Privacy Policy

01Who we are

Tongda is a simplified Chinese learning app and the website at tongda.app, operated by One FortySeven Limited (“we,” “us,” “our”), with its registered office at Unit 909, Prosperity Millennia Plaza, 663 King's Road, Quarry Bay, Hong Kong. This policy covers the website, the early access signup and our emails, and the Tongda app, including early-access and test versions. One FortySeven Limited is the controller of the personal data described here.

You can reach us at hello@tongda.app.

02What we collect

• Early access signup: 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 early access form outcomes, interaction heatmaps, and the campaign parameters on the link you arrived on. This is measured without cookies, using a short-lived pseudonymous identifier (see section 06).
• 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, the email address and sign-in method you use, onboarding answers, settings, timezone, learning progress, review history, streaks, the people, places, and things you add to your palette, 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 and support replies.

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.

03How we use it

• To provide Tongda: run the website and early access signup, operate your account, schedule your reviews, generate mnemonic suggestions and scenes, deliver audio, and answer your support requests.
• To communicate with you: launch and early-access announcements, marketing emails, and account, security, and support messages.
• To keep Tongda safe and working: prevent abuse, enforce rate limits, fix errors, and secure the service.
• To improve the product: understand how Tongda is used and make it better.
• To meet legal obligations: keep records and respond to lawful requests.

We do not sell or rent your personal information, including your email address. We do not use your data for advertising. Marketing emails always include an unsubscribe link.

04Service providers and international transfers

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

• Cloudflare: website and content hosting, security, and early access signup handling.
• Convex: app backend and database.
• Clerk: sign-in with your email address or a third-party provider such as Apple or Google. When you use a third-party provider, that provider also processes your sign-in.
• Resend: our emails, including early access, launch, marketing, account, and support messages.
• PostHog: product analytics, error and crash diagnostics, and monitoring of generation requests, including their inputs and outputs. In the app, these records are linked to your account identifier.
• OpenRouter: producing mnemonic suggestions and scenes from your inputs. OpenRouter routes each request to an upstream model provider, such as OpenAI. These providers may retain generation inputs and outputs and may use them to improve their models under their own terms.
• Crisp: in-app support chat. Crisp receives your user id, an optional nickname, your messages and attachments, and, if notifications are allowed, a push token for replies.
• Expo: app updates, app performance and reliability telemetry, and, if you turn on notifications, push delivery via Apple's and Google's notification services.
• Apple: app distribution through the App Store and TestFlight, Sign in with Apple, and push notification delivery. Apple processes installs, tester feedback, and any diagnostics you share with it under its own terms.
• Google: app distribution through Google Play, including its testing tracks, Sign in with Google, and push notification delivery. Google processes installs and any diagnostics you share with it under its own terms.

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. Providers that act on our behalf may use personal data only to provide their services to us and must protect it under their agreements with us. Apple, Google, and the model providers reached through OpenRouter also process some data under their own terms, as described above.

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. Do not put secrets or sensitive personal information into prompts. We store generated content you keep, and generation providers may retain request and response data and may use it to improve or train their models under their own terms. Generated suggestions can be inaccurate or unexpected, and you choose what to keep.

06Cookies and device storage

The website measures usage without cookies. Nothing is stored on your device. Our analytics provider PostHog groups events with a short-lived pseudonymous identifier derived from your IP address and browser, so visits are not linked across days. IP addresses are not kept with analytics events.

The website does not use advertising or cross-site tracking cookies.

The app stores session tokens, settings, and offline study data on your device.

07Retention and deletion

We keep early access contact data while you are subscribed. If you unsubscribe, we stop sending marketing emails. You can ask us to delete your email address entirely.

Account and study data is kept while your account is active. You can delete your account in the app at any time. We then delete your account and study data, subject to limited retention for backups, security, or legal reasons. Some records at our service providers, such as analytics and support history, are not deleted automatically. Email hello@tongda.app and we will delete or de-identify them. Deleting your account does not cancel an App Store or Google Play subscription.

08Your privacy rights

Where the GDPR or similar law applies, we rely on these legal bases:

• Contract: to create and operate your account, sync your study data, generate scenes, and provide support.
• Consent: to send early access and marketing emails. You can withdraw consent at any time.
• Legitimate interests: to run cookieless audience measurement on the website, prevent abuse, enforce rate limits, diagnose errors, and secure Tongda. You can object to this processing by contacting us.
• Legal obligation: to keep required records and respond to valid legal requests.

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.

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. Providing your email address is voluntary, but without it we cannot sign you up for early access or create your account. We use your email address for direct marketing of Tongda only with your consent, which you can withdraw at any time without charge through the unsubscribe link. Access and correction requests go to hello@tongda.app.

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 personal information, share it for cross-context behavioral advertising, or use it for targeted advertising. 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

Tongda is not directed at children under 16, and we do not knowingly collect personal information from children under 16. 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.