Privacy Policy

Effective Date: November 1, 2025
Last Updated: November 1, 2025

1. Introduction

Diicho (“we”, “us”, and/or “our”) operates the Diicho AI-powered language learning application (the “App”) and related services (collectively, the “Services”). We are committed to protecting and respecting your privacy. This Privacy Policy applies to and describes how we collect, store, use, and share personal data and other information about you or provided by you through our Services. References to “you” mean the person whose personal data we collect, use, and process. We will manage your personal data only as described below and in accordance with applicable laws. By using the Services, you acknowledge that you have read and understand this Privacy Policy.

We care about the protection and confidentiality of your information. When you use the App and our Services, you may provide personal data and content as part of your learning activities. We process this information only as described in this Privacy Policy—for example, to enable you to import materials, generate AI-based learning content, and improve your overall experience with the App. We may also use limited information about your use of the Services to help maintain, improve, and promote them, but we will never use or disclose your educational content, learning materials, or user-generated content for marketing or advertising purposes.

Any terms used in this Privacy Policy without definition have the meanings given to them in our Terms of Service. If you have any questions, please contact us at [email protected].

2. Information We Collect

We automatically log the following information about you, your computer or mobile device, your network, and your interactions over time with our Services and our communications:

Device and network data. We collect certain login information stored on your device such as your computer’s or mobile device’s operating system, manufacturer and model, browser, IP address, device and cookie identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area. We also collect information from crash reports and system error logs.

Usage data. We collect information about how you use the Services, such as your interactions with the Services, the links and buttons you click, and page visits. We use cookies, web beacons (e.g., pixel tags), and local storage technologies (e.g., HTML5) to collect some of this information. Additional information from Google Analytics or other analytics vendors, like website visitor or app user behavior and demographics, analytics information, log files cookies, pixel tags, web beacons, and other usage information, like the time of day or how often you use each tool, will also be collected.

For users on our free tier, we display advertisements through third-party advertising partners. These advertising partners may use technologies such as cookies and pixel tags to collect limited information about your device and interactions with the Services, such as the links you click, pages you visit, IP address, advertising ID, and browser type. Under various U.S. state privacy laws (including California, Virginia, Colorado, Connecticut, and Utah), IP addresses and advertising IDs may constitute “personal information” or “personal data.” We do not share any of your user-generated content or learning materials with advertising partners. We do not pass any user data to advertising partners to personalize advertisements. You may have the right to opt out of the sharing of personal information for targeted advertising purposes as described in Section 11 below.

3. Information You Voluntarily Provide

Through your use of the Services, you may provide us with the following information:

Account information. This includes your name, email address, and password. If you create an account directly with us using an email and password, your password is encrypted and securely hashed in our database using industry-standard cryptographic methods. If you choose to log in using a third-party authentication service (such as Google, Apple, or Facebook), we receive and store your name and email address from these services. We do not receive or store passwords from third-party authentication services. Depending on your privacy settings with the third-party service, we may also receive your profile picture and unique user identifiers necessary for authentication. When you authenticate through third-party services, your use of those services is subject to their respective privacy policies and terms of service.

Profile information. We ask you to provide your birth date (to verify you are 16 or older), pronouns (optional), and work status (optional) when you register for the App.

Language preferences. You may provide us with your language preferences, such as the languages you wish to study and your preferred level of difficulty. You may also select learning preferences and the pace at which you want to progress. Over time, we learn about your interests and preferences through your use of the App and use this information to personalize your lessons, recommendations, and overall experience with the Services.

User-Imported Content. You may import web content or link YouTube videos for learning purposes. We use this content only to process it in real time and do not store, share, or redistribute it. We temporarily access this content through lawful GET requests and/or APIs and do not interfere with ads or monetization.

Support and feedback. When you contact us with support requests or provide feedback, we collect the information you share with us in order to respond to your inquiries and improve the Services.

4. How We Use Your Information

We solely utilize your personal information for the intended purposes for which it was gathered. If an alternative use aligns with the original purpose, we may consider it. Depending on the specific purpose, we might employ multiple legal grounds to process your data. In cases mandated or allowed by the law, we may process your personal data even without your explicit knowledge or consent.

Managing Our Services

Ensuring the content and functionality of the Services are provided and updated. Fulfilling contractual obligations resulting from our agreement with you. Setting up your account and profile. Assisting with payments, transactions, premium feature purchases, and reward management. Addressing your inquiries, comments, feedback, or questions, and resolving issues. Maintaining our relationship with you by sending relevant administrative information about our Services.

Training, Internal Review and Development

Collecting, anonymizing, and deidentifying personal information. Evaluating the usage and effectiveness of our Services. Enhancing and incorporating features into our Services. Formulating our business and marketing strategies. Improving product and service quality, as well as customer experience. Anonymizing reports, research, and analytics data. We may use aggregated, anonymized, and de-identified information to train and improve our AI models, but we will never use your personal data, user-generated content, learning materials, or imported content for AI training purposes unless you provide explicit opt-in consent as described in Section 5.

User Communication

Emailing you information that we think might interest you, such as details about our Services, features, and surveys. Sharing important updates and offering system support. Displaying advertisements about our Services on the internet.

Protection and Enforcement

Upholding and adhering to our terms and policies. Safeguarding our rights, as well as others' rights, privacy, safety, and property. Preserving the integrity of our Services. Verifying the age of registered users. Defending against legal claims and disputes. Retrieving payments owed to us. Maintaining records of transactions and complying with legal processes.

Compliance

Compliance with applicable laws and regulations and our commitments and obligations with applicable third parties we work with.

The Services empower you to input information that could be sensitive and may require special protections under applicable laws. This section delineates how we handle and safeguard such sensitive information.

This sensitive information encompasses details you share in your messages, learning materials, and content. In the course of your interactions with the Services, you might choose to disclose information pertaining to your religious beliefs, sexual orientation, political affiliations, health status, racial or ethnic background, philosophical convictions, or membership in trade unions. By providing this sensitive information, you explicitly consent to our processing of it solely for the purposes of providing and improving the Services as outlined in this Privacy Policy. We will never utilize your sensitive information, or any content from your learning materials or user-generated content, for marketing or advertising purposes. You may withdraw your consent at any time by deleting such content or closing your account as described in Section 11.

We do not sell your personal data.

5. AI and Data Usage

Our AI models may use imported third-party content strictly for ephemeral, personal-use processing (e.g., creating AI-generated audio content for language learning). No data is retained beyond the temporary processing period necessary to provide the requested service, and no imported content, user-generated content, or learning materials are used for AI model training unless you provide explicit, affirmative opt-in consent through a separate, clear mechanism within the App. You may withdraw such consent at any time.

We comply with applicable copyright law, including the Digital Millennium Copyright Act (DMCA), and only access third-party content through lawful means (e.g., through authorized APIs or standard HTTP requests). Imported content is processed temporarily solely for your personal use and is not stored beyond the time necessary to provide the requested service (typically no more than 24 hours). Imported content is not redistributed, made available to other users, or used for any purpose other than providing the Services to you. We do not circumvent any technological protection measures or access controls on third-party content.

6. Data Sharing and Third Parties

We only share your information when we determine it is necessary to provide the Services, protect our legitimate business interests, comply with legal obligations, or as otherwise described in this Privacy Policy.

Service Providers. We disclose your information to companies and individuals who assist us in providing services, operating the Services, or managing our business. These entities include service providers for functions such as hosting, information technology, customer support, email delivery, website analytics, and third-party advertising partners for our free tier. We require all service providers to maintain appropriate security measures and to process personal information only as instructed by us and in compliance with this Privacy Policy and applicable law. Additionally, we collaborate with marketing service providers to promote our Services, although we do not share the content of your learning materials or other user-generated content for marketing or advertising purposes. For instance, we might provide your email address to marketing service providers to send marketing emails on our behalf and to help us identify potential users interested in our Services. We ensure that these marketing service providers are contractually bound to use your email address solely for sending communications on our behalf and are prohibited from using it for any other purpose. Our Services may link to third parties, like helplines or other resources. Any information shared with or otherwise collected by third parties is subject to the third party’s terms and privacy policy. We are not responsible for the processing of personal data by third parties relevant to these resources.

Advisors and Partners. We may share information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us. We may also partner with organizations to conduct research studies, conduct collaborations or provide you with the Services through separate programs. Program partners may include employers, hospitals, providers, or other medical and academic partners. Clinical partner programs are a specific type of partner program that include a licensed healthcare provider. Providing your information to these partner programs may be necessary to effectuate the implementation of these programs and may be governed by additional terms outside this privacy policy. Sensitive information, such as your conversational interactions, like what you write or your path through a conversation, will not be shared unless you give us your consent to do so or if it becomes necessary. We may also share identifiable data about how you’re doing such as survey responses, mood trends, or your confirmation that our AI program has understood a concerning entry that’s beyond what it can support, if it is necessary for reporting or facilitating the programs. Please note that any personal data shared with a partner program is also subject to the partner program’s terms and privacy policy. We are not responsible for the processing of personal data by partner programs. We might utilize your personal data to generate de-identified and/or aggregated data, including approximate location details, information about your device used to access our Services, conversational patterns, and other analyses we conduct. De-identified and/or aggregated data lacks personal identifiers and falls outside the realm of personal data. As permitted by applicable law, we can utilize and share this data, including but not limited to with academic, medical, clinical, program, government, and non-profit partners.

Authorities. We may share information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the legal compliance and protection purposes.

Business transferees. We might disclose information to buyers and other pertinent parties in business dealings, which could include corporate divestitures, mergers, consolidations, acquisitions, reorganizations, sales, or other transactions involving all or a part of the business, assets, or equity interests. This also applies to scenarios related to bankruptcy or similar proceedings.

Disclosures for Protections. We have the right to access, preserve, and share any personal data linked to you with external parties if we genuinely believe it is necessary to abide by law enforcement or national security requests and legal procedures, including court orders or subpoenas; safeguard your, our, or others' rights, property, or safety; enforce our policies or agreements; or in the investigation or prosecution of suspected or confirmed illegal activities.

We do not share user-imported content with third parties or train our AI models on it, unless you have given specific consent.

7. Children’s Privacy

Our Services are not designed for individuals under the age of 16, and we do not knowingly collect personal data from children under 16. If you discover that your child has shared personal data with us without your consent, please get in touch with us. Should we find that we have inadvertently collected personal data from an individual under 16 in violation of applicable law, we will promptly restrict their access, delete the personal data (unless legal obligations require retention), and close the account.

The Children's Online Privacy Protection Act ("COPPA") requires that online service providers obtain verifiable parental consent before knowingly collecting personally identifiable information online from children under the age of 13. While COPPA applies to children under 13, our Services have established a minimum age requirement of 16. We do not knowingly gather or request personally identifiable information from individuals under 16. If you are under 16, please refrain from attempting to register for the Services or sharing any personal details with us. Should we discover that we have unintentionally collected personal information from an individual under 16, we will promptly delete the information and close the associated account. If you suspect that an individual under 16 may have provided us with personal information, kindly get in touch with us.

8. Data Retention

Our Services are based in the United States of America. If you are situated in a different jurisdiction, please note that the information you share with us might be transferred, stored, and processed in the USA. This jurisdiction may not have privacy laws as comprehensive as those in your residing country or your citizenship country.

We will keep your personal information only for the duration necessary to fulfill the purposes for which it was collected, including meeting legal, accounting, or reporting obligations. We store personal data to personalize your experience with our Services, drawing on your past interactions and for the reasons mentioned earlier. We maintain the collected personal data for the duration of your use of our Services or as long as required to fulfill the purposes for which it was gathered. This includes providing our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business objectives, enforcing agreements, and adhering to relevant laws.

In determining the suitable retention period, we assess the quantity, type, and sensitivity of the personal information, the potential risk of unauthorized use or disclosure, the purposes for processing the information, whether those objectives can be achieved through alternative methods, and the relevant legal obligations.

9. Security

We employ various industry-standard security technologies and protocols to safeguard your data from unauthorized access, usage, or disclosure.

Your account is secured by a password to ensure your privacy and safety. It's essential to prevent unauthorized access by carefully choosing and safeguarding your password. Limit access to your computer or device and browser by logging out after using your account.

During transmission, all data are encrypted using industry-standard Transport Layer Security (TLS) protocols. Stored data are kept on secure servers and protected using multiple security measures, including firewalls, row-level security, role-based access controls, encryption at rest (with industry-standard encryption methods applied to sensitive data such as passwords), firewalls, row-level security, role-based access controls, and strong authentication mechanisms.

We make commercially reasonable efforts to implement security measures, including firewalls, row-level security, and industry-standard encryption methods on sensitive data such as passwords, aimed at preventing accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data. Despite our efforts, it's important to note that no technology or system can guarantee 100% security. In the event of a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to your data, we will promptly notify you once the issue is detected. As a result, we cannot ensure or warrant the security of any personal data you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal data.

10. Advertising and Your Choices

The free tier of our Services includes advertisements provided by third-party advertising partners. We do not sell, share, or otherwise provide your personal information, user-generated content, or learning materials to these advertising partners for the purpose of personalizing advertisements. Advertisements displayed to you are not based on your personal data or activity within the App.

If you prefer an ad-free experience, you may upgrade to a premium subscription tier.

11. Your Rights

Opt-out of marketing communications. You have the choice to stop receiving marketing-related emails and other communications by following the unsubscribe instructions in the messages you receive or by reaching out to us using the contact information provided in the "Contact Us" section below. Please note that you will still receive emails related to our Services and other non-marketing communications from us.

Sensitive Information. If you decide to share sensitive personal information within your messages and content, we will utilize this data solely to enhance your conversation with your AI companion, following the guidelines outlined in the "Sensitive Information" section above. If you prefer that we do not process your sensitive information for these purposes, kindly refrain from providing it. Should you wish to have information you've shared deleted, please refer to the "Information Requests" section below for instructions.

Information Requests. We provide you with various choices regarding the handling of your personal information under our control. Depending on your location and your interactions with our Services, you can request the following in relation to personal information:

1. Information: You can ask for details on how we collected and used your personal information, which we've already made available in this Privacy Policy. You can also ask to receive a paper copy of this privacy policy.

2. Access: If applicable, you can obtain a copy of the personal information we've collected about you in a portable, machine-readable format.

3. Correction: If your personal information is inaccurate or outdated, you have the right to request corrections.

4. Deletion: You can request the deletion of personal information that we no longer need for providing the Services or for other lawful purposes. You can also delete your account through your account settings.

5. Withdrawal of Consent: Where we rely on consent as the legal basis for processing your personal information, you have the right to withdraw that consent at any time. Any withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

To make a request, please contact us using the information provided in the "Contact Us" section below. We will require reasonable information to verify your identity before processing your request. Where permitted by applicable law, you may designate an authorized agent to make requests on your behalf. We will require authorized agents to provide proof of their authorization and may require you to verify your identity directly with us and confirm that you have provided the authorized agent permission to submit the request. You can exercise these rights without facing discrimination.

We may limit or deny requests in certain situations as permitted by applicable law, including when: For instance, fulfilling your request might impede others’ rights, our ability to provide a requested service, or our ability to comply with legal obligations and enforce our legal rights. If you are dissatisfied with our response to your request, you can file a complaint through the contact details in the “Contact Us” section below. Where applicable under local law, you may have the right to complain to your local data protection authority if you believe we have not appropriately handled your personal data.

12. Changes to This Privacy Policy

We may update this Privacy Policy at any time, and if there are material changes, we will notify you as required by law. Considering the evolving nature of our Services and business, periodic adjustments to this Privacy Policy may be necessary. We retain the right to update or amend this Privacy Policy and will provide notice of material changes as required by applicable law. We encourage you to visit this page periodically to stay informed about our privacy practices. This Privacy Policy was last updated on September 30, 2025.

By continuing to use our Services after the new policy becomes effective, you acknowledge your acceptance of the updated privacy policy. We recommend that you regularly review the contents of this privacy policy to stay informed about any changes.

13. Contact Us

If you have questions, please contact us at:

• Email: [email protected]

• Mailing Address: 2900 E. Broadway Blvd #1001020, Tucson, AZ, 85716