Privacy Policy

01Who we are

Tōngdá is a Simplified Chinese learning app and the website at tongda.app, operated by One FortySeven Limited (“we,” “us,” “our”), a company incorporated in Hong Kong with its registered office at Unit 909, Prosperity Millennia Plaza, 663 King's Road, Quarry Bay. This policy covers the website, the waitlist and our emails, and the Tōngdá app, including any beta or early-access version. One FortySeven Limited is the controller of the personal data described here.

You can reach us at hello@tongda.app.

02What we collect

• Waitlist: your email address, plus basic request data such as IP address, browser type, and timestamps.
• Website analytics: usage data such as page URL, referrer, device and browser details, interactions like pageviews, clicks, form submissions, and waitlist form outcomes, interaction heatmaps, and the campaign parameters on the link you arrived on. By default this is measured anonymously without cookies; if you accept analytics cookies, we can also recognize your browser across visits.
• Messages: anything you send us directly, including support and feedback emails and in-app support chat.
• Account and study data, if you use the app: account identifiers, sign-in details, onboarding answers, settings, timezone, learning progress, review history, streaks, your palette entries (People, Places, Things), and mnemonic scenes you keep.
• Generation inputs: the character or word you're studying, the palette entries you pick or write, any direction you type when regenerating, and the generated result.
• Diagnostics: error and crash reports, product analytics events, app performance and reliability telemetry, generation logs, and rate-limit records.
• Device and notification data, when you opt in: a push notification token and basic device details used to deliver review reminders, support replies, and app updates.

We do not collect contacts or precise location, and we do not access your photos or camera except when you choose to attach an image in support chat. There are no purchases in the app today; if subscriptions launch, payment will be handled by the Apple App Store or Google Play, and we will receive your subscription status, never your full payment details.

03How we use it

• To run the website, waitlist, emails, accounts, learning and generation features, support, and security.
• To send launch, early-access, account, security, and support messages.
• To prevent abuse, enforce rate limits, debug errors, improve the product, and comply with law.

We do not sell your personal information, rent your email, or use your data for advertising profiles or cross-context behavioral advertising. Marketing emails include an unsubscribe link.

04Service providers and international transfers

We share data only with the providers needed to operate Tōngdá, or when required by law:

• Cloudflare: website hosting, security, waitlist request handling, and audio delivery.
• Convex: app backend and database.
• Clerk: sign-in with email codes or Apple. When you sign in with Apple, Apple also processes your sign-in.
• Resend: waitlist, launch, and product emails.
• PostHog: product analytics, error and crash diagnostics, and monitoring of generation requests, including their inputs and outputs.
• OpenRouter: producing mnemonic suggestions and scenes from your inputs. OpenRouter routes each request to an upstream model provider, such as OpenAI.
• Crisp: in-app support chat. We send your user id, an optional first-name nickname, your messages, any attachments you choose to send, such as photos, and, when notifications are allowed, a device push token so replies reach your device.
• Expo (EAS): app updates, app performance and reliability telemetry, and, if you turn on notifications, push delivery via Apple's and Google's notification services.
• Google Fonts: the website loads its display font from Google, which receives standard request data such as your IP address and browser details when a page loads.

One FortySeven Limited is incorporated in Hong Kong, and these providers may store and process data in the United States, the European Union, and other countries whose data-protection laws may differ from your own. Where the GDPR or UK GDPR applies to a transfer, we rely on appropriate safeguards such as standard contractual clauses or an adequacy decision. Each provider handles data under its own terms and may retain request and response data. We keep this list current and update this policy when a core provider changes.

If One FortySeven Limited is involved in a merger, acquisition, financing, reorganization, or sale of assets, personal data may be disclosed or transferred as part of that transaction, subject to this policy. We will notify you of material changes, including any change of controller.

05Generated content

Generation sends only the inputs needed to produce a suggestion or scene. Your palette entries are part of those inputs, so if you name real people or places you know, those names are included in generation requests and in our generation logs. Do not put secrets or sensitive personal information into prompts. We store generated content you keep, and providers may retain request and response data under their own terms. Generated suggestions can be inaccurate or unexpected, and you choose what to keep.

06Cookies and device storage

By default, the website measures usage anonymously and without cookies: nothing is stored on your device, and events are grouped using a short-lived identifier our analytics provider PostHog derives from your IP address, browser, and the current day, which rotates daily so visits cannot be linked across days. If you accept analytics cookies in the cookie banner, PostHog additionally sets cookies and similar browser storage so we can recognize your browser across visits. If you decline, no analytics cookies are set and only the anonymous measurement continues; the only thing stored on your device is your choice itself. You can change your choice at any time by clearing this site's cookies and site data in your browser; the banner will ask again on your next visit. When a Do Not Track or Global Privacy Control signal is present and you have not already made a choice, we do not show the banner and never set analytics cookies. The website does not use advertising or cross-site tracking cookies, and IP addresses are not kept with analytics events.

The app stores session tokens, settings, and offline study data on your device, including secure storage such as the device keychain. If we later add technologies that require consent, we will ask first and update this policy before turning them on.

07Retention and deletion

We keep waitlist data until you unsubscribe or ask us to delete it. Account and study data is kept while your account is active. You can delete your account in the app at any time; this deletes your sign-in identity and the data we hold about you, subject to limited retention for backups, security, or legal reasons. Deleting your account does not cancel any App Store or Google Play subscription.

08Your privacy rights

We process personal data to provide and secure the service and carry out our agreement with you, based on our legitimate interest in operating and protecting Tōngdá, with your consent where we ask for it (such as marketing emails and website analytics cookies, which you can withdraw at any time), and to meet legal obligations.

Depending on where you live, you may have rights to access, correct, delete, and receive a portable copy of your personal data, to restrict or object to certain processing, and to withdraw consent. You will not be treated unfairly for exercising a right.

Hong Kong. Under the Personal Data (Privacy) Ordinance, you may request access to and correction of your personal data, and you may complain to the Privacy Commissioner for Personal Data.

EEA, UK, and Switzerland. Where the GDPR or equivalent law applies, you have the rights above, we transfer your data outside these regions only with the safeguards in section 04, and you can lodge a complaint with your local data protection authority.

United States. Depending on your state, you may have rights to know, access, correct, and delete personal information and to opt out of its sale, sharing, or use for targeted advertising. We do not sell or share personal information or use it for targeted advertising, so there is nothing to opt out of, and we will not discriminate against you for exercising any right.

To make a request, email hello@tongda.app. We may verify your identity first, accept requests through an authorized agent where the law allows, and will respond within the time the law requires. If we decline a request, you can appeal by replying to our response and we will review the decision.

09Security

We use reasonable technical and organizational measures to protect personal information, such as encryption in transit and access controls. No method of storage or transmission is completely secure. If a personal data breach affects you, we will notify you and the relevant authorities where the law requires it.

10Children

Tōngdá is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If the minimum age is higher where you live, that higher age applies. If you believe a child has provided personal information to us, contact us and we will take appropriate steps to delete it.

11Changes

We may update this policy as the product, providers, laws, or platform requirements change. We will update the date above and, where appropriate, notify you of material changes.