Effective Date: May, 1, 2024
This Privacy Policy describes how Muenzo, the offline visual design application developed and managed by Smart Lingo Co. Limited ("Smart Lingo", "we", "us", or "our") collects, uses, and shares information about users of the Muenzo App.
Parties
Smart Lingo Co. Limited, a company incorporated under the laws of Hong Kong with its registered office at 9TH FLOOR, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONGKONG ("Smart Lingo"); and
You, being an individual user of the Muenzo App.
Background
Muenzo is an offline visual design application ("App") developed and managed by Smart Lingo.
This Privacy Policy governs the collection and use of personal data by Smart Lingo when users access the Muenzo App.
The Muenzo App allows users to access all core features offline without an internet connection. When using the App offline, Smart Lingo does not collect or store any personal data on its servers.
Definitions
Personal data means any data relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Use of personal data means the handling of personal data by Smart Lingo, including the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of the data.
Disclosure of personal data means the sharing of personal data with third parties outside Smart Lingo.
You/Your means the individual users of the Muenzo App.
Collection of Personal Data
Smart Lingo collects users' personal data for the purposes of:
Facilitating purchases of products and services through the Muenzo App;
Providing customer support to users; and
Analysing usage data to improve users' experience with the Muenzo App.
By providing their personal data to Smart Lingo, users consent to the collection of such personal data for the purposes stated in this Privacy Policy.
Publisher Service
If you choose to use our "Publisher" service to publish and share your notes, we will need to store the data you publish on our servers. Your data will be stored for the duration of your subscription. If your Publish subscription expires, your data will remain stored on our servers for one month, after which it will be permanently deleted. If you cancel the subscription yourself, your data will be deleted immediately. Any local vaults on your devices are unaffected.
Use of Personal Data
Smart Lingo uses Firebase Analytics to analyse basic usage patterns and performance metrics of the Muenzo App on an aggregate and anonymous basis. This includes metrics such as device types used to access the App, most used features, and app performance. However, no personal data relating to individual users is collected through these analytics.
When users purchase products or services through the Muenzo App, their email addresses are collected for processing such purchases. Email addresses will only be used to process the purchases and will not be used for any other marketing or promotional purposes.
Email addresses collected for processing purchases will not be shared with any third parties, except for payment processors such as Stripe and PayPal as necessary to complete transactions.
Smart Lingo shall not use any personal data provided by users for any purposes other than those stated in this Privacy Policy, unless user consent is obtained in advance.
Disclosure of Personal Data
Smart Lingo may disclose a user's personal data to payment processors including Stripe and PayPal for the sole purpose of processing purchases and payments made through the Muenzo App.
We only use users' email addresses to send payment receipts and important product updates. Users may choose to delete their Muenzo account at any time using the account dashboard, which will permanently delete their account, licenses, and subscriptions.
Smart Lingo may disclose a user's personal data to its lawyers, auditors and other outside professional advisers as necessary.
Smart Lingo may disclose a user's personal data if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to (i) comply with legal process; (ii) enforce this Privacy Policy; or (iii) protect the rights, property or safety of Smart Lingo, its users, or others.
In connection with any reorganisation, restructuring, merger or sale, or other transfer of assets (including in connection with any bankruptcy or similar proceedings), Smart Lingo may transfer any personal data.
Smart Lingo may disclose aggregated and anonymised data to third parties for analytics and other purposes. However, such disclosed data will not include any personal data that can identify any individual users.
Data Security
Smart Lingo implements appropriate technical and organisational measures to protect personal data collected through the Muenzo App against unauthorised or unlawful processing and accidental loss, destruction or damage.
Technical security measures implemented include:
Data is stored on secure servers located in the United States of America with firewalls and encryption technology;
Access to servers is restricted through multi-factor authentication and authorisation procedures;
Regular security audits and vulnerability assessments are conducted to identify and address any issues.
When accessing our website from outside the United States, please note that your information may be transferred, stored, and processed by us and our third-party partners in our facilities or in locations where they operate.
Physical security measures implemented include:
Servers are located in secured facilities with controlled access and 24/7 monitoring;
Backup servers are located separately in a different secured facility for redundancy.
Organisational security measures implemented include:
All staff receive training on Smart Lingo's privacy and security policies and procedures;
Access to personal data is restricted on a need-to-know basis through authorisation controls;
Third party service providers are contractually required to implement adequate security measures to protect personal data.
Data Retention
Smart Lingo will retain users' personal data for a period of 5 years from the date the user last accessed their account or used the Muenzo App.
The retention period of 5 years has been determined based on Smart Lingo's legitimate business needs to maintain records for legal and accounting purposes.
At the end of the 5 year retention period, users' personal data will be deleted from Smart Lingo's records and IT systems in a secure manner so that the data cannot be reconstructed or retrieved.
Personal data may be stored for longer than the 5 year retention period if required by law or for the establishment, exercise or defence of legal claims. In such cases, Smart Lingo will only retain the minimum amount of personal data required and only for as long as is necessary for the permitted purpose.
Your Rights
Right to access data
You have the right to request access to your personal data held by us.
Upon receipt of your written request and sufficient verification of your identity, we will provide you with a copy of your personal data within 40 days.
Right to rectification
You have the right to request rectification of any inaccurate or incomplete personal data held by us.
We will rectify the data within 40 days of your request.
Right to erasure
You have the right to request erasure of your personal data held by us.
We will erase the data within 40 days of your request, except where there is a legal requirement for us to retain the data.
Right to restriction of processing
You have the right to request restriction of processing of your personal data held by us in certain situations such as when the accuracy is contested.
Right to data portability
You have the right to receive your personal data held by us in a commonly used machine readable format.
Right to object
You have the right to object at any time to processing of your personal data held by us for direct marketing purposes.
Right to withdraw consent
Where processing is based on consent, you have the right to withdraw your consent at any time.
Changes to this Privacy Policy
Smart Lingo reserves the right to amend or update this Privacy Policy at any time by publishing the amended version on the Muenzo App.
Users will be notified of any material changes to this Privacy Policy through an in-app notification or email notification.
Continued use of the Muenzo App after an amendment to this Privacy Policy is published will constitute acceptance of the updated Privacy Policy.
Unless expressly stated otherwise, any amended version of this Privacy Policy approved and published by Smart Lingo takes effect immediately from the date of publication.
A record of previous versions of this Privacy Policy will be maintained so that users can review the changes made at any time on the Muenzo App.
Contact Us
Contact Details. Smart Lingo Co. Limited can be contacted at 9TH FLOOR, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONGKONG or via email at admin@muenzo.com