Privacy Policy

Effective Date: March 10, 2026 | Last Updated: March 10, 2026

1. Introduction

English Tense Master is a children's educational app designed to help primary school students (ages 6-12) learn English tenses through interactive lessons and AI-powered practice. This Privacy Policy explains how we handle information when you use our app.

We are committed to protecting children's privacy and complying with applicable laws including:

• Children's Online Privacy Protection Act (COPPA) - United States
• Apple App Store Guidelines for children's apps
• Google Play Families Policy
• Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (PDPO)

2. Information We Collect

We Do NOT Collect Personal Information

We do NOT directly collect, store, or retain any personal information from children. Our app does not require user accounts, login, registration, or any form of personal identification.

Data Processing Through Third-Party Services

AI Chat Feature (Microsoft Azure OpenAI)

When a child uses the AI Q&A feature, their questions are transmitted to Microsoft Azure OpenAI Services for real-time processing to generate responses.

Important Details:

• Questions are processed in transit only and are NOT stored on our servers or Microsoft's servers
• No conversation history is retained by us or Microsoft
• Responses are generated in real-time and immediately discarded after delivery
• By using this feature, you consent to data processing by Microsoft Azure as described in Microsoft's Privacy Policy

Text-to-Speech Feature (Microsoft Azure Speech Services)

English text is transmitted to Microsoft Azure Speech Services to generate audio pronunciation.

• Text is processed in transit only and is NOT stored
• Audio is generated in real-time and delivered directly to the user's device
• No recordings or transcripts are retained
• By using this feature, you consent to data processing by Microsoft Azure as described in Microsoft's Privacy Policy

Microsoft Azure as Data Processor

Microsoft Azure acts as our data processor for AI and speech services. Microsoft operates under data processing agreements that comply with applicable privacy laws and industry standards. We are not responsible for Microsoft's data processing practices. Please review Microsoft's privacy policies independently.

Local Device Data (Not Transmitted)

The following data is stored locally on the user's device only and is never transmitted to any server:

• Learning progress and completed lessons
• Experience points (XP) and level
• Streak data (consecutive days of learning)
• Earned badges and achievements

This data remains exclusively on the device, is protected by device operating system security features, is automatically deleted when the app is uninstalled, and cannot be accessed by us or any third party.

3. Information We Do NOT Collect

4. Third-Party Services

Our app uses the following third-party services strictly for functionality:

Third-Party Disclaimer

WE DO NOT:

• Use any third-party analytics services
• Use advertising networks or ad tracking
• Use social media plugins or sharing tools
• Use behavioral tracking or profiling tools
• Share data with data brokers or marketing companies

5. Children's Privacy (COPPA Compliance)

This app is specifically designed for children under 13 years of age. We take children's privacy extremely seriously.

Our COPPA Commitments:

• We do not knowingly collect personal information from children
• We do not require children to provide any personal information to use core app features
• There are no user accounts, profiles, or social features
• There is no advertising, tracking, or behavioral profiling
• There are no chat rooms, forums, or user-to-user communication features

Parental Consent for Purchases

In-app subscription purchases require authentication through a parent or guardian's Apple ID (iOS) or Google account (Android). This ensures that only authorized adults can make purchase decisions.

Support for Internal Operations Exception

Our use of Azure OpenAI and Azure Speech Services qualifies as "support for internal operations" under COPPA Rule 16 CFR 312.5(c)(3), as these services are necessary to maintain and analyze the functioning of the app, provide educational content and responses to users, and enable text-to-speech functionality for learning purposes. No personal information is collected, stored, or used for any other purpose.

6. Data Security

We take the security of our users seriously and implement industry-standard security measures:

Technical Security Measures

• Encryption in Transit: All API communications with Microsoft Azure services use HTTPS/TLS 1.2 or higher encryption
• No Server-Side Storage: We do not maintain any servers that store user data
• Local Data Protection: Device data is protected by iOS/Android operating system security features
• Access Controls: Our development team has no access to user data since none is collected
• Regular Security Reviews: We conduct periodic security assessments of our code and architecture

Microsoft Azure Security

Microsoft Azure services we use are SOC 2 Type II certified, ISO 27001 certified, COPPA compliant, and subject to Microsoft's enterprise-grade security infrastructure.

However, no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect data in transit, we cannot guarantee absolute security.

7. Data Retention

We maintain no server-side data retention policy because we do not collect or store personal data on any servers.

Data Processing (Not Retained)

• AI chat queries: Processed in real-time by Azure OpenAI and immediately discarded. No logs or conversation history retained.
• Text-to-speech requests: Processed in real-time by Azure Speech Services and immediately discarded. No audio recordings retained.

Local Device Data

• Learning progress, XP, streaks, and badges persist on the device until the app is uninstalled
• Users can manually reset progress through app settings (this deletes all local data)
• Automatic deletion occurs upon app uninstallation

8. Parental Rights

As a parent or legal guardian, you have the following rights under COPPA and PDPO:

Access and Review Rights

• Right to review: You may request to review any information collected from your child (we collect none on servers)
• Right to access: You may access locally stored data on your child's device through the app interface

Deletion Rights

• Right to deletion: You may request deletion of any information we store (none on servers)
• Local data deletion: You can delete local device data by uninstalling the app or using the "Reset Progress" feature in app settings

Control Rights

• Right to refuse: You may refuse further collection or use of your child's information
• Right to withdraw consent: You may withdraw consent for AI features by discontinuing use of those features
• Device controls: You may restrict app usage through iOS Screen Time or Android parental controls

How to Exercise Your Rights

Email: info@wfai.hk | Response Time: Within 14 business days

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

How We Notify You:

• Effective Date Update: The "Last Updated" date at the top of this policy will be revised
• Material Changes: Significant changes affecting children's privacy will be communicated through an in-app notification before taking effect
• Continued Use: Your continued use of the app after changes take effect constitutes acceptance of the updated policy

Parent Responsibility

We encourage parents and guardians to review this policy periodically, check for updates when you see an in-app notification, and contact us with questions about any changes. Archive of previous versions available upon request.

10. Limitation of Liability

Service Provided "As-Is"

This app and all content, features, and services are provided on an "as-is" and "as available" basis without warranties of any kind, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy or reliability, and uninterrupted or error-free operation.

AI-Generated Content Disclaimer

AI responses are generated automatically by artificial intelligence and may contain errors, inaccuracies, or inappropriate content despite our best efforts. We do not guarantee the accuracy, completeness, or appropriateness of AI-generated responses. AI responses should not be considered professional advice. Parents should supervise children's use of AI chat features. We are not responsible for any reliance on AI-generated content.

Limitation of Damages

TO THE MAXIMUM EXTENT PERMITTED BY LAW, we and our officers, directors, employees, contractors, and service providers shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of data or learning progress, loss of profits or revenue, service interruptions or technical failures, errors in AI-generated content, educational outcomes or academic performance, third-party service failures (Microsoft Azure, Apple, Google), unauthorized access to devices, and any damages arising from use or inability to use the app.

Maximum Liability Cap

In any event, our total aggregate liability shall not exceed the amount you paid for the app subscription in the 12 months preceding the claim (if applicable), or HKD 36, whichever is lower.

Third-Party Service Failures

We are not responsible for Microsoft Azure service outages, data breaches, or processing errors; Apple App Store or Google Play billing issues or disputes; device manufacturer defects or operating system failures; or internet connectivity problems.

11. Indemnification

By allowing your child to use this app, you (as parent or legal guardian) agree to indemnify, defend, and hold harmless the app operator, its officers, directors, employees, contractors, and service providers from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising from:

• Your child's use or misuse of the app
• Violation of this Privacy Policy or any applicable laws
• Violation of any rights of another person or entity
• Any misrepresentation regarding your child's age
• Unauthorized use of the app by someone other than your child
• Any claim that AI-generated content caused harm or injury

This indemnification obligation survives termination of app use.

12. Intellectual Property Rights

Our Ownership

All content, features, functionality, and materials in the app, including but not limited to lesson content and curriculum, graphics, logos, and user interface design, text, images, and audio content, software code and algorithms, and trademarks and branding, are owned by WORKFLOW ARCHITECTS LIMITED or our licensors and are protected by Hong Kong and international copyright, trademark, and other intellectual property laws.

User-Generated Content

Any questions, inputs, or content submitted by users through the AI chat feature are not stored or retained by us, do not grant us any ownership rights (since we don't retain them), and may be processed by Microsoft Azure as necessary to provide AI responses.

Restrictions

• You may not copy, modify, or distribute app content
• You may not reverse engineer or decompile the app
• You may not use the app for commercial purposes
• You may not remove copyright or proprietary notices

13. Governing Law and Jurisdiction

Applicable Law

This Privacy Policy and any disputes arising from or relating to it shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to its conflict of law provisions.

Dispute Resolution / Jurisdiction

You agree that any legal action or proceeding arising out of or relating to this Privacy Policy or the app shall be brought exclusively in the courts of Hong Kong SAR. You consent to the personal jurisdiction of such courts and waive any objection to venue.

Prior to filing any lawsuit, parties agree to attempt to resolve disputes through good-faith negotiation. If unsuccessful within 30 days, disputes shall be resolved through binding arbitration in Hong Kong under the Hong Kong International Arbitration Centre (HKIAC) Administered Arbitration Rules.

Exceptions

Nothing in this section limits your rights as a consumer under Hong Kong consumer protection laws or prevents you from bringing proceedings in the courts of your country of residence if required by applicable law.

14. Data Breach Notification

In the unlikely event of a data breach affecting children's information:

Our Commitment:

• We will investigate and assess the breach within 72 hours of discovery
• We will notify affected parents/guardians without undue delay
• Notification will be sent to the email address on file (if applicable) or through in-app notification
• We will cooperate fully with regulatory authorities

What We Will Tell You:

• Nature of the breach and data affected
• Approximate date and duration of the breach
• Steps we are taking to address the breach
• Steps you can take to protect your child
• Contact information for further questions

15. Hong Kong PDPO Compliance

This app complies with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.

Data Protection Principles

We adhere to the six Data Protection Principles (DPPs) under Schedule 1 of the PDPO:

• DPP1 - Purpose and Manner of Collection: We collect no personal data. Data processed by third parties is done lawfully and fairly for specific educational purposes.
• DPP2 - Accuracy and Retention: Not applicable (no personal data retained).
• DPP3 - Use of Personal Data: Not applicable (no personal data collected).
• DPP4 - Security: Data in transit is protected by encryption and industry-standard security measures.
• DPP5 - Information to be Generally Available: This Privacy Policy provides transparency about our data handling practices.
• DPP6 - Access to Personal Data: Parents may exercise access rights (though no personal data is stored by us).

Data Subject Rights Under PDPO

• Request access to personal data we hold (none on servers)
• Request correction of inaccurate data we hold (none)
• Object to use of personal data for direct marketing (we do not engage in direct marketing)
• File a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) if you believe we have violated the PDPO

16. International Users

While this app is operated from Hong Kong and primarily complies with Hong Kong and US laws, users from other jurisdictions may have additional rights under their local privacy laws (e.g., GDPR in Europe).

European Users (GDPR)

If you are in the European Economic Area:

• Legal basis for processing: Legitimate interest and consent (for AI features)
• Right to data portability: You may request data in a structured format (we hold none)
• Right to erasure: You may request deletion (we hold none on servers)

Other Jurisdictions

We respect privacy rights under all applicable jurisdictions. Contact us if you have specific questions about your local privacy rights.

17. Contact Us

18. Acceptance of This Policy

By downloading, installing, or using this app, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use the app.

As a parent or legal guardian, you represent and warrant that:

• You are the parent or legal guardian of the child using the app
• You have authority to agree to this Privacy Policy on behalf of your child
• You will supervise your child's use of the app
• You accept responsibility for your child's use of the app

© 2026 WORKFLOW ARCHITECTS LIMITED. All rights reserved.