PRIVACY POLICY

1. General

This Privacy Policy applies to Migii websites, mobile apps, and related services ("Service"). By using the Service, you agree with EUP's collection, use, and sharing of your personal information in accordance with the terms of this Privacy Policy.

Please note that EUP is constantly testing and improving our product features. Any features discussed in this Privacy Policy may not be available to all users or in all jurisdictions.

2. Information We Collect

When you use the Service, EUP may collect the following personal information about you.

a. Account Registration

To register for a Migii account, you may provide us with your age and email address. In some countries, you may also provide us with your phone number.

You may also register for a Migii account using certain social logins, such as Google and Facebook. If you register for Migii using a social login, EUP may receive information about you from your social login provider, including your email address.

b. Profile Page and User-Generated Content

After you register for your Migii account, a profile page will be created for you ("Profile"). Your Profile will be populated by information you submit, such as your name, username, and profile picture ("User-Generated Content"). Your age, phone number, and email address are not included in your public Profile.

Your Profile will also include information about your learning progress, such as the exam levels you are studying, your learning statistics, and your achievements. By default, your Profile is public. You can set your Profile to private in your settings.

c. Premium and AI Features

If you subscribe to Migii Premium, you may interact with Artificial Intelligence ("AI") features, such as personalized feedback on your answers. When you interact with AI features, your information may be shared with AI vendors, which may keep a copy of your responses for their own purposes. Please do not submit any personal or confidential information when using AI features.

d. Speaking and Listening Activities

Some activities involve you speaking into the Migii app. To recognize speech, your audio may be sent to a third-party provider. EUP may also collect and analyze your speech to help us understand the effectiveness of our lessons and to improve the product. You may skip speaking activities. Any audio you agree to send to EUP is anonymized when it reaches our servers.

e. Activity Data and IP Addresses

When you use the Service, we may generate data about your use of the Service, which may include browser and device data, log data, device ID, and IP address. We will also generate data regarding your engagement in educational activities on the Service.

We will retain your IP address for no more than 30 days, unless exceptional circumstances require longer retention.

f. Cookies

When you access the Migii website, we store certain data from your browser using cookies. We use session ID cookies to confirm that users are logged in. If you do not want your data to be collected by cookies, you can deny or accept the cookie feature in most browsers.

g. Google Analytics

We use Google Analytics to help us understand how users engage with our website. Google Analytics uses first-party cookies to track user interactions and compile reports without identifying individual visitors.

3. How We Process Your Information

EUP may process your personal information according to the following legal bases: to provide products or services you request, to promote EUP's legitimate interests, to comply with legal obligations, and with your consent.

a. Providing and Improving the Service

EUP will process your personal information to provide and improve the Service — for example, to maintain your Profile and learning progress, personalize learning content, detect and fix bugs, perform research, and provide customer service.

EUP may share personal information with third parties that help us provide or improve the Service, including hosting providers, search engine providers, analytics providers, support providers, and payment processors.

b. Communicating with You

EUP will use the email address or phone number you provide to send you:

Essential messages to support the operation of the Service
Messages to support Migii's teaching methodology and reinforce your learning
Announcements regarding changes to the Service or products
Announcements of new Migii products, services, or offers

You may opt out of receiving non-essential messages in your settings.

c. Complying with Law and Preventing Harmful Activities

EUP may process and share personal information if necessary to comply with legal requests, such as subpoenas or court orders. EUP may share personal information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud, or to assist law enforcement.

d. Personalized Advertising

EUP may process and share your personal information for the purpose of providing you with personalized advertising. We work with third-party advertising service providers such as Google. You can opt out of receiving personalized advertising in your settings.

e. Anonymous Information

EUP may process aggregated, de-identified, or otherwise anonymous information for any purpose. Such information is not considered personal information.

4. Your Data Subject Rights

You have the following rights in relation to the personal information we hold about you:

Know what personal information we have collected about you
Access a copy of the personal information that we hold about you
Know what personal information about you we have shared with third parties
Request information about whether we sell your personal information (We do not sell your personal information for monetary gain)
Opt out of the sharing of your personal information with third parties
Object to our processing of your personal information
Not be discriminated against for exercising your data subject rights
Request that we delete any personal information we have collected from you
Request that we correct any inaccurate personal information about you
Export the personal information you have provided to EUP in a format that can be transferred electronically to a third party
Withdraw any consent you previously gave us to process your personal information
Delete your Migii account by following the instructions in the Service
Lodge a complaint with a supervisory authority if you believe your personal data has been processed in violation of applicable data protection laws

You may update or correct your information, and exercise certain opt-out rights, in your settings page. To make another privacy-related request, please send an email to [email protected].

5. Data Retention

EUP will generally retain your personal information until your account is deleted. However, EUP may retain certain information longer if necessary to provide the Service, defend our legitimate interests, comply with legal requirements, or resolve disputes.

In accordance with applicable Vietnamese law, personal information submitted during transactions shall be retained for a minimum of 2 years from the date of the transaction. We may also retain anonymous data indefinitely.

6. Child Users

We know that children deserve extra privacy protection. We treat Child Users (meaning users under the age of 13 in the United States or another age of digital consent in their country) differently to ensure their parents are in control and we only collect the bare minimum information we need to make Migii work.

All Child Users receive the following special treatment when using Migii:

Educational content adjusted to be age-appropriate
Advertisements are non-personalized and set to family-safe content
Promotional emails are disabled
Child Users' speech data is not shared with EUP for product improvement purposes

Parents may contact us at [email protected] to request access to, changes to, or deletion of information about their child.

7. Do Not Track

The Service is not designed to respond to "do not track" signals sent by some browsers.

8. Links to Third-Party Websites

The Service may contain links to other websites. EUP is not responsible for the content or privacy practices of other websites. This Privacy Policy applies only to information collected by EUP.

9. Privacy Policy Updates

We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice on the Website for at least seven (7) days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy.

10. Data Transfer

EUP is based in Vietnam and processes data in Vietnam, which may not provide equivalent levels of data protection as your home jurisdiction. EUP may transfer the data of users outside Vietnam to Vietnam.

Decree No. 13/2023/ND-CP on Protection of Personal Data ("Decree 13")

EUP has responsibility for the processing of personal information it receives under the Decree 13 Principles and subsequently transfers to a third party acting as an agent on its behalf. EUP shall remain liable under the Decree 13 Principles if its agent processes such personal information in a manner inconsistent with the Decree 13 Principles.

The Ministry of Public Security of Vietnam has jurisdiction over EUP's compliance with the Decree 13 Principles. EUP may disclose personal information in response to lawful requests by Vietnamese authorities, including to meet national security or law enforcement requirements.

11. Supplemental Terms in Certain Jurisdictions

In some jurisdictions, the Service may be subject to supplemental privacy policies or local laws. For users in those jurisdictions, the applicable supplemental privacy policies and local laws will take precedence over this Privacy Policy to the extent they conflict.

12. Compliance with Regulations

California Consumer Privacy Act (CCPA)

California residents have rights including the right to request access, deletion, or correction of personal data, and the right to opt out of data sales or sharing, as well as other rights provided under the CCPA. For CCPA-specific inquiries, email us at [email protected].

Virginia Consumer Data Protection Act (VCDPA)

Virginia residents have the right to access, correct, delete, and obtain a copy of their personal data. To exercise these rights, contact us at [email protected].

General Data Protection Regulation (GDPR)

Users in the EU have rights under the GDPR, including access, correction, deletion, portability, and the right to restrict or object to data processing. Requests can be sent to [email protected].

Lei Geral de Proteção de Dados (LGPD)

Brazilian users have rights under the LGPD, including access, correction, deletion, and portability of their data. Requests can be sent to [email protected].

13. Contact Us

EUP TECHNOLOGY.,JSC is the data controller of your data for the purposes of the General Data Protection Regulation ("GDPR") and any relevant local legislation. EUP's headquarters are located within Vietnam at:

Room 802, 8th Floor, 315 Truong Chinh Building, Khuong Mai Ward, Thanh Xuan District, Hanoi, Vietnam

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact us at [email protected] or visit: https://migii.net

Data Protection Officer (DPO)

Email: [email protected]
Phone: (+84) 961.285.987