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Huahua — Privacy Policy (DRAFT)

DRAFT. Owner facts folded in 2026-07-29; owner-input blanks resolved 15 August 2026. Still needs a legal review before publishing. Not legal advice.

Who we are. Huahua ("we", "us") is a Mandarin-learning app operated by PT HUAHUA EDUKASI INDONESIA, the data controller, registered in Indonesia. Contact: admin@huahualearning.com. (We publish an email only — no home address on this page.)

Last updated: 15 August 2026 (15 Agustus 2026)

1. What this covers

What personal data the Huahua app collects, why, who we share it with, how long we keep it, and your choices.

2. Data we collect

We do not sell your personal data.

3. AI providers we use (subprocessors)

Limited data goes to these providers, only for the feature you use:

These providers process your data only to deliver the feature and do not use it to train their own models.

4. Why we're allowed to use your data (legal basis)

To provide the service you asked for (your account, lessons, and features you tap), with your consent for audio and notifications, and our legitimate interest in security and reliability. These bases — your consent, and our performance of the contract with you — are mapped to Indonesia's Personal Data Protection Law (UU No. 27 of 2022 on Personal Data Protection). We do not currently serve the EU market, so no GDPR basis is claimed here.

5. Children and teens

Huahua is for users aged 13 and older — the same minimum Duolingo and most language apps use. We do not knowingly collect data from children under 13, and use of Huahua by anyone under 13 is not permitted. Because under-13 use is not allowed, Huahua does not offer a parental-consent flow.

6. How long we keep data

The retention periods above are current and confirmed. Backup copies are rotated automatically and expire shortly after data is deleted from live systems.

7. Where your data is stored

Our database, storage, and the AI providers run on servers outside Indonesia, so your data may be processed abroad. Indonesia's PDP Law allows this when we tell you and require the providers to protect the data — which we do. Huahua is served for the Indonesian market, and your data is processed by the service providers listed in this policy on their own cloud infrastructure. We do not currently have EU/EEA users; if that changes, we will add EU-specific transfer terms before serving that market.

8. Your rights

You can see, export, correct, and delete your data (deleting your account removes your personal data, subject to legal retention). Contact admin@huahualearning.com or use in-app settings where available.

9. Security

Least-privilege access, encrypted secrets, signed content, and fail-closed checks. No system is perfectly secure, but we work to protect your data. Report security issues per SECURITY.md.

10. Changes

We'll update this policy as the app changes and note the "last updated" date.

11. Contact

Email admin@huahualearning.com. Our legal entity is PT HUAHUA EDUKASI INDONESIA, registered in Indonesia; registered business details are given to the app stores, not published here.