Privacy Policy

Welcome to Timekettle App! Timekettle (Shenzhen Timekettle Technologies Co., Ltd, "we", "us") takes your privacy seriously！

When you utilize our real-time translation service, you act as the data controller for any audio, text, photos, or other materials you submit for translation. We will process these data in accordance with your instructions (e.g., translating from one language to another) as your data processor, we will process your materials in accordance with the Data Processing Agreement (DPA). Prior to your use of our real-time translation services, we require you to consent to the Data Processing Agreement (DPA). Should you decline to agree to our DPA, access to our real-time translation services will be denied. For your information, the following details how we safeguard your privacy during real-time translation, adhering to the principles of "Privacy by Design" and "Privacy by Default":

If the material contains conversations with other people, speeches, or texts that are subject to the copyright or other rights of others, please obtain their authorization before translation.

Regarding all other personal data collected by the App to provide our translation services (such as username, password, payment information, etc.), we (Shenzhen Timekettle Technologies Co., Ltd) act as the data controller. We will safeguard your personal data in accordance with this Privacy Policy (referred to as the "this Policy").

If you have any questions regarding anything in this Policy, wish to contact our EEA representatives or DPO，or intend to exercise any rights as a data subject, please contact [email protected].

If you are located in the European Economic Area (EEA), the provisions in the main body of this Privacy Policy shall apply to you.

For users residing in California (USA), Japan, Thailand, or South Korea, please also consult the jurisdiction-specific addendum corresponding to your region. In the event of any conflict between these special provisions and the main policy text, the regional addendum shall prevail.

For individuals from all other countries/regions, we will provide protections in accordance with applicable local laws.

In this section, we will explain the types of personal data we collect and use, how we use it, the legal basis for such use, and the recipients to whom we will disclose your personal data.

While you are not legally required to provide personal data to us, certain personal data is necessary for us to provide our products and services. Without these data, we may not be able to deliver our products and services to you.

Data types	Use	Legal Bases	Recipients
When you choose to Register/Login via email, we collect: Email address, password, username, User ID When you choose to Register/Login via third-party accounts, we collect: Facebook: Facebook UID, username, User ID Google: Google UID, username, User ID Apple: Apple UID, username, User ID WeChat: WeChat UID, username, User ID	To create a user account, verify user identity, and facilitate the management of your account (such as with verification codes).	Necessary to perform our contract with you.	Cloud Service Providers, the third-party platform you have chosen （such as Facebook）
When you use Personalized Glossary Function to personalize terms like names and locations to make the translation more accurate and tailored to your needs, we collect: Entries When you select the source and target languages (such as Chinese, English, Spanish) for personalized terms, we collect: Language settings	To personalize your experience in accordance with your need.	We collect these data with your consent.	Cloud Service Providers
When you use Human-like Voice Function to customize the gender of the voice used for audio playback, we collect: Gender settings (male or female)	To enhance the translation quality and personalize the user experience in accordance with your request.	We collect these data with your consent.	Cloud Service Providers
When you Top Up Fish Coins (virtual currency) directly within the Timekettle App, we collect: User ID, recharge amount (number of Fish Coins) When you Top Up your Fish Coin balance using a Fish Card, we collect: User ID, Fish Card number, Fish Card activation code, recharge amount (number of Fish Coins)	To verify your identity, payment information, and payment results.	Necessary to perform our contract with you.	Cloud Service Providers
When you Pay within Timekettle App, we collect: User ID, third-party payment system name, third-party payment receipt, transaction ID, payment amount, currency type, purchase history	To verify your identity, payment information, and payment results.	Necessary to perform our contract with you.	Cloud Service Providers, Payment Service Providers
When you Redeem your Fish Coins for a Translation Time Card within the Timekettle App, we collect: User ID, redemption amount (number of Fish Coins), Translation Time Card ID, Translation Time Card type, time duration, start time, expiration time When you Redeem your Fish Coins for Offline Packages within the Timekettle App, we collect: User ID, redemption amount (number of Fish Coins), Offline Package type ID, Offline Package information When you Redeem Coupons for Translation Time Card or Offline Packages within the Timekettle App, we collect: User ID, Coupon ID, Translation Time Card ID, Offline Package type ID	To verify your identity, confirm the redemption result.	Necessary to perform our contract with you.	Cloud Service Providers
When you Redeem Translation Time Card for Translation Services within the Timekettle App, we automatically collect and update the usage duration data: User ID, time duration, start time, expiration time, Translation Time Card ID, remaining Translation Time Card time	To verify your identity, confirm the redemption result.	Necessary to perform our contract with you.	Cloud Service Providers
When you use the Translation Services within the Timekettle App, we automatically collect the usage duration data: User ID, time duration, start time, expiration time	To calculate your usage duration and billing status.	Necessary to perform our contract with you.	Cloud Service Providers
When you use the Help and Feedback Function within the Timekettle App: Problem description text, App usage logs, Problem type, User-provided images, User contact information	To locate faults and issues in equipment, analyzing your feedback and providing a personalized solution.	Necessary to collect problem type to perform our contract with you to provide customer support services. We collect problem description text, App usage logs, User-provided images, User contact information with your consent.	Cloud Service Providers, Customer Support Service Providers
Information You Provide to Us: When you use the Customer Support Function to provide feedback: Email address, purchase channel, problem title, detailed problem description, related files When you send an email through the in-app Email Function to [email protected]: The email subject and body written by users, system-added information (app version, device model, OS version, headphone model, and user ID) which you can freely edit or remove. When you fill out a Survey within the app: Survey responses and any related uploaded files	To help resolve your issues and improve our products and services, such as by analyzing feedback to optimize product features and using surveys to understand user needs.	Necessary to perform our contract with you to provide customer support services. We collect your email subject and body, survey responses and any related uploaded files with your consent.	Cloud Service Providers, Customer Support Service Providers, Survey Service Providers
We collect user interaction data for app performance analytic, including: Page view counts, time spent on pages, button click frequencies, other user interaction metrics	To conduct app performance analytic, for example, identifying areas for product improvement, and personalizing survey pop-ups.	We collect these data with your consent.	Cloud Service Providers
When you use the Fun Translation (AI Character) Function within the Timekettle App, we collect: Voice recordings and text messages you input during the AI interaction Region information (used to route your request to an appropriate AI service provider)	To provide interactive AI-powered translation experiences, including generating character-based translation responses.	We collect these data with your explicit consent, obtained through an in-app dialog before first use.	Cloud Service Providers, Third-Party AI Service Providers (see Section 3)
When you use the AI Speaking Coach (AI Language Tutor) Function within the Timekettle App, we collect: Voice recordings and text messages you input during the AI interaction Region information (used to route your request to an appropriate AI service provider)	To provide AI-powered language learning and speaking practice, including generating conversational tutoring responses.	We collect these data with your explicit consent, obtained through an in-app dialog before first use.	Cloud Service Providers, Third-Party AI Service Providers (see Section 3)

Important Notice Regarding AI Features

To provide the Fun Translation (AI Character) and AI Speaking Coach (AI Language Tutor) features, your conversation content (voice recordings and text messages) is first transmitted to our own servers, where it is then forwarded through encrypted channels to third-party large language model (LLM) services for response generation. Depending on your region, different third-party LLM services may be used, including but not limited to Alibaba Cloud Qwen, OpenAI, and other industry-leading LLM providers.

These third-party AI services only process your conversation content to the extent necessary to generate AI responses. They do not receive your account information, contact details, location, or any other personally identifiable information. Under the applicable API service terms of these third-party providers, your data is not used to train their models or for any other purpose unrelated to providing this service.

We continuously evaluate the third-party AI services we use and may make adjustments based on service quality, regional availability, and other factors. In the event of material changes, we will inform you through updates to this Privacy Policy and in-app notifications.

Before you use any AI-powered feature for the first time, we will clearly explain the above data processing practices through an in-app dialog, and the feature will only be enabled after we obtain your explicit consent. You may decline to use these features at any time. If you decline, you will not be able to use the corresponding AI features, but this will not affect your use of Timekettle's other basic translation services.

We manage your data carefully to ensure that we only keep what is necessary. To protect your privacy, we routinely delete logs and retain only the data needed to provide the services you have requested, as detailed in our Policy.

We retain your data for as long as necessary for the purposes outlined in this Policy, and where applicable, in accordance with your consent. Once these purposes are fulfilled or if you submit a deletion request to our Data Protection Officer via email to [[email protected]] or terminate your account, whichever occurs first, we will either delete the data completely or anonymize it.

However, we are required by applicable laws to retain certain personal data. We will either delete such data after the statutory retention period has expired or anonymize it.

For AI-powered features in AI Lab (including Fun Translation / AI Character and AI Speaking Coach / AI Language Tutor), your conversation content is processed in real-time and only cached temporarily on our servers. We do not retain any historical records of these interactions — each new conversation replaces all previous conversation data. For details regarding the third-party AI service providers involved in processing this data, please refer to Section 1 ("Important Notice Regarding AI Features") and Section 3 of this Policy.

We may transfer your personal data outside of your location as necessary to provide our services. Our data centers are located in Japan and the United States.

We implement technical and organizational security measures, including encryption technology, to protect your information. Access to our systems and technology is strictly limited by comprehensive information security policies.

We maintain a formal incident management process to ensure the swift identification, response, and resolution of any security incidents. Our process is designed to minimize impact and keep customers informed without delay.

Third Party Recipients	For What?
Cloud Service Providers	Hosting and delivering our services
Authentication Service Providers	User verification and account security
Payment Service Providers	Processing transactions and payments
Customer Support Service Providers	Providing customer service, technical support，troubleshooting, and after-sales assistance
Survey Service Providers	Understanding user feedback and improving services
Real-time Communication Service Providers (Agora/Shengwang)	Enabling real-time audio and video communication for our core translation features. We share IP address, signal strength, network type, user agent, Bluetooth status, and SSID (the name of the Wi-Fi network you are connected to, used to detect network environment and select optimal communication paths to ensure real-time audio and video call quality)
Third-Party AI Service Providers (including but not limited to Alibaba Cloud Qwen, OpenAI)	Processing conversation content submitted through Fun Translation (AI Character) and AI Speaking Coach (AI Language Tutor) features to generate AI responses. These providers receive only the conversation content necessary to generate a response, and under their applicable API service terms, your data is not used to train their models.

Our data centers are situated in the United States and Japan, and some of our service providers operate beyond the European Economic Area (EEA). Consequently, your personal data may be processed outside the EEA. These third countries might not offer the same level of data protection as within the EEA，and have not obtained an adequacy decision by the European Commission. To ensure lawful international data transfers, we enter into Standard Contractual Clauses (SCCs) with data recipients and perform Transfer Impact Assessments (TIAs). Depending on the results of the TIA, we implement additional safeguards, which include, but are not limited to: vendor selection processes, data encryption protocols, stringent access controls, and data pseudonymization measures. These combined measures ensure that your personal data receives equivalent protection to that within the EU. You can obtain copies of our SCCs by contacting [email protected].

To exercise your rights above, email us at [email protected]. Please state which right(s) you wish to exercise and your intended action. For security, we may ask for identity verification or clarifying your request details to prevent unauthorized data handling. We will respond within legal timelines.

We will inform you of any changes via general announcements on our services or by sending you a notification when you log in to or update the App. If the update includes terms that significantly impact your rights, we will seek your consent once more.

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Policy, this English version shall prevail.