Privacy Policy

1. Data controller and contact

CONG TY TU VUNG FLOW is responsible for processing within the service. Address: 23 Nguyen Trai Street, Ben Thanh Ward, District 1, Ho Chi Minh City; telephone: +84 908 555 583. Privacy contact: founder@tuvungflow.id.vn.

This policy covers data processed through Từ Vựng Flow. Independent websites, videos, browsers and services you use may process data under their own policies.

2. Types of data processed

Simply viewing the website does not require every category below. Data arises from features you choose to use:

• Account data: email, internal user ID, hashed password, verification/account status, role, login sessions and associated times. Google login also uses a Google account identifier and verified email.
• Consent records: terms version, acceptance time, age eligibility confirmation, marketing choices and optional-feature choices. Age confirmation does not mean we collect your date of birth or identity documents.
• Learning data: saved vocabulary, notes, review progress, exercise history/results and preferences. A learning-data copy is sent to your account when you use eligible sync.
• Transactions: order code, plan, amount, currency, payment status, access period and invoice details you provide.
• AI and community: the Writing submission or transcript you choose to send; your opt-in choice, display name and check-in dates when using the board.
• Technical and security data: network request information, IP address or a hash derived from it, times, errors, login events and necessary action logs. Hashed or pseudonymous data can still be personal data when associated with an account.
• Support: email, correspondence, order codes and evidence you send with questions, complaints or data requests.

Do not place passwords, one-time codes, full card numbers, identity documents or unnecessary sensitive data in learning content, AI submissions or support email. The website has no personal-photo upload feature for face or health analysis.

3. Processing purposes and consent choices

We process data to create and verify accounts, provide login and recovery, sync progress, grant plan access, handle payments and invoices, respond to support, detect fraud, protect the service and meet legal obligations. Processing must be appropriate to its purpose and applicable legal basis.

AI Coach and the activity board require separate opt-in actions. Creating an account or buying Pro does not automatically send content to AI. Syncing does not automatically publish private progress. Declining an optional feature leaves independent learning tools available.

Transactional messages such as verification, recovery and account notices differ from marketing email. Accepting the terms is not automatic advertising consent. If marketing is introduced, we use appropriate consent and provide a withdrawal method.

You may withdraw consent-based processing. Withdrawal does not invalidate lawful processing already performed. Data needed for legal obligations, transactions or disputes may still be retained within the appropriate scope.

4. Cookies, browser storage and local learning

The website uses essential login-session cookies and temporary Google login cookies when you choose that feature. Login cookies use HttpOnly, SameSite and Secure on HTTPS; sessions currently last up to 7 days. The Account panel lets you log out or revoke other sessions.

LocalStorage and IndexedDB store learning data, interface choices, practice history and sync information on your device. Application caches may retain downloaded interface and content for faster reopening or partial offline use. These stores differ from cookies and do not automatically disappear on logout.

The current version does not integrate Google Analytics, Google AdMob or advertising cookies placed by Từ Vựng Flow. External video/resource providers may read or set cookies and collect information when loaded, as described in section 9.

Manage or clear website data in browser settings. Blocking cookies can prevent login; clearing browser storage can lose progress without a backup. Export your data before clearing it or changing devices.

5. Google login

When Google login/registration is enabled and you select it, the website redirects you to Google for authentication. The requested scope is account authentication and email. We receive a Google identifier and verified email to create or identify your account.

We do not receive your Google password or request Gmail, Drive, contacts or photo-library access in this flow. Accounts are not automatically linked merely because their emails match. Google handles authentication under its Privacy Policy.

6. Optional AI Coach and processing through the Claude API

AI Coach works only when enabled on the server. For each request, you choose Writing text or a Speaking transcript, read the data submission notice and select Send to request feedback. The server sends that content, skill, target and up to four recent messages in the current chat session to the configured AI provider for context. Conversations stay in the current page session and are not saved to your account.

Integrated with the Claude API. See Anthropic's privacy policy for its identity, data use, retention and transfers.

The request does not include your account identifier, email, password or full learning profile, except information you enter into the submission yourself. Do not include sensitive information, secrets or other people's data. The API key stays on the server.

Từ Vựng Flow does not save submissions or AI feedback in its learning database. The provider may process and retain data under its applicable API agreement or policy. Flow Coach does not promise zero retention, no training or a fixed deletion period.

Anthropic processes data through the Claude API under its applicable API retention policy and API training policy.

You can decline a request, refuse future submissions or contact support about previously sent data. This does not automatically recall content already processed by the provider.

7. Microphone, images and sensitive data

Pronunciation practice requests microphone permission only after you initiate it. The browser performs speech recognition and may send audio to its provider’s service. Recognition is not necessarily performed entirely on your device.

Từ Vựng Flow has no server-side microphone recording storage in this pronunciation flow. AI Coach processes text transcripts you choose to submit and does not automatically obtain recordings. You may deny or revoke microphone permission in browser settings, limiting the relevant practice feature.

Exercise illustrations are supplied by the system. The website currently does not access your camera/photo library for face analysis, identify you from a face, or analyze health or reproductive data. Any new feature requiring sensitive data must be disclosed and meet processing conditions before collection.

8. Activity board and public data

You choose to join, select a display name and record learning days. We process your opt-in choice, name and check-in dates to run the board. Only your display name and total active days for the week are public. Check-ins older than 35 days are removed by scheduled cleanup.

We do not publish your email, Writing/transcripts, answers, TOEIC/IELTS history, vocabulary or private review data. The feature has no chat, messaging, user search or group matching. Choose a name without email, phone number or identifying information.

Leaving removes your community profile and associated check-ins while retaining private learning progress. We cannot automatically erase screenshots or copies other people saved before removal.

9. Data recipients and external content

We do not sell or rent personal data. The following parties may receive data as necessary for a feature or related obligation:

• Infrastructure and databases: hosting, PostgreSQL/Supabase depending on configuration, storage and CDN providers handle account/learning data, backups or technical information for operation.
• Resend: processes recipient emails and transactional message content when configured. See Resend’s policy.
• payOS and banks: process necessary order and payment information for your chosen method. See payOS information. Your Từ Vựng Flow password is not sent to the payment provider.
• Configured AI provider: receives selected AI Coach content, skill and feedback target for requests you consent to, as explained in section 6.
• Google/YouTube: handles Google login or video connections when used. Embedded videos may disclose your IP, browser information, cookies and playback interactions. Caption retrieval sends a video ID from our server to the source service. See Google’s policy.
• Browser and external resource providers: may process speech or receive IP/request information when fonts, libraries, audio, video or linked resources load.
• Authorized staff and authorities: operations/support access data according to duties. Necessary disclosures may be made for lawful requests, fraud handling or protection of lawful rights.

Actual providers depend on the feature and configuration. Independent services have their own retention and data-rights terms. Operational sharing does not authorize unrestricted use for other purposes.

10. Processing outside Vietnam

Infrastructure, email, Google and AI providers may process or store data abroad. Locations depend on the provider and deployment configuration; we do not promise that all data remains in Vietnam.

Transfers must satisfy applicable legal conditions, required notices/consent and appropriate safeguards and processing agreements. The operator is responsible for required documentation and assessments. Contact the privacy contact to ask about a feature’s transfer scope.

11. Retention and deletion limits

Retention depends on processing purposes, account status, legal duties and the period needed to protect transactions. There is no single retention period for all data:

• Local data: remains in your browser until you clear it, the application updates/removes it or the browser clears storage. Device or browser-profile changes can lose it.
• Accounts and synced data: retained while the account is active. Account deletion removes synced learning data, sessions, tokens, plan access, community profiles and check-ins; replaces the email with an invalid address; and marks the account deleted.
• Remaining records: deletion does not erase every user, transaction or audit record. Internal account IDs, consent records, a Google identifier if present, and records needed for reconciliation, security, legal duties or disputes may remain. Replacing an email does not fully anonymize all remaining data; you may request review of further deletion/restriction.
• Sessions and tokens: sessions last up to 7 days; verification/recovery links usually expire in 20–30 minutes. Expiry differs from record deletion: scheduled cleanup removes tokens expired for more than 7 days.
• Security: failed-login and action-limit counters are cleaned after 30 days on the operational schedule. Event logs and support requests may be retained for investigation or ongoing cases according to the purpose and applicable duties.
• Community: check-ins older than 35 days are cleaned up. Leaving deletes the profile and associated check-ins.
• Orders and invoices: may remain after account deletion for tax/accounting, reconciliation or disputes. Retention does not restore account access.
• AI: submissions/feedback are not stored in our learning database. Provider retention is described separately in section 6.
• Backups: deleted data may remain until a backup expires under its retention cycle. Timing depends on infrastructure configuration; we do not promise immediate erasure of every copy. Contact us about the current schedule.

Server account deletion does not automatically clear browser storage, downloaded backups or data retained by independent services under their policies. Export needed data first, then manage website storage and copies on your devices.

12. Security and incident handling

System measures include password hashing, expiring authentication tokens, HttpOnly cookies, request-origin checks, access limits and permissions. Official deployments require HTTPS, protected database connections and secret-key management. Additional server-side learning-data encryption depends on configuration; deployments do not necessarily have identical encryption settings.

No transmission or storage method is completely secure. Use a strong password, protect your email, do not share one-time codes and log out on shared devices. For suspected exposure, change your password, revoke other sessions and contact support.

When a data incident is detected, we assess its scope, contain risks, preserve necessary evidence, remediate and fulfill notification obligations to affected people and authorities under applicable law.

13. Your rights and choices

Subject to applicable law and conditions, you may be informed about processing, access or obtain a copy, request correction/deletion/restriction, object, withdraw consent and complain or seek protection. Requests do not always require immediate erasure where lawful retention remains necessary; we explain the reason and available scope.

• Export: the Account tool downloads account information, synced learning data, orders and related community profiles/check-ins. Server export does not replace a backup of data stored only locally.
• Correction and security: edit learning content, change your password and revoke other sessions. Contact support about account information without a self-service editing tool.
• AI and community: decline further AI submissions or leave the board to delete your profile/check-ins. Request review of previously processed data when needed.
• Account deletion: use the Account deletion action with your password and confirmation text. Google accounts without passwords can use email password reset or request verification through support.
• Devices: manage microphone access, cookies and website storage in your browser and delete downloaded backups when no longer needed.

Declining optional features does not affect independent tools. Refusing information necessary for login, payment or sync can prevent the corresponding function.

14. Data requests and complaints

Email founder@tuvungflow.id.vn with your account email, relevant feature, specific request and relevant dates/events. Supply only necessary evidence. Do not send passwords, one-time codes, full card numbers or unrequested identity documents.

To prevent wrongful disclosure or deletion, we may verify account control and representative authority. Requests are reviewed and answered within applicable legal timeframes. If more information is needed or a request cannot be fully completed, we explain the reason, scope and next steps.

You may complain to the operator or competent authorities and seek protection under law. Support procedures do not restrict complaint or court rights.

15. Children and minors

Registration requires confirmation that you are at least 16 or have representative consent. Processing children’s data must protect their interests and meet legal consent requirements for children, parents or representatives. Registration confirmation does not replace every related verification requirement.

Parents/representatives can request review, restriction or deletion after appropriate verification. Where children’s data does not meet processing conditions, we consider stopping processing, deletion or protective measures required by law. Children should not submit sensitive data to AI or publish identifying information on the board.

16. Policy updates

We update this policy for feature, provider, data-scope or legal changes. The date and version at the top identify this document. Significant changes are communicated through the website, account or appropriate email notice. Where fresh consent is required, we request it before the relevant processing.

This policy applies alongside the Terms of Use and Vietnamese personal data protection law. Contact our privacy contact about the policy version or processing scope applicable when you used the service.