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picovo.

THE DETAILS, IN PLAIN SIGHT

Privacy

Policy draft — publication details are being finalized. This version is not ready for App Store submission.

Draft updated October 29, 2026

1. Who we are

Picovo is a Vietnamese learning service operated by Ambivalent Co., a sole proprietorship in the Republic of Korea, represented by Kim Seokjun. This policy covers the Picovo app and picovo.app. Privacy inquiries may be directed to contact@picovo.app once the support address is active.

2. Information processed

Account information includes account identifiers, sign-in information, and an email address when you register using email. Learning information includes saved words, meanings, sentences, notes, wordbook selections, settings, review history, and practice results.

AI features process the text and relevant learning context submitted for the requested feature. Depending on the feature, audio recordings or transcripts and images you choose to upload may also be processed. On-device reading recognition and server pronunciation analysis are separate paths; server analysis sends the relevant audio for processing.

Subscription processing uses internal account identifiers, product and transaction identifiers, subscription status, and usage records. Payment card details are handled by Apple rather than collected directly by Picovo. Technical information such as IP addresses and request logs may be processed by our hosting and infrastructure providers.

3. Why we process information

We use information to authenticate accounts, save and sync learning content, schedule reviews, provide requested AI and speech features, verify subscriptions, measure available AI allowance, prevent abuse, maintain security, and respond to support requests.

Depending on the processing and applicable law, the basis may be providing the service you request, your consent, a legal obligation, or legitimate interests such as service security. Permission for microphone or photo access can be managed in your device settings. Withdrawing access may limit the associated feature.

4. Service providers and international processing

Picovo uses Google Firebase for authentication, Google AI services for generation and speech processing, RevenueCat and Apple for subscription services, and Cloudflare for website delivery and media infrastructure. Relevant inputs and identifiers are sent to providers as needed for the feature; using the app does not mean every item is sent to every provider.

The website is served through Cloudflare’s global network. Information processed by external providers may be handled outside your country, including outside the Republic of Korea. The production recipient entities, processing countries, transfer details, and retention terms must be confirmed before this draft is published. Do not submit sensitive personal information in AI prompts.

5. Storage and deletion

Saved learning content and history are stored to provide your account’s learning experience. The mobile app also maintains local learning replicas and media caches. Archiving a word or sentence is not the same as permanently deleting account data.

Deletion requests require identity verification where appropriate. Some billing, security, and trial-abuse-prevention records may need to be retained separately after account deletion. The exact production retention periods, statutory grounds, backup lifecycle, and deletion schedule remain under review for the published policy. We do not promise immediate deletion from every backup or third-party system.

6. Your choices and rights

Subject to applicable law, you may request access, correction, deletion, restriction, portability, or objection, and withdraw consent where consent is the basis for processing. Contact support using the email associated with your account when possible. We may verify your identity before fulfilling a request.

Deleting the app does not delete server-side account data or cancel an Apple subscription. Subscription cancellation is managed separately through Apple. If European or UK data protection law applies, you may also have the right to complain to your local data protection authority.

7. Website, security, and children

This website does not add advertising trackers, analytics scripts, or a mailing-list form. Cloudflare may process technical request data to deliver and secure it. Links to Apple and other external sites are subject to those services’ own policies.

We use measures including authenticated access, user-scoped data access, and encrypted network connections to protect information. No service can guarantee absolute security. Picovo is not intended for children under 14. If you believe a child has provided information, please contact us.

8. Changes and contact

The published policy will include an effective date. Material changes will be communicated as required by applicable law. Operator: Ambivalent Co. / Kim Seokjun, Republic of Korea. Privacy contact: contact@picovo.app. This is a draft, and missing publication details are not replaced by the draft revision date.

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