Pinko Privacy Policy

1. Information We Collect

When you register, sign in to, or use the Service, we may collect information depending on the features you use.

1.1 Account and Profile Information

• Email address
• User identifier (UID)
• Nickname, profile photo, and profile introduction
• Account type or user role
• Other information you voluntarily provide

If you sign in through a third-party authentication service, Pinko may receive information necessary to create and manage your account within the scope of your authorization.

1.2 Transaction, Coin, and Lesson Information

When you purchase Coins, participate in audio or video lessons, or use other paid features, we may collect and retain:

• Coin purchase, top-up, balance, and deduction records
• Order, payment status, transaction time, and transaction amount
• Lesson or call type, start and end times, and duration
• Billing records, call status, and related system records
• Teacher earnings and settlement records

Payment-related information may be processed by third-party payment providers used by Pinko in accordance with their payment procedures.

1.3 Audio, Video, and Device Permissions

To provide one-on-one real-time audio and video services, Pinko may, after receiving your device permission, access:

• Your microphone
• Your camera
• Technical information necessary to establish real-time audio or video connections

You may manage these permissions through your browser or operating system settings. If required permissions are denied or disabled, certain audio or video features may not operate properly.

Unless Pinko separately provides clear notice and obtains any consent required by applicable law, Pinko does not continuously record or store the actual content of ordinary real-time audio or video services.

Pinko may retain necessary call records, including participating account identifiers, call type, status, start and end times, duration, billing records, and technical system records for service operation, transaction processing, customer support, dispute resolution, and security.

1.4 Device and Usage Information

• IP address, device type, and operating system
• Browser type, App version, or service version
• Login time, usage time, and feature activity records
• System error and technical logs
• Technical information required for security and abuse prevention

This information is mainly used to operate the Service, maintain security, troubleshoot issues, manage risk, and improve the user experience.

1.5 Push Notification Information

When you use a Pinko App that supports push notifications, we may collect device push notification tokens and technical information necessary to deliver notifications.

We may use this information to send incoming call, lesson, account, transaction, security, and other Pinko-related notifications. You may manage notification permissions through your operating system settings.

1.6 Customer Support, Reports, and Disputes

• Customer support communications, questions, and complaint details
• User reports and dispute resolution records
• Relevant account, lesson, transaction, or system records required to investigate a matter

2. How We Use Your Information

1. To create, authenticate, and manage Pinko accounts.
2. To provide Teacher profiles and related Platform features.
3. To provide and establish real-time audio and video services.
4. To process Coin purchases, top-ups, deductions, payments, and transaction records.
5. To calculate lesson duration, Coin usage, and Teacher earnings.
6. To send call, lesson, account, transaction, security, and service notifications.
7. To provide customer support, technical troubleshooting, refunds, complaints, and dispute resolution.
8. To prevent fraud, unauthorized transactions, money laundering, account misuse, malicious activity, violations, and other unlawful or abnormal activity.
9. To maintain Platform, account, transaction, and information security.
10. To improve service quality, system performance, and user experience.
11. To perform internal statistical analysis, operations management, and service optimization.
12. To provide AI language-learning, conversation, or related features you choose to use.
13. To comply with legal obligations or lawful requests from courts, government authorities, law enforcement agencies, or other legally authorized bodies.
14. For other purposes reasonably related to the above and permitted by applicable law.

3. Third-Party Services and Data Sharing

To provide reliable and complete Pinko services, we may use the following third-party technologies or service providers depending on the features you use.

Google / Firebase

May be used for authentication, sign-in, cloud databases, cloud storage, backend functions, push notifications, system operation, and related cloud services.

Agora

Primarily used for real-time audio and video communication. Connection and technical information necessary to establish and maintain communications may be processed through Agora services.

Apple

When you use the Pinko iOS App, some features may rely on Apple system services, including Apple Push Notification service (APNs).

PAYUni

May be used for payments, Coin top-ups, transaction processing, and payment confirmation. Payment providers may process information as necessary to complete transactions, prevent fraud, and comply with applicable laws.

OpenAI

Certain AI language-learning, conversation, content-generation, or other AI-assisted features may use OpenAI technologies. Only when you use those features may necessary content or information be processed through the relevant service.

Pinko only permits third-party providers to process information within the scope reasonably necessary to provide the relevant services and does not arbitrarily sell, rent, or disclose your personal information to unrelated third parties.

We may provide, disclose, or otherwise process information where reasonably necessary:

1. To provide a service you request or complete a transaction.
2. With your consent or authorization.
3. To protect the legitimate rights and interests of Pinko, Users, Teachers, or third parties.
4. To investigate fraud, security incidents, violations, or unlawful activity.
5. Where required by law or by lawful requests from legally authorized authorities.

Third-party providers may also process information under their own terms of service, privacy policies, and security practices.

4. International Data Processing

Some cloud, communication, push notification, payment, or AI services used by Pinko may be provided by multinational service providers. Depending on the technical infrastructure, some information may therefore be transmitted to, stored in, or processed outside Taiwan.

Pinko will use such services within the reasonable scope necessary to provide the Service and will take reasonable data protection measures in accordance with applicable law.

Data protection laws may differ between countries and regions. When you use Pinko features involving third-party technology, necessary information may be processed internationally where required to provide those features.

5. Data Retention and Security

Pinko implements reasonable technical and organizational measures to protect your information, including:

1. Using HTTPS, SSL, or other appropriate encrypted transmission technologies.
2. Using account authentication and access-control mechanisms.
3. Restricting unnecessary access to User information.
4. Using appropriate cloud services and information security measures.
5. Monitoring abnormal logins, transactions, system activity, and other conduct that may affect Platform security.
6. Performing system maintenance, updates, and security improvements as reasonably necessary.

Information may be retained based on:

• The period during which you continue to use Pinko
• The period necessary to provide the Service and complete transactions, payments, Coin accounting, or Teacher earnings settlement
• The period necessary for customer support, complaints, and dispute resolution
• The period necessary for information security, fraud prevention, and risk management
• Retention periods required by tax, accounting, transaction-record, or other applicable laws

When the retention purpose no longer applies or the applicable retention period expires, Pinko may delete, de-identify, anonymize, or otherwise appropriately process the relevant information.

Internet, wireless network, and electronic data transmission cannot be guaranteed to be completely secure. Pinko takes reasonable protective measures but cannot guarantee that any information system will be entirely free from security risks in all circumstances.

You are also responsible for protecting your account, password, login device, and related information against unauthorized access.

6. Cookies, Device Information, and Similar Technologies

Depending on the Pinko service you use, we may use cookies, browser storage technologies, device information, or similar technologies.

Web Services

When you use the Pinko website or web-based services, we may use cookies, Local Storage, or similar technologies to:

• Maintain your login session and necessary settings
• Provide website functionality and maintain account and service security
• Analyze system operation and improve user experience

You may restrict, manage, or delete cookies through your browser settings. Disabling necessary cookies or browser storage may prevent certain Pinko features from operating properly.

App Services

When you use the Pinko App, we may use device information, login identifiers, push notification tokens, and other necessary technical information to maintain login sessions, provide push notifications, establish audio or video communications, maintain security, troubleshoot issues, and improve the App experience.

7. Your Personal Data Rights

Under Taiwan's Personal Data Protection Act and other applicable laws, you may exercise the following rights regarding personal information held by Pinko:

1. Request access to or review of your personal information.
2. Request a copy of your personal information.
3. Request supplementation or correction.
4. Request that we stop collecting, processing, or using your personal information.
5. Request deletion of your personal information.

When you exercise these rights, Pinko may request information reasonably necessary to verify your identity for account security and prevention of unauthorized requests.

Certain information may not be immediately deleted where retention is required or permitted for legal obligations, payment and transaction records, tax, accounting, dispute resolution, fraud prevention, information security, or other legally permitted purposes.

If you request deletion of, or cessation of processing of, information necessary to provide core Pinko functionality, some or all of the Service may no longer be available to you.

8. Protection of Minors

If you are under eighteen years of age or have not reached full legal capacity under applicable law, your legal representative, such as a parent or guardian, should review, understand, and agree to this Privacy Policy, the Pinko Terms of Use, and other applicable rules before you register, sign in, or use the Service.

Where applicable law requires legal-representative consent to use the Service, purchase Coins, or conduct another transaction, such consent must be obtained before the relevant activity.

Anyone applying for or using Pinko Teacher features must be at least eighteen (18) years old. Users under eighteen may not apply for Teacher status, provide Teacher services, or receive Teacher earnings.

Pinko may request reasonable confirmation of age, identity, or legal-representative consent where necessary for the nature of the Service, Teacher verification, earnings settlement, legal compliance, account security, or risk management.

If Pinko reasonably determines that a minor is using the Service without legally required consent, or that a User under eighteen is using Teacher features, Pinko may restrict, suspend, or terminate the relevant account or features and process the related personal information in accordance with applicable law.

9. Account and Data Deletion

You may request permanent deletion of your Pinko account through the account-management features provided by Pinko or another applicable method.

1. Pinko may conduct necessary identity verification before deletion to prevent unauthorized account deletion.
2. After permanent deletion, certain account information, personal settings, follow information, and other deleted service data may no longer be recoverable.
3. Account deletion does not extinguish transactions, payments, refunds, Teacher earnings, contractual obligations, infringement liability, or other legal responsibilities arising before deletion.
4. Even after deletion, Pinko may retain certain information for legally required or reasonably necessary periods for tax, accounting, payment and transaction records, Teacher earnings settlement, refunds or chargebacks, dispute resolution, fraud prevention, information security, or other legitimate purposes.
5. Information retained for such purposes will be restricted to those purposes and will be deleted, anonymized, or otherwise appropriately processed when the retention purpose or period ends.

Deleting a Pinko account does not necessarily mean that transaction, tax, payment, or other records that Pinko is legally required to retain will be immediately deleted.

10. Third-Party Websites and External Services

Pinko may provide links to, or functionality involving, third-party websites, payment services, authentication services, or other external services.

When you leave Pinko or directly use a third-party service, the collection, processing, and use of information may be governed by that third party's own privacy policy and terms of service.

This Privacy Policy applies only to personal information collected, processed, or controlled by Pinko and does not necessarily apply to services independently provided by third parties.

We encourage you to review the applicable privacy policies and terms before using third-party services.

11. Updates to This Privacy Policy

Mount Humble Technology Ltd. may update this Privacy Policy due to changes in Service features, technology, applicable law, third-party services, or other operational requirements.

Pinko may provide notice of updates through the website, App, in-service announcements, push notifications, email, or other appropriate means.

The updated Privacy Policy will display the latest revision date. Where applicable law requires additional consent, Pinko will follow the necessary procedure.

We encourage you to review this Privacy Policy periodically to stay informed about Pinko's current privacy and personal-data protection practices.

12. Contact Us

If you have any questions about this Privacy Policy, our handling of personal information, account deletion, or the exercise of your personal-data rights, please contact:

After receiving a request, Pinko may request information reasonably necessary to verify the applicant's identity for account security, personal-data protection, and prevention of unauthorized or fraudulent requests.