Privacy Policy

1. Who we are and what this policy covers

Mooteach is operated by Mooteach Pty Ltd ("Mooteach", "we", "us"), a company registered in Australia. This policy covers the Mooteach app for iPhone (the "App") and this website, mooteach.com (the "Site"). It sets out what personal information we collect, how we collect and hold it, why we use it, who we disclose it to, and how you may access or correct it or make a complaint. Contact us at hello@mooteach.com.

"Personal information" has the meaning given in the Privacy Act 1988 (Cth). It has the same meaning here as "personal data" under the GDPR.

The laws we follow

We handle personal information in accordance with the Australian Privacy Principles (APPs) in Schedule 1 of the Privacy Act 1988 (Cth), as amended by the Privacy and Other Legislation Amendment Act 2024 (Cth). We apply the APPs whether or not the Privacy Act's small business exemption would otherwise apply to us. This document is our APP privacy policy for the purposes of APP 1.

Depending on where you live, the following laws also apply and we comply with them:

• Australia: the Spam Act 2003 (Cth) for marketing email, and the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.
• European Economic Area and United Kingdom: the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the UK GDPR and the Data Protection Act 2018 (UK).
• California: the California Consumer Privacy Act as amended by the California Privacy Rights Act (the "CCPA").
• Thailand: the Personal Data Protection Act B.E. 2562 (2019) (the "PDPA").

2. Information we collect and how we collect it

We collect personal information directly from you, from your device when you use the App, and from Apple, Google and our subscription management provider when you sign in or subscribe. We do not purchase personal information or collect it from publicly available sources.

On the Site

The Site does not set analytics or advertising cookies. Our hosting provider processes the technical information transmitted with each request to the Site, including your IP address, for the purposes of serving and securing the Site, and measures visits to the Site on our behalf, including the pages viewed, the referring page, the type of browser and device, the country of access and page load performance. That measurement does not use cookies or store information on your device and is not used to track you across other websites. Where you contact us by email, we hold your email address and your correspondence for the purpose of responding to you.

The waitlist

If you join the waitlist on the Site, we hold your email address, the time at which you joined, your browser type and a pseudonymised form of your IP address. We use your email address to confirm your registration and to notify you of the launch of the App, and the remaining information solely to detect and prevent automated or abusive registrations. Joining the waitlist is optional and is not required to use the App.

Account information

Where you create an account, we hold your email address and, where you sign in with Apple or Google, the account identifier and, where provided, the name that the provider discloses to us. We do not collect or store passwords.

Google user data

If you choose Sign in with Google, Google shares with us your name, your email address, whether Google has verified that address, and an identifier for your Google account. We ask only for these basic profile details. We do not request or receive your contacts, Gmail, Google Drive, calendar, photos or any other data held in your Google account.

We use this information only to create your Mooteach account, sign you in, recognise you when you sign in again, and link your sign-in to an existing account with the same verified email address. We do not sell Google user data, use it for advertising, use it to train artificial intelligence models, or share it with anyone except the service providers in section 5 that host and run Mooteach for us. Our use of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements.

We retain this information for so long as your account exists. Upon deletion of your account it is permanently deleted as described in section 7. You may also revoke Mooteach's access to your Google account at any time at myaccount.google.com/permissions.

Learning data

We hold your learning progress (including lessons completed, points and streaks), your App settings and your responses to the App's setup questions, in connection with your account.

Your voice

Where you use speaking exercises, your speech is processed by speech recognition for the purpose of evaluating your answer. We do not retain recordings of your voice, and we do not process your voice to identify you or collect biometric information.

Purchases

Subscriptions are purchased through the Apple App Store. Payment is processed by Apple, and we do not receive your payment card details. We hold your subscription status for the purpose of providing the features to which your subscription entitles you.

Usage analytics

We collect pseudonymous usage data, being information about your interactions with the App (including the screens viewed, the controls selected and the duration of each session of use) and the errors encountered in it, linked to your account and to an identifier assigned to your installation of the App. We use usage data to operate, maintain and improve the App and to diagnose faults. Usage data is not disclosed to advertisers and is not used to track you across apps or services owned by third parties. You may withdraw from its collection at any time by means of the Share usage data setting under Settings → Manage privacy. In the EU/EEA and the United Kingdom that setting is disabled by default.

Diagnostics

We collect reports of errors and crashes generated by the App and by our servers, for the purpose of identifying and correcting faults. Reports generated by the App include the identifier assigned to your installation of the App and information about your use of the App immediately preceding the error. Reports do not include your name or email address and are not used to track you across apps or services owned by third parties. You may withdraw from the App's reports at any time by means of the Share diagnostics setting under Settings → Manage privacy. In the EU/EEA and the United Kingdom that setting is disabled by default.

Problem reports

Where you elect to submit a report by means of the App's Report a problem feature, we receive, linked to your account, the category of problem and any description you provide, information about the App, its content, your device and your App settings, the screen from which the report was made and, where the report concerns an exercise, information identifying that exercise together with the text transcribed from your spoken answer. A problem report does not include a recording of your voice. We use problem reports solely to investigate and correct the problem reported. The Share diagnostics setting does not apply to problem reports.

Advertising

Where you use the App without a Mooteach Plus subscription, the App displays advertisements served by Google through its AdMob service. For the purposes of serving, measuring and limiting the frequency of those advertisements and detecting fraud, Google may collect device data, your approximate location as derived from your IP address, information about the advertisements displayed and your interactions with them and, only where you permit tracking by means of Apple's App Tracking Transparency prompt, your device's advertising identifier. Where you do not permit tracking, the advertisements displayed to you are not personalised. Where the GDPR or the UK GDPR applies, advertisements are displayed only in accordance with the choices you make in the consent message presented before the first advertisement, which you may review or change at any time under Settings → Manage privacy → Ad privacy choices. Where you elect to view an advertisement in exchange for an in-App reward, we disclose a pseudonymous identifier to Google for the sole purpose of verifying that reward. Advertisements are not displayed to Mooteach Plus subscribers.

Notifications

Practice reminders are optional. Where you enable them, we hold an identifier issued for your device for the purpose of delivering them. You may disable reminders at any time in the App or in iOS Settings.

Activity data and IP address

When you use the App or the Site, we generate information about that use, which may include device data, log data and your IP address, for the purposes of providing and securing the Service and diagnosing faults. We retain IP addresses for no more than thirty days unless exceptional circumstances require longer retention.

What we do not collect

• Precise location.
• Contacts, photos or other device content.
• Government identifiers.
• Sensitive information as defined in the Privacy Act, or special category data under the GDPR.

3. How we use your information

• To provide Mooteach: to provide the App, maintain your account and learning progress and give effect to your subscription.
• To communicate with you: to send service messages, including sign-in codes and account notices, and, where you joined the waitlist, a confirmation of your registration and notice of the App's launch.
• To improve the App and the Site: to analyse use of the App and the Site and to diagnose and correct faults, including by means of usage analytics, diagnostics, problem reports you elect to submit and visit measurement on the Site.
• To show advertising: to display advertisements to users of the App who do not hold a Mooteach Plus subscription, as described in section 2.
• To keep the service secure: to detect and prevent misuse of the Service and to enforce our Terms of Service.
• To meet our legal obligations.

We use personal information only for the purpose we collected it for, or a related purpose you would reasonably expect (APP 6). We will not use it for any other purpose without your consent unless the law requires or permits it.

Where the GDPR or the UK GDPR applies, our legal bases are: performance of a contract (providing the App), legitimate interests (security, including preventing abusive waitlist signups, service messages, investigating problem reports and improving the App and the Site), consent (waitlist email, analytics and diagnostics in the EU/EEA and the UK, advertising, and notifications) and legal obligation. You may withdraw consent at any time by means of the settings in the App, the unsubscribe link in any waitlist email, or by emailing us. Withdrawal does not affect processing that took place before it.

4. Direct marketing

We send marketing email only to people who have asked for it by joining the waitlist. Waitlist members receive a confirmation when they join and news of the App's launch. We do not add you to a marketing list when you create an account, we do not send marketing for anyone else, and we do not give or sell your address to anyone else for their marketing.

As the Spam Act 2003 (Cth) and APP 7 require, every marketing email identifies Mooteach Pty Ltd as the sender, says how to contact us and includes an unsubscribe link. Upon your unsubscribing, your email address is removed from the waitlist within five business days. You may also unsubscribe by emailing hello@mooteach.com. Sign-in codes and account notices are service messages, not marketing.

5. Who we disclose it to

We do not sell personal information. Where you permit tracking through Apple's App Tracking Transparency prompt, the advertising described in section 2 may constitute sharing for cross-context behavioural advertising as defined in the CCPA; you may opt out of such sharing at any time by disabling tracking for the App in iOS Settings. Save as aforesaid, we disclose personal information only to the service providers below, which process it on our behalf under contracts that limit its use to providing their service to us and require protection equivalent to this policy:

• Cloudflare, for hosting, data storage, content delivery and email.
• RevenueCat, for subscription management.
• Sentry, for error reporting.
• Google, for advertising in the App (AdMob), acting under its own privacy policy where it uses data to personalise advertisements.
• Apple and Google, for sign-in, and Apple for payment, notifications and speech recognition. Each acts under its own privacy policy for those services.

We may also disclose personal information where the law requires it, to protect the rights or safety of Mooteach or others, or as part of a business transfer such as a merger or sale, in which case this policy continues to apply.

6. Overseas disclosure

Mooteach is based in Australia. Our service providers operate globally, so your personal information is likely to be disclosed to and stored in the United States, countries in the Asia-Pacific region and other countries in which they operate. This is the disclosure required by APP 8.

Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it consistently with the APPs. For transfers out of the EEA and the UK we rely on the European Commission's standard contractual clauses and the UK International Data Transfer Addendum.

7. How long we keep it

• Account and learning data: while your account exists.
• IP addresses: no more than thirty days.
• Usage analytics: no more than 13 months.
• Account deletion: where you delete your account under Settings → Manage account → Delete account, it may be restored by signing in again within 30 days, after which your account and learning data are permanently deleted.
• Waitlist: until you unsubscribe or ask us to delete your address, and no longer than 12 months after the App launches.
• Diagnostics and problem reports: for so long as is necessary to investigate and correct the faults to which they relate.
• Support email: for so long as is necessary to resolve and record your enquiry.

When personal information is no longer needed for a purpose in this policy and the law does not require us to keep it, we destroy or de-identify it, as APP 11 requires.

8. Security and data breaches

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. No method of transmission or storage is completely secure.

If a data breach occurs that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme, and any other regulator that applicable law requires, within the time those laws set.

9. Automated decisions

The App evaluates your answers in practice exercises by automated means, and those evaluations affect only your progress within the App. We also use automated means to detect misuse of account features, which may result in the restriction of an account. Where your account is restricted, you may request, by contacting us, that the decision be reviewed by a person. We make no other decision based solely on automated processing that produces a legal or similarly significant effect concerning you, and we do not profile you for advertising.

10. Your rights

Wherever you reside, you may:

• Access and correct the personal information we hold about you (APPs 12 and 13), including by requesting a copy by email.
• Delete your account in the App, leave the waitlist with the unsubscribe link in any waitlist email, or ask us to delete other information we hold, such as a support email.
• Withdraw from usage analytics and diagnostics, and manage notifications, by means of the settings in the App or in iOS Settings.

If you are in the EEA or the UK, you also have the right to restrict or object to processing, to data portability, to withdraw consent and to lodge a complaint with a supervisory authority. If you are a California resident, you have the rights to know, to delete, to correct and to non-discrimination for exercising those rights; we do not sell or share personal information. If you are in Thailand, you have the equivalent rights under the PDPA.

To exercise a right, email hello@mooteach.com from the address on your account, or tell us how to verify your identity. We respond within 30 days. We do not charge for requests unless the law permits it and the request is clearly excessive. If we refuse a request we will tell you why and how to complain. You may use an authorised agent; we will ask for proof of authority.

11. Complaints

If you believe we have mishandled your personal information or breached the APPs, email hello@mooteach.com with "Privacy complaint" in the subject. We will acknowledge your complaint, investigate it and respond in writing within 30 days. If we need longer we will tell you why.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner. If you are in the EEA, you may complain to the supervisory authority where you reside or work. In the UK, you may complain to the Information Commissioner's Office. In Thailand, you may complain to the Personal Data Protection Committee.

12. Children

Mooteach is not directed at children under 13, or the higher minimum age that applies in your country, and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, contact us and we will delete it.

13. Changes to this policy

When we change this policy we update the date at the top of this page. For material changes we notify you in the App or by email before they take effect. Earlier versions are available on request.

14. Contact

hello@mooteach.com. Mooteach Pty Ltd is the controller of personal information collected through the App and the Site.