# INNOTRIK Privacy Policy
Updated: October 10, 2025
Effective: October 17, 2025
INNOTRIK is a companion app developed by **Shenzhen Innotrik Technology Co., Ltd.** ("we", "us", or "our") for spoken-language learning devices and related AI services.
We understand the importance of personal information and protect your privacy in accordance with applicable laws and industry best practices.
This Privacy Policy explains how we collect, use, store, transfer (if applicable), and protect your personal information, and how you can exercise your rights.
## Overview
This policy helps you understand:
1. How we collect and use personal information
2. How we use cookies and similar technologies
3. Third-party partners, data transfer, and public disclosure
4. How we store personal information
5. How we protect personal information security
6. How to exercise your personal information rights
7. Minor protection terms
8. Policy updates and notices
9. How to contact us
Granting consent does not mean we will collect all possible information. We only process information necessary for specific functions or as required by law.
Sensitive permissions such as microphone, location, and Bluetooth are not enabled by default and are used only after your explicit authorization for specific features.
## 1. How We Collect and Use Personal Information
We collect information you provide directly and information generated during service usage through automated means.
### 1.1 Phone Number Verification
When you first use the service, you may register or bind your account with a phone number.
Phone number verification may be required for legal compliance (real-name requirements) and account security. If you refuse to provide a phone number, some features (such as AI conversation) may not be available.
If you choose one-click login, we process your phone number with telecom operators based on your consent.
### 1.2 Intelligent Dialogue and Real-Time AI Practice
To provide AI conversation and translation features, we may process text, voice, images, files, and operation commands that you submit.
If you use voice input, we request microphone permission. If you decline, voice input is unavailable but other features remain usable.
Current version note:
- Camera and photo upload are not supported.
- The app does not request camera or gallery permissions for unsupported features.
In dialogue scenarios:
- We process your input to generate text/voice responses.
- If you initiate AI search, we process your query to provide relevant search results.
- If you ask for nearby places, we may process precise location information (for example, GPS, WLAN, Bluetooth, or base station signals) only when needed for that request.
- If your submitted content includes personal information of others, you must obtain lawful authorization first.
- Vocabulary and scenario data you create is intended for your own account usage.
### 1.3 Meeting Recording Support
If enabled by you, meeting-related features may record system audio and microphone audio for speech-to-text and summarization.
Speaker distinction may rely on temporary voiceprint clustering for segmentation. Relevant voiceprint features are processed in an anonymous and temporary manner and are deleted after processing.
You are responsible for ensuring recording use is lawful and authorized by relevant participants.
### 1.4 Feedback and Customer Service
To respond to your issues, we may retain communication records, feedback content, device details, and contact information you provide.
When handling disputes, we may provide necessary information to regulators or consumer protection authorities as required by law.
### 1.5 Security and Operation
For service security, reliability, and diagnostics, we may process:
- Device model and OS version
- Device identifiers (platform-specific IDs)
- IP address and network status
- App version and logs
- Crash/performance data
- Sensor/network diagnostics necessary for service safety and stability
### 1.6 Purpose Changes
If we introduce new features that require additional information processing beyond the original purpose, we will provide notice and obtain consent where legally required.
### 1.7 Exceptions to Consent
In certain circumstances permitted by law, we may process personal information without prior consent, such as:
- Legal obligations
- Public safety or major public interest
- Criminal investigation, prosecution, trial, or enforcement
- Protection of life, property, or other significant lawful rights
- Information publicly disclosed by you
- Contract performance requested by you
- Information from lawful public sources
## 2. Partners, Transfer, and Public Disclosure
### 2.1 Third-Party Partners
Where necessary, we cooperate with affiliates and third-party service providers under legal agreements and data protection requirements.
We follow principles of legality, purpose limitation, data minimization, and security review.
### 2.2 Typical SDK Integrations
To enable app functions, we may use SDKs such as:
- ByteDance StarBurst SDK (AI dialogue, translation, TTS)
- Device information plugins (device diagnostics and activation checks)
Collected data is used for feature delivery and service reliability, not for unrelated commercial exploitation.
### 2.3 Data Transfer
In case of merger, acquisition, or asset transfer, your personal information may be transferred in compliance with applicable laws and with equivalent or stronger protection obligations.
### 2.4 Public Disclosure
We do not publicly disclose your personal information unless:
- You provide explicit consent
- Disclosure is required by law
## 3. Data Storage
### 3.1 Storage Location
Personal information collected in mainland China is stored in mainland China unless cross-border transfer is legally permitted and compliant.
### 3.2 Retention Period
We retain personal information only as long as necessary for service purposes, legal obligations, dispute handling, audit, and security requirements.
After retention expires, we delete or anonymize data as required by law.
## 4. Security Measures
We implement reasonable technical and organizational measures, including encryption, access control, de-identification, and security auditing.
No system can guarantee absolute security. In case of a data security incident, we will take remedial actions and notify you according to legal requirements.
## 5. Your Rights
Subject to applicable law, you may request to:
- Access, copy, correct, or supplement personal information
- Delete personal information under lawful conditions
- Withdraw consent for specific processing
- Manage permissions in device settings
- Submit complaints or inquiries
Permission controls can also be managed in the app settings path equivalent to "My -> Settings -> System Permissions".
Current permission usage:
- Bluetooth: connect INNOTRIK devices
- Location: required by system for Bluetooth scanning
- Microphone: voice recognition and translation
Currently not used: camera, photo upload, clipboard read (disabled at code level).
## 6. Contact and Complaints
If you have privacy-related questions, suggestions, or complaints, contact us:
- `Dataprivacy@innotrik.com`
- `super@innotrik.com`
We will respond after identity verification within the period required by applicable law.
## 7. Minors
If you are under 18, read this policy with your parent or guardian and use the service with guardian consent.
For users under 14 ("children"), guardian consent is required before use.
If we discover children's information collected without verifiable guardian consent where required, we will delete it as soon as practicable.
## 8. Policy Updates
We may update this Privacy Policy when services or legal requirements change.
Updated versions will be published through official channels before they take effect where required by law.
## 9. Company Information
Shenzhen Innotrik Technology Co., Ltd.
If you have questions about this policy, contact:
- Email: `super@innotrik.com`
- Service Phone: `4000-779-663`