1. General
This Privacy Policy (“Policy”) explains how CurioSea Pte. Ltd., doing business as "Catchi" ("we," "us," "our," or the "Company") collects, uses, discloses, retains, and protects personal information when you use our mobile application, and related services (collectively, the "Service"). The Service provides an AI-powered English language learning experience featuring leveled video episodes, interactive quizzes, and virtual rewards.
This Policy applies to personal information we process in connection with the Services. It does not apply to a third-party website, application, payment service, identity provider, or integration that operates under its own privacy policy, even if you access or connect it through the Services. By using any of the Services, you agree to the collection, use and disclosure of your information as described in this Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue the use of our Services immediately. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
2. Information We Collect
When you use the Service, we may collect the following categories of personal information.
a. Information You May Provide or Create
When you create an account and use the Service, you may provide:
- Age (required): We collect your age to verify that you meet the minimum age requirement for the Service. Users under the age of 13 are not permitted to use the Service.
- Gender (optional): You may provide your gender, which may be used in the future to personalize content recommendations. Gender is not currently used for recommendations.
- Nickname (optional): You may provide a nickname, which is displayed on your profile and used to address you within the Service.
b. Information We Collect
Account Registration
To create an account, you may register by providing:
- Your email address and verification code; or
- Your Google/Apple account credentials via Google/Apple single sign-on.
If you register using Google/Apple, we may receive from Google/Apple your name, nick name, email address, profile picture, account identifier and authentication tokens as permitted by your Google/Apple privacy settings.
Learning Activity Data
The Service delivers AI-generated video episodes tailored to your assessed proficiency level. When you use the Service, we collect:
- Selected language and learning track: The language you choose to learn and your learning track;
- Course nodes and episode/question numbers: The specific learning nodes, episodes, and questions you access; and
- Viewing and answering position data: Your partial playback positions and answer positions within episodes and exercises.
Voice and Speak Data
The Service includes speaking practice features. When you use these features, we collect:
- Your audio recordings;
- The reference text associated with each speaking exercise;
- Speech recognition results and word-level results; and
- Pronunciation scores, including metrics for accuracy, fluency, completeness, and prosody.
Voice data is collected only after you grant microphone permission and actively submit a recording.
Device Identifiers and Network Information
When you use the Service, we automatically collect:
- Device identifiers: App-generated device identifier, installation identifier, and Apple's Identifier for Vendors (IDFV), used for device registration, request validation, security protection, analytics, and fault correlation.
- Device and network information: Device model, operating system version, app version, release channel, interface language, source IP address, and request time, used for compatibility, service delivery, security, and fault diagnosis.
Usage and Analytics Data
We automatically collect information about how you use the Service for product analysis, feature configuration, and experiment evaluation, including:
- Pages and screens visited;
- Feature flags and configuration settings; and
- Experiment group assignments.
Error and Diagnostic Data
To diagnose faults and monitor stability and performance, we collect error and diagnostic information, including:
- Crash reports;
- Error types; and
- API/interface status information.
Media Access Information
When you load and play learning content, we collect the following data for learning content delivery :
- The addresses of requested images, audio, or video content;
- Source IP address; and
- Request time.
Cookies and Similar Technologies
We use cookies, pixels, and similar tracking technologies on our website and within the Service to:
- Authenticate users and maintain session state;
- Remember your preferences and settings; and
- Analyze usage and performance of the Service.
Communications and Support
If you contact us for customer support, we may collect your name, email address, and any information you include in your communication. We retain records of our correspondence with you.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- Verify user age and enforce the minimum age requirement for using the Service;
- Create and maintain your account;
- Generate and deliver AI-powered episodes and quizzes;
- Present in-episode pop-up quizzes and post-episode exercises; grade responses and determine pass/fail status;
- Provide speech recognition and pronunciation assessment;
- Personalize your learning experience and adapt difficulty;
- Register devices, validate requests, and protect security;
- Send administrative communications (e.g., account changes);
- Provide customer support;
- Analyze usage, manage feature configuration, and evaluate experiments;
- Diagnose faults and monitor stability and performance;
- Deliver and play learning media content;
- Detect, prevent, and address fraud, security incidents, and violations of our Terms of Service;
- Comply with applicable laws and regulations; respond to legal process; and
- De-identify or aggregate information for research, analytics, and product improvement.
We only process your personal data when we have a valid legal basis to do so, based upon different scenarios, where one or more following legal basis applies: (a) Necessity of Contract Performance: necessary to provide the Services you request, including recording, transcription, summarization, account management, and device functionality; (b) Your Consent: Certain optional features are enabled only with your explicit consent, which you may withdraw at any time through the App settings or other channels as provided in the Policy; (c) Legitimate Interests: Necessary to improve the quality, security, and functionality of the Services, provided that such interests are not overridden by your rights and interests; and (d) Legal Obligations: Processing is necessary to comply with applicable laws and lawful requests from authorities.
4. How We Share Your Information
We do not sell your personal information for monetary consideration. We may share your personal information as follows:
a. Service Providers
We engage trusted third-party vendors to perform functions on our behalf, including:
- Cloud hosting and data storage providers (e.g., Amazon Web Services, Google Cloud Platform and AWS Cognito);
- AI content generation and natural language processing providers — to generate leveled episodes, quizzes, and exercises. Our agreements with AI vendors prohibit them from using your personal information for their own purposes, including training their AI models on your data;
- Product analytics and feature-flagging providers (e.g., PostHog) to understand how users interact with the Service, manage feature configuration, and evaluate experiments;
- Error and stability monitoring providers (e.g., Sentry) — to receive crash reports, error types, and diagnostic information for troubleshooting;
- Content delivery network (CDN) and media service providers — to deliver and play images, audio, and video learning content;
- Authentication providers (e.g., Google and Apple) — to facilitate single sign-on registration and login.
These service providers are contractually bound to process your personal information only on our instructions and for the purposes we specify, and to implement appropriate security measures.
b. Corporate Transactions
We may disclose or transfer personal information in connection with the evaluation, negotiation, financing, or completion of a proposed or actual merger, acquisition, reorganization, bankruptcy, sale of all or part of our business or assets, or similar corporate transactions. This may include disclosure to potential buyers, investors, lenders, professional advisers, and other transaction participants, subject to appropriate confidentiality and security safeguards.
Any successor’s handling of personal information collected under this Privacy Policy will remain subject to applicable law and the privacy commitments made when the information was collected. If the successor intends to use or disclose previously collected personal information in a materially different manner, it will provide prior notice and obtain consent or provide applicable privacy choices where required by law.
c. Legal Obligations and Safety
We may disclose your personal information if we believe in good faith that such disclosure is necessary to:
- Comply with applicable laws, regulations, legal process, or governmental requests;
- Enforce our Terms of Service, including investigation of potential violations;
- Detect, prevent, or address fraud, security, or technical issues; or
- Protect the rights, property, or safety of the Company, our users, or the public.
d. With Your Consent
We may share your personal information for other purposes with your explicit consent.
e. Aggregated and De-Identified Information
We may share aggregated, de-identified, or anonymized information that cannot reasonably identify you for any purpose, including research, analytics, and improving our Services.
5. Your Rights and Choices
Depending on your state of residence, you may have certain rights regarding your personal information. This section describes those rights and how to exercise them.
Regardless of whether a particular state privacy law applies to the Company, we currently accept reasonable requests to access, export, correct, or delete your personal information, subject to verification, technical feasibility, the rights of others, and legal exceptions. Where an applicable U.S. state privacy law applies, you may also have additional rights, including to confirm processing, obtain a portable copy, withdraw consent for certain sensitive processing, appeal a privacy-request decision, and receive equal service without unlawful discrimination. Please see Section 13 for additional U.S. state disclosures.
Submit a request through an available in-product control or by emailing feedback@catchi.ai. We may verify identity and authority, including an authorized agent.
We do not offer a financial incentive or a price or service difference in exchange for the collection, sale, or sharing of personal information.
a. Cookies and Similar Technologies
Cookies are small text files or similar records placed on a browser or device. Catchi websites may use cookies, and Catchi applications and devices may use local storage, device identifiers, software-development kits, and similar technologies, to operate and understand the Services.
We may use strictly necessary technologies for sign-in, authentication, security, network management, payment, and core functions of the Services; functional technologies to remember settings and preferences; and analytics or performance technologies to understand feature use, diagnose errors, and improve reliability. Third parties providing these functions may process limited information on our behalf, subject to applicable contractual and use restrictions.
Most browsers and devices allow you to control or delete cookies, local storage, permissions, and similar technologies. Disabling strictly necessary technologies may prevent parts of the Services from working. Where applicable law requires consent for a non-essential technology, we will request that consent before using it.
Catchi does not sell personal information as “sell” is defined under applicable U.S. state privacy laws. Catchi does not share personal information for cross-context behavioral advertising. Analytics or attribution technologies, if used, are not used to build profiles or deliver cross-context behavioral advertising. We do not disclose personal information to third parties for their own direct marketing.
Because there is no uniform industry standard for browser “Do Not Track” signals, the Services do not currently respond to them. Global Privacy Control (“GPC”) can communicate an opt-out request, but Catchi does not currently sell personal information or share it for cross-context behavioral advertising, so there is no such processing to opt out of. If our practices change, we will provide legally required choices and honor GPC where required. You can also use browser, device, and product controls to limit cookies, permissions, local storage, and similar technologies, although disabling strictly necessary technologies may affect the Services.
6. Children's Privacy
The Services are not intended for children under 13. Users under the age of 13 are not permitted to use the Service and we do not knowingly collect their personal information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)). If you do not meet the legal age requirement for adults in your jurisdiction, please do not use our services. If we discover that an individual under 13 has provided it with personal information, we will delete the personal information to the extent required by COPPA. If you believe a child under 13 has provided personal information without such consent, contact feedback@catchi.ai. Users below the age of majority may use the Services only with parental or guardian involvement where required by applicable law.
7. Data Retention and Deletion
Your personal information is stored in the United States. We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, taking into account the nature and sensitivity of the information, the feature and settings you use, security needs, our relationship with you, and applicable legal, tax, accounting, and dispute-resolution requirements.
Most of your information is associated with your account and is kept for as long as your account remains active. When you request deletion of certain data or your account, we will take steps to delete or anonymize information in accordance with applicable laws:
- Your personal information is removed or anonymized from our active systems within 30 minutes;
- Certain information may be retained for longer periods as necessary to: comply with legal obligations, resolve disputes, enforce our agreements, detect and prevent fraud, or protect the security and integrity of the Service; and
- De-identified, aggregated, or anonymized information may be retained indefinitely.
IP addresses are retained for no more than 30 minutes, except where longer retention is necessary for security investigations or fraud prevention.
8. Data Security
We implement and maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information. These measures include:
- Encryption of data in transit (TLS/HTTPS) and at rest;
- Access controls and authentication mechanisms, including multi-factor authentication for internal systems;
- Regular security assessments, vulnerability scanning, and penetration testing;
- Employee training on data privacy and security practices; and
- Contractual obligations imposed on service providers to maintain appropriate security measures.
However, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.
9. Third-Party Links and Services
The Service may contain links to third-party websites or services that are not owned or controlled by the Company. This Privacy Policy applies only to information collected by the Company. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access.
10. International Data Transfers
Our servers are located in the United States, and we process and store information in the United States. If you are located outside the United States, your personal information will be transferred to and processed in the United States, which may not provide the same level of data protection as your home jurisdiction. By using the Service, you consent to the transfer of your personal information to the United States.
Where required by applicable law, we implement appropriate safeguards (such as Standard Contractual Clauses) for international data transfers.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make material changes, we will:
- Post the updated Privacy Policy on this page and update the "Last Revised" date;
- Notify you via email or through a prominent notice within the Service; and
- Obtain your consent where required by applicable law.
Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
- Email: feedback@catchi.ai
- Mailing Address: 68 Circular Road, #02-01, Singapore 049422
- Phone: 65-93350406
For parents and legal guardians with questions regarding Child User privacy, please contact us at the email above with "COPPA Inquiry" in the subject line.
If you have questions specifically about your state privacy rights, please include the name of your state of residence in your communication so we may respond appropriately.
For data subject access requests under the CCPA or other state privacy laws, please email us with "Data Subject Request" in the subject line. We will acknowledge your request within 10 business days and respond substantively within 45 days (which may be extended by an additional 45 days if reasonably necessary, in which case we will notify you).
13. Supplemental State-Specific Disclosures
a. California Residents
The following supplemental disclosures apply to California residents. Because the Company has not commercially launched the Services to the general public as of the Effective Date, the table below describes the categories we expect to collect upon launch, rather than a complete historical record of public-user collection during the preceding 12 months.
Categories of Personal Information Expected to Be Collected
Category |
Expected Business or Commercial Purposes |
|---|---|
Identifiers (e.g., name, email, IP address, device identifiers) |
Account creation and authentication; providing and securing the Services; communications, support, fraud prevention, and localization. |
Customer records (e.g., account information, age, gender, nickname) |
Processing transactions and subscriptions; providing purchased features; customer support, accounting, fraud prevention, and dispute resolution. |
Commercial information (e.g., purchase history) |
Operating, securing, maintaining, measuring, troubleshooting, and improving the Services. |
Internet or electronic network activity (e.g., app usage, learning activity) |
Account creation and authentication; providing and securing the Services; communications, support, and fraud prevention |
Audio / biometric information (e.g., voice recordings used for pronunciation assessment) |
speech recognition and pronunciation assessment |
Categories of Personal Information Expected to Be Disclosed for Business Purposes
We have not "sold" or "shared" (as defined under the CCPA) personal information in the preceding 12 months, nor do we have actual knowledge of selling or sharing personal information of consumers under 16 years of age.
Consumer Rights
The CCPA provides California residents with the following rights regarding their personal information:
Right to Know and Access. You may request information about how we have handled your personal information, including:
- the categories of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purposes for collecting, selling, or sharing personal information;
- the categories of third parties to whom we disclosed personal information; and
- the specific pieces of personal information we have collected about you.
Sections 2 through 4 and Sections 13 a (1) and (2) of the Policy provide this information.
Right to Deletion. You may request that we delete personal information collected from or about you, subject to applicable exceptions.
Right to Correction. You may request that we correct inaccurate personal information maintained about you.
Right to Opt Out. You may opt out of the sale of personal information and sharing for cross-context behavioral advertising. We do not currently engage in either activity.
Right to Non-Discrimination. We will not unlawfully discriminate against you for exercising an applicable privacy right.
Other Information
Shine the Light Disclosure. We do not disclose personal information to third parties for their own direct-marketing purposes.
Children Under 16. We do not knowingly sell or share the personal information of consumers under 16.
Financial Incentives. We do not currently offer a financial incentive or a price or service difference in exchange for collection, sale, or sharing of personal information.
Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes that create a right to limit under California law.
b. Colorado, Connecticut, Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia
This Section 13 supplements the main Policy for residents of the states listed above when the applicable state consumer privacy law applies to us.
Mandatory Disclosures
Categories Processed. We process the categories of personal information described in Section 2 of the Policy, including identifiers and contact information, commercial information, internet or device activity.
Purposes. The purposes for processing personal information are described in Section 3 of the Policy.
Disclosures. Depending on the feature and circumstances, we may disclose the categories described in Section 2 of the Policy to the recipient categories identified in Section 4 of the Policy.
Targeted Advertising. We do not currently sell personal information or process it for targeted or cross-context behavioral advertising.
State Privacy Rights
Depending on your state of residence and subject to applicable exceptions, you may have the right to:
- confirm whether we process your personal information and access that information;
- obtain a copy of personal information in a portable and, where technically feasible, readily usable format;
- correct inaccuracies in personal information;
- delete personal information provided by or obtained about you;
- obtain information about the third parties to which we have disclosed personal information, including the categories of such third parties and, where provided by applicable law, a list of specific third parties.
- withdraw consent to processing where we rely on consent and applicable law provides that right;
- opt out of the sale of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects;
- appeal denial of a privacy-rights request;
- exercise applicable rights without unlawful discrimination or retaliation; and
- if we deny a request or appeal and applicable law permits a complaint to a state attorney general, you may submit a complaint to the applicable authority.
Some rights are not available in every state. We do not currently sell personal information, process it for targeted advertising, or use profiling to make decisions that produce legal or similarly significant effects concerning consumers.
How to Exercise Your Rights
- You, or an authorized agent acting on your behalf, may submit a request through an available in-product control or by emailing feedback@catchi.ai.
- Your request should identify the privacy right you wish to exercise and provide information reasonably sufficient for us to locate the relevant records.
- We may use commercially reasonable methods to verify your identity, residence, and the authority of an authorized agent to act on your behalf.
- We will process verified requests subject to applicable exceptions, technical feasibility, and the rights of other individuals.
Time to Respond
We will respond within the period required by applicable law. Where a 45-day response period applies, we may extend that period by an additional 45 days when reasonably necessary because of the complexity or number of requests and will notify you of the extension.
Right to Appeal
If we deny a request and applicable law provides an appeal right, you may appeal by replying to the decision or emailing feedback@catchi.ai.
Please explain why you believe the request should be granted despite the denial. We will respond to the appeal within the period required by applicable law and, where applicable, within 45 days.
c. Nevada Disclosures
We do not sell “covered information” as defined under Nevada law. Requests concerning Nevada privacy rights may be submitted to feedback@catchi.ai.