We. places great emphasis on user privacy protection, with particular attention to the privacy and security of children. This Privacy Policy (hereinafter referred to as the "Policy") details our data protection measures and explains how information may be processed when users install and use our mobile application (hereinafter referred to as the "App").

Definition of Personal Data

"Personal data" (or "personal information") refers to any information that can directly or indirectly identify a specific natural person, including but not limited to identification numbers, as well as specific elements reflecting an individual's physiological, psychological, economic, cultural, or social characteristics.

Scope of Application

This Policy applies to all users of our applications or websites (hereinafter referred to as "users"), including children and their parents or guardians. "Children" as referred to in this Policy specifically means minors under the age of 13 (or under the age of majority in the jurisdiction where they reside).

If you have any questions regarding our handling of children's information or compliance with COPPA, please contact mytwzp@sina.com.

For the purposes of the EU General Data Protection Regulation (GDPR), we act as a data controller for our data processing activities unless otherwise stated.

Please read this Policy carefully to understand how your personal information is processed. By using our App or website, you are deemed to have read, understood, and agreed to be bound by the terms of this Policy.

Special Notes for California Residents

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request the following information regarding their personal information:

Categories of personal information we process;
Categories of sources from which personal information is obtained;
Purposes of processing;
Categories of third parties with whom personal information is shared;
Detailed personal information that can identify a specific user (sufficient verification information is required).

All third parties that process user data are compliant service providers operating in accordance with contractual agreements.

Opt-Out Mechanism

To stop us from processing your or your child’s personal information, please send an email to mytwzp@sina.com. Please note that discontinuing the provision of necessary operational data may result in limited App functionality, and we recommend that you uninstall the App in such cases.

You may refuse to share device identifiers and location data through your device settings, though this may affect some App functions. We always respect your privacy choices. If you have any questions, please feel free to contact us.

Exercising Your Rights

To exercise your rights, you may submit a verifiable request to access, transfer, or delete your personal information by sending an email to mytwzp@sina.com with "California Privacy Rights" specified in the subject line. To ensure the successful processing of your request, you must:

Provide sufficient information to verify your identity;
Clearly state the nature of your request.

If we cannot confirm your identity or the relevance of the request, we may be unable to respond to it.

We promise to treat all users' privacy requests equally, and service quality and pricing will remain consistent. However, please note that deleting personal information may render some services unavailable.

Data Protection Commitment

We solemnly promise not to sell, trade, or transfer your personal information, and all data processing will strictly comply with the provisions of this Policy.

Scope of Information Processing

The normal use of App functions requires the processing of the following necessary information:

1. Functional Information

User-generated content (including text input, PDF attachments, and AI-generated content);
Contact information (provided via email or support forms).

We only collect the minimum amount of personal information necessary for children to use the App. If you discover any violations of COPPA in the collection of children's information, please contact mytwzp@sina.com, and we will handle the matter in accordance with the law.

2. Automatically Collected Information

With your authorization, we may process the following aggregated data that does not directly identify individuals through third-party analytics tools:

Device information (model, system version, performance indicators, etc.);
Network data (IP address, carrier, connection status, etc.);
Location-related information (IP-based geolocation, time zone, etc.);
App custom identifiers.

This data is used to optimize the App experience and provide basic statistical analysis.

3. Payment Information

In-App payments are fully handled by platforms such as Apple/Google. We will not access your bank card or other payment information.

Purposes of Processing

We process personal information primarily for the following purposes:

Providing service support;
Product optimization and quality control;
Delivering relevant content;
User communication;
Preventing fraud and illegal activities.

Any updates to these purposes will be announced by revising this Policy.

Information Sharing Principles

We only share information in the following circumstances:

Complying with child privacy regulations such as COPPA;
Using third-party services that meet data security standards (e.g., analytics tools like AppMetrica and Adjust).

We are not responsible for the privacy practices of third-party websites or services.

Cross-Border Data Transfer

Due to the needs of global operations, data may be transferred overseas. EU users should be aware that some recipient countries may not have established data protection systems equivalent to those of the EU.

Data Retention

We retain data for the shortest period necessary to fulfill our services. After an account is canceled, we may retain necessary data to comply with legal requirements or ensure system security.

Protection of User Rights

Pursuant to applicable laws, you have the following rights:

Inquiring about and obtaining a copy of your personal information;
Correcting inaccurate information;
Deleting specific information;
Objecting to certain processing activities;
Withdrawing your consent.

To exercise these rights, please contact mytwzp@sina.com. Please note that we can only process data that we actually control.

Security Measures

We use industry-standard encryption technology and organizational management measures to protect data security. While reasonable protections have been implemented, absolute security cannot be guaranteed. In the event of a data breach, we will notify affected parties in a timely manner in accordance with legal requirements.

Special Protection for Children's Privacy

We will not collect information from children under the age of 13 without parental consent. Minors aged 13-18 must use the App under parental supervision. If we discover that children's information has been collected in error, we will delete it immediately. For related reports, please contact support@brainytrainee.com.

Revisions to the Policy

This Policy may be revised from time to time, and the revised version will be published promptly. Major changes will be notified separately.

If you have any questions, please send an email to mytwzp@sina.com.