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 can 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 provider when you sign in or subscribe. We do not buy personal information or collect it from public sources.

On the Site

The Site has no forms and sets no analytics or advertising cookies. Our hosting provider processes the technical data that any web request carries, such as your IP address, to serve and protect the Site. If you email us, we hold your email address and your message so we can reply.

Account information

When you create an account we store your email address and, if you use Sign in with Apple or Sign in with Google, the account identifier that provider shares with us. Signing in is passwordless, and we do not store passwords. If you sign in by email, we send a one-time code and sign-in link to your address.

Learning data

We store your learning progress (such as lessons completed, points and streaks) and your App settings. This data is held on our servers so that your progress follows your account.

Your voice

Speaking practice uses speech recognition to score what you say. We do not store recordings of your voice. We do not use your voice to identify you and we do not collect biometric information.

Purchases

Subscriptions are purchased through the Apple App Store. Apple processes the payment and we do not receive your card details. We store your subscription status so the App knows what you have access to.

Usage analytics

We collect pseudonymous usage data, such as which features you use, to understand how the App is used and to improve it. This data is not shared with advertisers and is not used to track you across other apps or services. You can turn it off at any time under Profile → Settings → Share usage data. In the EU/EEA and the UK it is off by default.

Diagnostics

We collect reports about errors and crashes so we can fix them. These reports do not include personal content and are not used to track you. You can turn them off at any time under Profile → Settings → Share diagnostics. In the EU/EEA and the UK they are off by default.

Notifications

Practice reminders are optional. If you enable them, we store a device token so they can be delivered. You can turn them off in the App or in iOS Settings.

What we do not collect

• Advertising identifiers or advertising and tracking software.
• 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 sign you in, keep your progress and apply your subscription.
• To communicate with you: service messages such as sign-in codes and account notices.
• To improve the App: usage analytics and diagnostics, both of which you can switch off.
• To keep the service secure: to detect and prevent misuse and enforce our terms.
• 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, service messages and improving the App), consent (analytics and diagnostics in the EU/EEA and the UK, and notifications) and legal obligation. You can withdraw consent at any time using the controls in the App or by emailing us. Withdrawal does not affect processing that took place before it.

4. Direct marketing

We do not send marketing email. We do not add you to a marketing list when you create an account, and we do not send marketing for anyone else. If we send marketing email in future, it will be sent only with your consent, will identify Mooteach as the sender and will include an unsubscribe link, as required by the Spam Act 2003 (Cth) and APP 7. Sign-in codes and account notices are service messages, not marketing.

5. Who we disclose it to

We do not sell personal information, and we do not share it for cross-context behavioural advertising as defined in the CCPA. We disclose personal information only to service providers that process it on our behalf, under contracts that limit its use to providing their service to us and require protection equivalent to this policy. They fall into these categories:

• Hosting and infrastructure.
• Apple and Google, for sign-in, and Apple for payment, notifications and speech recognition. Each acts under its own privacy policy for those services.
• Subscription management.
• Email delivery.
• Error reporting, if you have diagnostics enabled.

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 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.
• Account deletion: you can delete your account in the App under Profile → Manage account → Delete account. If you sign back in within 30 days your account is restored. After 30 days your account and learning data are permanently deleted.
• Diagnostics: as long as needed to investigate and fix issues.
• Support email: as long as needed to resolve and record your query.

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

Data is encrypted in transit between the App, the Site and our servers, and access to personal information is restricted to those who need it. No system 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 scores your practice automatically. Those scores affect your progress in the App only. We also use automated checks to detect misuse of account features, which may restrict an account. If your account is restricted, contact us and a person will review the decision. We make no other automated decisions with a legal or similarly significant effect on you, and we do not profile you for advertising.

10. Your rights

Wherever you live, you can:

• Access and correct the personal information we hold about you (APPs 12 and 13). Most of it is visible in the App. For a full copy, email us.
• Delete your account in the App, or ask us to delete other information we hold, such as a support email.
• Switch off usage analytics and diagnostics in the App, and manage notifications in the App or in iOS Settings.

If you are in the EEA or the UK, you also have the rights 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 can complain to the Office of the Australian Information Commissioner. If you are in the EEA, you can complain to the supervisory authority where you live or work. In the UK, you can complain to the Information Commissioner's Office. In Thailand, you can 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.