statistics;
• help users continue their learning process.

Under the current architecture, this learning data:

is stored locally on the device and is not uploaded by Loro to the developer's servers.

Loro does not use this locally stored learning data to build advertising profiles about users.

5. Deleting Learning Data

Loro provides a feature that allows users to delete all learning data stored by the App on their device.

When a user confirms deletion, Loro may delete local data such as:

• learning history;
• progress;
• scores;
• statistics;
• saved vocabulary;
• course data created by the user;
• other learning-related App data.

The deletion process may be irreversible once completed.

Certain data stored in operating-system settings, data managed by third parties, or backups created by the operating system or the user's backup service may be outside Loro's direct control.

6. Data Export

Loro may provide a feature that allows users to export their learning data.

Data export is performed only at the user's active request.

Loro does not consider a user's own export of data from their device to constitute collection of that data by Loro on our servers.

After a user exports or shares data to another application, service, or location, the processing of that data may be subject to the policies of the receiving service.

7. Loro Content Servers

Loro may connect to the Internet to download shared resources necessary for the App, such as:

• vocabulary lists;
• vocabulary content;
• courses;
• translations;
• system configuration;
• language configuration;
• other publicly available content.

Loro's content servers are currently operated using a custom backend infrastructure and PostgreSQL database, with server infrastructure located in Vietnam and provided by AZVPS.

Requests used to download this content are not designed to send the following information to Loro's servers:

• learning history;
• scores;
• the list of words a user is currently learning;
• learning profiles;
• names;
• email addresses;
• user accounts;
• Loro account identifiers.

However, when a device communicates with an Internet server, technical network information such as an IP address, request time, or request information may be processed by the network provider, server, or infrastructure provider to the extent necessary to transmit data, operate the service, diagnose problems, or protect the service.

Loro does not intentionally use IP addresses from content API requests to build learning-behavior profiles or advertising profiles about users.

8. Advertising

Loro uses Google AdMob / Google Mobile Ads SDK to display advertisements.

Google and Google's advertising technology partners may process certain technical data for purposes such as:

• delivering advertisements;
• selecting advertisements;
• measuring advertising performance;
• limiting ad frequency;
• preventing fraud and abuse;
• analyzing advertising performance;
• ensuring that the advertising SDK operates correctly.

Depending on the device, operating system, region, privacy status, and advertising configuration, such data may include:

• IP address;
• approximate location inferred from IP address;
• Advertising ID or other device identifiers where permitted;
• information about advertisements displayed;
• interactions with advertisements;
• certain interactions with the App;
• diagnostic information;
• application or SDK performance information;
• information necessary for fraud prevention and security.

This data may be processed by Google and Google's partners outside Loro's server infrastructure.

Loro does not sell users' locally stored learning data to Google or advertising networks.

9. Personalized Advertising and Consent

In countries or regions where consent is required before data may be used for personalized advertising or advertising-related storage, Loro intends to use Google's consent-management mechanisms, including Google User Messaging Platform or another solution that satisfies the applicable requirements.

Users may be given choices such as:

• consenting to personalized advertising;
• declining personalized advertising;
• managing advertising providers;
• changing their privacy choices later.

Declining personalized advertising does not necessarily mean that the App will contain no advertising.

In such cases, non-personalized, contextual, or limited advertisements may still be displayed where permitted by applicable law and platform rules.

Certain minimum technical processing may still be necessary to:

• deliver advertisements;
• prevent fraud;
• limit frequency;
• maintain security;
• perform basic technical measurement.

10. App Tracking Transparency on Apple Devices

On iPhone or iPad, where Loro or the Google Mobile Ads SDK intends to use data in a manner that Apple considers "tracking", Loro will request permission through Apple's App Tracking Transparency (ATT) framework where required by applicable law and Apple policies.

Users have the right to decline.

If a user declines ATT permission, Loro will not intentionally access IDFA for tracking purposes in a way that conflicts with the user's choice.

Users may change their tracking permissions through the privacy settings on their Apple device.

11. Advertising Privacy

Loro intends to provide a Privacy section within the App's Settings.

Depending on the user's region and applicable legal requirements, this section may allow users to:

• view the Privacy Policy;
• reopen advertising privacy settings;
• change consent choices where supported by the advertising service;
• delete locally stored learning data.

Available options may vary depending on country, operating system, or advertising-service configuration.

12. Loro Does Not Sell Personal Data

Loro does not sell users' personal data in exchange for money.

Loro also does not sell users' learning databases, learning history, or scores.

However, privacy laws in some jurisdictions use broad legal definitions for concepts such as "sale", "share", "targeted advertising", or "cross-context behavioral advertising".

The use of third-party advertising networks for personalized advertising may be considered "sharing" under certain local laws even where Loro does not receive money for selling data.

Where applicable law requires it, Loro will provide an opt-out right or an appropriate privacy mechanism.

13. Notifications and Study Reminders

Loro may request permission to send notifications for purposes such as:

• study reminders;
• scheduled study reminders;
• review reminders;
• task-related notifications;
• functional or system notifications.

Under the current architecture, these reminders are scheduled and processed locally on the device.

Loro currently does not:

• send Expo Push Tokens to Loro servers;
• store push tokens on the backend;
• use a user account system to associate push tokens with an individual user.

Users may disable notification permissions at any time through their operating-system settings.

14. AI and Prompt Content

Loro may provide functionality that helps users generate text prompts for use with an artificial intelligence service of their choice.

Prompts may be generated from information such as:

• vocabulary structure;
• course data;
• content that the user wants to generate;
• learning results selected by the user;
• learning-analysis requests.

Under the current version:

Loro does not automatically send prompts or learning data to OpenAI, Gemini, or any other third-party AI service.

Prompts are generated for the user to view or copy.

If a user intentionally copies a prompt and pastes it into another AI service, the data will be sent to that service as a result of the user's own action.

From the moment data is submitted to an external AI service, its processing will be governed by the privacy policy and terms of the AI service chosen by the user.

Loro is not responsible for controlling how an independent AI service processes content voluntarily submitted to it by the user.

Users should avoid including personal or sensitive information in prompts unless doing so is necessary.

15. Microphone, Camera, and Biometric Data

The current version of Loro does not require microphone or camera access for the core features described in this Privacy Policy.

Loro currently does not collect:

• voice recordings;
• facial images;
• biometric data;
• camera data;
• voice-recognition data.

If these features are introduced in the future, Loro will update this Privacy Policy and provide appropriate notices and operating-system permission requests before collecting or transmitting such data.

16. Location Data

Loro does not request GPS permission to track a user's precise location.

Loro does not create a location history for users.

However, Internet or advertising services such as Google AdMob may process an IP address and use it to infer an approximate geographic area for purposes described in their own policies.

17. Analytics

Loro currently does not integrate third-party analytics platforms such as Google Analytics, Firebase Analytics, Mixpanel, or Amplitude to track users' learning behavior.

Loro's learning statistics are calculated from data stored locally on the device.

Google Mobile Ads SDK may still process certain interaction and diagnostic data for advertising, advertising analytics, performance, and fraud-prevention purposes in accordance with the SDK's own operation.

18. Legal Bases Where GDPR / UK GDPR Applies

If the GDPR, UK GDPR, or a similar regulation applies to a user, data processing may rely on one or more of the following legal bases:

Consent

Consent may be used where applicable law requires user agreement, particularly for:

• personalized advertising;
• tracking;
• certain activities involving storage of or access to information on the device.

Users may withdraw consent through the mechanisms provided.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Providing Functionality Requested by the User

Certain technical processing may be necessary to download content or provide a feature explicitly requested by the user.

Legitimate Interests

To the extent permitted by applicable law, minimum technical data may be processed for legitimate interests such as:

• operating the service;
• maintaining security;
• preventing fraud;
• diagnosing errors;
• protecting systems.

Loro will not rely on legitimate interests where applicable law determines that the user's fundamental rights and interests override those interests.

Legal Obligations

Data may be processed or retained where necessary to comply with a mandatory legal obligation.

19. Data Retention

Learning Data

Locally stored learning data remains on the device until:

• the user deletes the data;
• the user resets the App;
• the App's data is removed by the operating system;
• another data-management mechanism is activated by the user.

Under the current architecture, Loro does not store a copy of this learning data on its backend.

Advertising Data

Retention periods for data processed by Google or advertising partners are determined by the policies and configurations of the relevant providers.

Technical Logs

Network infrastructure or hosting providers may process or retain technical logs for the period necessary for operation and security.

Loro does not use these logs to build individual learning profiles.

If Loro introduces a specific technical-log retention policy in the future, the relevant retention information will be updated accordingly.

20. Sharing Data with Third Parties

Loro may use the following categories of service providers:

Google

Google AdMob / Google Mobile Ads SDK is used to deliver and measure advertisements and to perform related functions.

Google may act in the appropriate legal role depending on the type of data and jurisdiction involved.

Hosting Provider

AZVPS is currently used for Loro's server infrastructure in Vietnam.

The server is primarily used to provide public application content such as vocabulary and courses.

Apple and Google

If Loro is downloaded through the Apple App Store or Google Play, Apple or Google may process information relating to application downloads, devices, store activity, and platform activity in accordance with their own policies.

Loro does not control data that application stores independently collect directly as part of their own relationship with users.

21. International Data Transfers

Loro is operated from Vietnam.

Loro's primary content server is currently located in Vietnam.

However, international providers such as Google may process data in multiple countries or regions.

As a result, certain advertising or technical data may be processed outside the country where the user resides.

Where applicable law requires safeguards for cross-border data transfers, the responsible parties will apply appropriate safeguards in accordance with their respective legal obligations.

22. User Rights

Depending on the user's country or region, users may have rights such as:

• the right to know what data is being processed;
• the right to access data;
• the right to correct inaccurate data;
• the right to request deletion;
• the right to restrict processing;
• the right to object to certain forms of processing;
• the right to withdraw consent;
• the right to opt out of personalized advertising or targeted advertising;
• the right to data portability where applicable;
• the right to lodge a complaint with a competent data-protection authority;
• the right not to be discriminated against for exercising lawful privacy rights.

Because Loro does not use user accounts and learning data is primarily stored on the device, many rights relating to learning data may be exercised directly through features that allow users to view, export, or delete data on their device.

For requests relating to data directly controlled by Loro, users may contact:

ngothe.genz@gmail.com

We may request reasonable information to determine the scope of a request and to prevent one person from requesting another person's data.

23. Users in California and Other U.S. States with Privacy Laws

Where California privacy law or similar privacy laws in other U.S. states apply, users may have rights including the right to:

• know the categories of personal information being processed;
• request access;
• request correction;
• request deletion;
• opt out of the sale of personal information;
• opt out of sharing for cross-context behavioral advertising or targeted advertising where applicable;
• limit certain uses of sensitive data where applicable;
• not be discriminated against for exercising their rights.

Loro does not sell personal data in exchange for money.

Loro does not sell learning data.

However, third-party personalized advertising may be classified as "sharing" or "targeted advertising" under certain U.S. privacy laws.

Where such rules apply, Loro will use appropriate privacy or consent mechanisms to allow users to manage their advertising choices.

24. Users in the EEA, EU, and United Kingdom

Users who fall within the scope of the GDPR or UK GDPR may have additional legal rights, including the right to:

• access;
• correction;
• deletion;
• restriction;
• objection;
• data portability;
• withdrawal of consent;
• lodge a complaint with a competent supervisory authority.

For personalized advertising in regions where consent is required, Loro will use an appropriate consent-management solution that complies with platform requirements and applicable law.

25. Users in Brazil

Where the Lei Geral de Proteção de Dados – LGPD applies, users in Brazil may exercise rights granted to data subjects under applicable law, including rights relating to information, access, correction, deletion, and other rights where legally available.

Requests may be sent to:

ngothe.genz@gmail.com

26. Users in Vietnam

Loro respects the rights of data subjects under Vietnamese personal-data protection laws.

To the extent applicable, users may exercise rights provided by law, including the right to be informed, to consent or withdraw consent, to access, correct, request deletion, and exercise other rights recognized by applicable law.

Users may contact:

ngothe.genz@gmail.com

27. Security

Loro follows a data-minimization approach and prioritizes storing learning data on the device in order to reduce the amount of data that needs to be transmitted over the Internet.

Protective measures may include:

• restricting APIs to necessary purposes;
• restricting access to databases;
• avoiding user-account creation where unnecessary;
• not storing passwords because the current version does not use accounts;
• not uploading learning history to the backend;
• using operating-system security mechanisms;
• protecting server connections with appropriate security technologies.

No electronic system can be guaranteed to be completely secure.

Users should also protect their devices using passwords, PINs, or other appropriate device-locking methods.

28. No Fully Automated Decisions with Legal Effects

Loro may use algorithms to calculate progress, statistics, or recommended learning content.

These calculations are designed to support the learning experience and are not designed to make decisions that produce legal effects or similarly significant effects on users.

29. Changes to This Privacy Policy

Loro may update this Privacy Policy if:

• new features are introduced;
• data-processing practices change;
• new service providers are integrated;
• the advertising model changes;
• account or synchronization features are introduced;
• applicable law or platform requirements change.

The "Last Updated" date at the beginning of this document will be changed whenever the Privacy Policy is updated.

If a change significantly affects user privacy, Loro may provide additional notice within the App where appropriate.

30. Contact

For questions, complaints, or requests relating to privacy:

Application: Loro

Developer: NGÔ NGỌC THỂ

Country: Vietnam

Email: ngothe.genz@gmail.com

Website: tramchuyenke.com

We will review valid requests in accordance with applicable law and respond within a reasonable period or within any legally required time limit.