App Data Cross-border Transfer Declaration

Please note that we have revised this Declaration on January 1, 2026.

This Declaration aims to obtain your authorization for LIG EDUTECH PTE.LTD. (“LINGOMASTER”) to transfer your personal information to our overseas affiliates for the purpose of providing standardized online language learning services to global users. Please read the following terms carefully and make your decision after full understanding. By ticking "I have read and agree to the Data Cross-border Transfer Declaration," you are deemed to have voluntarily consented to the transfer of your personal information abroad for the purpose of providing online language learning services.

1. Overseas Recipients of Personal Information

LIG EDUTECH PTE.LTD. (LINGOMASTER), located at 60 PAYA LEBAR ROAD, #11-53, PAYA LEBAR SQUARE, SINGAPORE 409051, conducts centralized data processing activities to provide globally unified online language learning services for LINGOMASTER.

Chengdu Chaoyouai Technology Co., Ltd., located at No. 4-6, 1st Floor, Unit 1, Building 4, No. 219 Tianhua 2nd Road, Chengdu Hi-tech Zone, China (Sichuan) Pilot Free Trade Zone.

2.Purposes of Cross-border Transfer and Processing of Personal Information

LINGOMASTER centrally manages and processes the online language learning needs of users from all over the world. Therefore, the purposes of our personal information transfer and processing include:

System Security Management: To support your account login operations, perform identity authentication during login, and ensure system and data security;

Unified Management of Language Learning Services: To provide unified and standardized language learning services to users in different regions globally, implement standardized service management, and provide identical learning courses and training services to users at the same language proficiency level;

Paid User Management: If you choose to purchase LINGOMASTER services for a seamless learning experience, we will verify your order information to grant access to the corresponding paid courses.

3. Types of Personal Information Transferred and Processed Cross-border

The personal information we transfer and process cross-border is directly related to the processing purposes, including the following:

System Login and Access Operation Information: Your account (including third-party accounts such as Facebook account and Apple ID), account password, time zone, country of IP address, and software usage records (including target language, source language, course name, daily learning goals, course progress, exercise names, completed questions, correct/incorrect answers, and question preferences);

User Relationship Management Information: Your encrypted mobile phone number, email address, and usage preferences;

Terminal Device Information: Operating system and device model;

Property Information: Order information (payment methods, subscription details) and redemption tools for value-added services.

4. Storage and Security of Personal Information

We guarantee the security of your personal information during cross-border transfer. We utilize Alibaba Cloud's dedicated cross-border transmission lines for the transfer of your personal information and store your personal information in the Alibaba Cloud International us-east-1 data center. Alibaba Cloud has obtained certifications including ISO 27001, ISO 27701, ISO 27017, BSI 10012, and Level 3 of the Multi-Level Protection Scheme (MLPS) 2.0. To safeguard your information security, we have signed relevant contracts with the aforementioned provider (including confidentiality agreements and data protection-related clauses).

5. Guarantee

We undertake that we will not transfer your personal information to any overseas personal information controller other than those described in this Declaration without your permission.If you need to exercise your rights regarding your personal information, you may assert your legal rights through the relevant paths specified in the Privacy Policy.You may also withdraw your consent for cross-border transfer at any time via the following path: Settings - Privacy - Manage My Consent. Please be advised that if you withdraw your consent, we will cease processing your personal information; however, this will not affect the validity of the personal information processing activities carried out based on your consent prior to the withdrawal.

Address: 60 PAYA LEBAR ROAD, #11-53, PAYA LEBAR SQUARE, SINGAPORE 409051

Phone: +6531588866

Email: [baicizhan@baicizhan.com]

If you agree to the above content, please tick to confirm.