Privacy Policy — LingoWeb Multilingual Browser

Light Nova Design Co., Ltd.（光辰設計有限公司）(“we,” “our,” or “us”) operates the LingoWeb Multilingual Browser mobile application (the “App”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

光辰設計有限公司（「我們」）營運 LingoWeb 多語言瀏覽器行動應用程式（「本 App」）。本隱私權政策說明我們如何蒐集、使用、揭露及保護您在使用本 App 時的資訊。

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

What “collect” means here. For the purposes of the Apple App Store “App Privacy” disclosures and the Google Play “Data safety” section, data is treated as “collected” only where it is transmitted off your device in a way that allows us or a third party to access it. Except for text you submit for translation (Section 1.3), none of the data described below ever leaves your device: we do not receive it, cannot access it, and do not store it. Where this Policy says data is “stored,” that means stored locally on your device only.

1.1 Information You Provide

• Custom Dictionary Entries: Words and phrases you add to your personal dictionary are stored locally on your device.
• App Settings: Your preferences such as language selection, display mode, theme, and translation settings are stored locally on your device.

1.2 Information Stored Automatically

As of the effective date of this Policy, and in the current version of the App:

• Browsing History: The App stores your recent browsing history (page URLs, page titles, and timestamps, up to 100 entries) locally on your device to provide the browsing history feature. It is never transmitted to any server, and it is deliberately excluded from device backups — on iOS the history file is marked as excluded from iCloud and computer backups, and on Android the App disables cloud backup and device-to-device transfer entirely. You can clear it at any time (iOS: Settings → Privacy; Android: see Section 5.5).
• We do NOT collect personal identification information.
• We do NOT collect location data.
• We do NOT collect contacts or address book data.
• We do NOT collect photos or media from your device.
• We do NOT transmit browsing history to any server.

1.3 Translation Data

• What is sent. When you translate a page, the visible text content of that page — which may include pages you have logged into, and text you did not specifically select — is sent to the translation provider. When you translate a selection or look up a word, only the text you selected is sent. Translation text may therefore contain personal data (such as names or addresses appearing on the page); it is processed solely to produce the translation.
• We never receive, log, or store any text you submit for translation.
• Translation cache. Translation results are cached on your device to avoid re-sending the same text. The cache lives in the App’s memory, holds at most 1,000 recent entries (the oldest are discarded first), and is discarded when the App is closed. It is never transmitted anywhere.

2. How We Use Your Information

We use the information we collect solely to:

• Provide translation services within the App.
• Store your preferences and custom dictionary locally on your device.
• Improve App performance through local caching.
• Display content in your preferred language.
• Provide browsing history for your convenience.

We do NOT use your information for profiling, automated decision-making, marketing, or any purpose other than providing App functionality.

3. Third-Party Services

3.1 Translation Services

The App uses the Google Translate service to provide translation functionality. When you request a translation, the text to be translated is sent to Google’s servers. Google’s privacy policy governs how they handle this data:

• Google Privacy Policy: https://policies.google.com/privacy

Google is the App’s only translation service provider. A previous build of the App also sent text to a second provider; that path was removed on 20 August 2026 and is not present in any version described by this Policy. If any additional provider is ever added, we will update this Privacy Policy and the app store privacy disclosuresbefore that version is released.

3.2 Websites You Visit

The App includes a built-in web browser. When you visit websites, those websites may collect data according to their own privacy policies. We have no control over and assume no responsibility for the privacy practices of third-party websites.

3.3 No Analytics or Advertising

As of the effective date of this Policy, and in the current version of the App:

• We do NOT use any analytics services or SDKs.
• We do NOT display advertisements.
• We do NOT use any advertising identifiers (including Apple IDFA or Google Advertising ID).
• We do NOT integrate any third-party tracking technologies.

4. Data Storage and Security

4.1 Local Storage

All user data, including custom dictionary entries, settings, browsing history, and translation cache, is stored locally on your device. We operate no server that receives, processes, or stores anything from the App. (We do run our company website at light-nova.com, including the contact form on it; that is entirely separate from the App and the App never communicates with it.)

4.2 Data Security

We implement appropriate technical measures to protect the information stored on your device, including:

• All data is stored in the App’s sandboxed storage area, isolated from other apps.
• No data is transmitted to our servers.
• Every request the App itself makes to the translation service is hard-coded to HTTPS; the App never sends your text over an unencrypted connection.
• Note: The App’s browser allows you to visit websites using both HTTPS and HTTP protocols. When visiting HTTP websites, data transmitted between your device and the website may not be encrypted. We recommend visiting HTTPS websites whenever possible.

4.3 Data Retention

• Custom Dictionary (iOS): Stored indefinitely until you delete entries or uninstall the App.
• App Settings: Stored indefinitely until you reset settings or uninstall the App.
• Browsing History: Up to 100 recent entries, stored until you clear the history or uninstall the App.
• Translation Cache: Held in memory only, capped at 1,000 entries, discarded when the App closes.
• Cookies: Managed according to your cookie settings; can be cleared at any time (iOS).
• We retain nothing, because the App never sends us anything.

Uninstalling and backups. Uninstalling the App removes everything it stored in its sandbox from your device. Your browsing history is additionally excluded from device backups, so it cannot be restored later: on iOS the history file is flagged as excluded from iCloud and computer backups, and on Android the App setsallowBackup="false" and excludes all of its data from cloud backup and device-to-device transfer. On iOS, your custom dictionary and App settings are stored in the standard iOS preferences store, whichis included in an iCloud or computer backup if you make one; restoring such a backup can bring them back. You can disable or delete backups in your device’s system settings.

5. Your Rights and Choices

5.1 Data Control

You have full control over your data. The controls listed below are provided by the App’s in-app Settings screens, which are currently available on iOS only; see Section 5.5 for what applies on Android.

• View, edit, and delete custom dictionary entries at any time. (iOS)
• Clear browsing history at any time through App settings. (iOS)
• Clear cookies and website data at any time through App settings. (iOS)
• Export or import your custom dictionary data. (iOS)
• Reset all settings to defaults. (iOS)
• The translation cache needs no control: it is held in memory and disappears when you close the App. (iOS and Android)

5.2 Cookie Management (iOS)

On iOS, the App provides the following cookie options, which you can change at any time in its Privacy settings. They are enforced by the browser engine on your device, and take effect immediately:

• Accept all cookies — the default.
• Accept only essential cookies — blocks third-party (cross-site) cookies, which are the ones commonly used for tracking, while allowing cookies set by the site you are actually visiting so that logins keep working.
• Block all cookies — blocks every cookie. Some websites will not work correctly with this setting.

These are browser-level controls applied on your device. We do not set any cookies ourselves. Each website you visit remains responsible for its own cookie practices and for obtaining any consent it is required to obtain.

5.3 Data Deletion

You can delete App data by:

• Using the in-app settings to clear specific data categories — history, cookies, dictionary. (iOS)
• Clearing the App’s storage in your device’s system settings. (iOS and Android)
• Uninstalling the App, which removes everything it stored on your device (see the note on backups in Section 4.3).

5.4 Data Portability (iOS)

On iOS, you can export your custom dictionary data in JSON format for backup or transfer to another device.

5.5 What differs on Android

We publish one policy for both platforms, so we state the differences plainly. The current Android version of the App is a browser with translation only: it does not yet include the in-app Settings screens, the custom dictionary, or the cookie controls described above. On Android:

• Browsing history is still stored locally, capped at 100 entries, and excluded from backups — but there is no in-app control to clear it. Clearing the App’s storage in Android system settings, or uninstalling the App, removes it.
• There is no custom dictionary, so nothing is stored for it and there is nothing to export.
• There are no in-app cookie controls; the system WebView defaults apply.

We will update this Policy when those features ship on Android. Nothing in this section changes what leaves your device: on both platforms, the only data sent anywhere is the text you submit for translation.

6. Children’s Privacy

The App is not directed at children. We do not knowingly collect personal information from children under the age of 13 (United States, COPPA), under 16 (European Union, GDPR Art. 8, varies by member state), or under the applicable age of digital consent in your jurisdiction.

The App carries a mature age rating on the app stores because it provides unrestricted access to the open web. The Terms of Service set the corresponding age requirement.

If you are a parent or guardian and believe your child has used the App and personal data may have been processed through translation services, please contact us so we can assist you.

7. International Data Transfers

When you use the translation feature, text is transmitted to Google’s servers, which may be located in countries outside your jurisdiction. These transfers are necessary to provide the translation you requested.

Like any internet request, these transfers necessarily include your device’s IP address and standard network metadata (such as the time of the request and the user-agent string), which the translation provider receives as part of the connection. We do not add any account identifier, device identifier, or advertising identifier to these requests. Apart from that metadata, the only content transferred is the text being translated.

For users in the European Economic Area and the United Kingdom: the processing of the translation text is necessary to perform the service you requested (GDPR Art. 6(1)(b)). As regards the transfer itself, Google is certified under the EU-U.S. Data Privacy Framework and its UK Extension and additionally relies on the European Commission’s Standard Contractual Clauses; details of those safeguards, and how to obtain a copy, are published atpolicies.google.com/privacyand business.safety.google/gdpr.

8. Regional Compliance

8.1 GDPR (European Union / European Economic Area)

For users in the EEA, the following applies.

Our role and the lawful basis for each activity:

• Translation text. We act as a controller for the limited purpose of transmitting the text you submit to the translation provider. The lawful basis is performance of a contract (Art. 6(1)(b)) — the transmission is necessary to provide the translation service you requested.
• Dictionary, settings, browsing history, and translation cache. These are stored solely on your device. We do not receive, access, or process them, and we are not a controller in respect of them. Storing them on your device is strictly necessary to provide the features you have explicitly requested, and is therefore exempt from the consent requirement under Article 5(3) of the ePrivacy Directive.
• Cookies set by websites you visit. The operator of each website is the controller for its own cookies and is responsible for obtaining any consent required. The App only provides a device-level control that lets you accept, limit, or block them (Section 5.2).

Your Rights Under GDPR:

• Right of access (Art. 15): view all your data directly within the App.
• Right to rectification (Art. 16): edit your dictionary entries and settings at any time.
• Right to erasure (Art. 17): delete any or all of your data through App settings.
• Right to restriction of processing (Art. 18): you can disable translation features while continuing to use the browser.
• Right to data portability (Art. 20): export your dictionary data in JSON format.
• Right to object (Art. 21): we do not process your personal data on the basis of legitimate interests, so this right does not arise; you can nonetheless stop all transfers to the translation provider at any time by not using the translation feature.
• Right related to automated decision-making (Art. 22): the App does not perform automated decision-making or profiling.
• Right to lodge a complaint: you have the right to lodge a complaint with your local data protection supervisory authority.

We have assessed our processing against Art. 37 GDPR and are not required to appoint a Data Protection Officer: we do not carry out large-scale systematic monitoring of data subjects, and we do not process special categories of data. Data protection enquiries should be sent to the contact in Section 11.

8.2 CCPA / CPRA (California, United States)

For California residents, the following applies to the extent the California Consumer Privacy Act and California Privacy Rights Act apply to us.

Categories of Personal Information Collected (preceding 12 months):

• Internet or other electronic network activity information (browsing history stored locally; translation text sent to Google for processing).

Categories of Sources:

• Directly from you (text you submit for translation, dictionary entries you create, websites you visit).

Business Purpose for Collection:

• Providing translation and browsing services within the App.

Categories of Third Parties with Whom Information Is Shared:

• Google (translation text only, for the purpose of providing translation results).

Your Rights:

• Right to Know: you can view all collected data directly in the App.
• Right to Delete: you can delete all data through the App settings or by uninstalling.
• Right to Opt-Out of Sale/Sharing: we do NOT sell or share your personal information. No opt-out is necessary.
• Right to Limit Use of Sensitive Personal Information: we do not collect sensitive personal information.
• Right to Correct: you can edit your dictionary entries and settings directly in the App at any time. Because we hold no copy of your data, corrections take effect on your device immediately.
• Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights.
• Authorized Agents: you may use an authorized agent to submit a request on your behalf; we may ask the agent for written proof of authorization.
• Verification: because we hold no data about you, there is nothing for us to verify or retrieve — all of it is under your direct control in the App.

Financial Incentives: we do not offer any financial incentives related to the collection of personal information.

8.3 Taiwan PDPA（個人資料保護法）

適用於台灣使用者：

• 蒐集者：光辰設計有限公司（Light Nova Design Co., Ltd.）
• 蒐集目的：提供翻譯及瀏覽服務（代碼 135 資（通）訊服務；代碼 136 資（通）訊與資料庫管理；代碼 090 消費者、客戶管理與服務）
• 個人資料類別：瀏覽紀錄（C001 辨識個人者中之網路活動紀錄）
• 利用期間：至使用者刪除資料或解除安裝本 App 為止
• 利用地區：中華民國境內及翻譯服務提供商所在地區
• 利用對象及方式：本 App 於裝置端儲存；翻譯文字傳送至 Google 翻譯服務處理

您的權利（依個人資料保護法第 3 條）：

• 查詢或請求閱覽您的個人資料
• 請求製給複製本
• 請求補充或更正
• 請求停止蒐集、處理或利用
• 請求刪除

您可隨時透過 App 設定行使上述權利（Android 版尚無設定畫面，詳見第 5.5 節）。如需協助，請聯繫我們（見第 11 節）。

不提供個人資料之影響（個人資料保護法第 8 條第 1 項第 6 款）：您得自由選擇是否使用翻譯功能。若您選擇不使用翻譯功能、不將文字傳送至翻譯服務提供商，本 App 之瀏覽功能仍可正常使用，僅無法取得翻譯結果；除此之外，對您的權益並無其他影響。本 App 之個人字典、設定與瀏覽紀錄均僅儲存於您的裝置，並未提供予我們。

8.4 UK GDPR (United Kingdom)

For users in the United Kingdom, the UK General Data Protection Regulation applies. Your rights are substantially the same as those described in Section 8.1. The relevant supervisory authority is the Information Commissioner’s Office (ICO): https://ico.org.uk/

8.5 PIPEDA (Canada)

For users in Canada: we collect only the minimum information necessary for App functionality. All data is stored locally on your device. You may access, correct, or delete your data at any time through the App settings.

8.6 LGPD (Brazil)

For users in Brazil: the legal basis for processing translation text is contractual necessity (Art. 7, V). You have the right to confirmation of processing, access, correction, anonymization, portability, deletion, and information about sharing with third parties. Exercise these rights through the App settings or by contacting us.

8.7 APPI (Japan)

For users in Japan: we specify the purpose of data use as providing translation and browsing services. Translation text is transferred to Google’s servers (which may be outside Japan) solely for translation purposes. You may request disclosure, correction, or cessation of use of your data.

8.8 PIPA (South Korea)

For users in South Korea: translation text is transferred to Google for processing, which may involve cross-border data transfer. You have the right to access, correct, delete, and suspend processing of your personal data.

8.9 PIPL (China)

For users in China: translation text is transmitted to servers outside of China (Google’s servers) for translation processing. By using the translation feature, you consent to this cross-border transfer. You have the right to access, copy, correct, and delete your personal information.

8.10 PDPA (Thailand / Singapore)

For users in Thailand and Singapore: we collect and use data only for the purpose of providing App functionality. You may withdraw consent for data processing by ceasing use of the translation feature. You have the right to access, correct, delete, and port your data.

8.11 Australia Privacy Act

For users in Australia: we comply with the Australian Privacy Principles (APPs). We collect only information necessary for App functionality. Translation text is disclosed to Google (overseas) for translation purposes. You may access and correct your data through the App settings.

8.12 Apple App Store Guidelines

• The App stores browsing history locally on your device only. It is not transmitted off the device, not linked to your identity, and not shared.
• The App does not collect data linked to your identity.
• The App does not use tracking technologies.
• The App does not use the Advertising Identifier (IDFA).
• The App does not require App Tracking Transparency authorization.

8.13 Google Play Store Guidelines

• The App complies with Google Play’s User Data policy.
• The App complies with Google Play’s Permissions policy.
• The App requests only INTERNET and ACCESS_NETWORK_STATE permissions.
• The App does not access sensitive user data beyond what is needed for core functionality.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by updating the “Last updated” date at the top of this Privacy Policy. For material changes, we will provide notice through the App. You are advised to review this Privacy Policy periodically.

If a future version of the App introduces any form of analytics, diagnostics, advertising, third-party SDK, or an additional translation provider, we will update this Policy and the App Store and Google Play privacy disclosuresbefore that version is released, and describe the change in the version history below.

10. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of China (Taiwan). Any disputes arising from or relating to this Privacy Policy shall be subject to the jurisdiction of the Taiwan Taipei District Court as the court of first instance, unless otherwise required by applicable local law in your jurisdiction.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your data, please contact us at:

• Light Nova Design Co., Ltd.（光辰設計有限公司）
• Email: [email protected]
• Contact form: https://www.light-nova.com/en/contact/

For GDPR-related inquiries from users in the EEA or UK, please use the same email address with the subject line “GDPR Request.”

12. Summary of Data Practices

13. Version History

This Privacy Policy is designed to be transparent about our data practices and to comply with applicable privacy laws and app store guidelines worldwide.