MELON LABS LIMITED – PRIVACY POLICY

The information we collect

Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity Data including your name, age, profession, language spoken, photographic identification, marital status, pronouns, and gender.
• Contact Data including your telephone number, address and email.
• Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website.
• Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional Data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
• Voice Recordings including audio captured from your microphone when you use pronunciation practice or the Chit-Chat conversation coach in our mobile app, or voice coaching on our web platform. This happens only while you are actively using those features, and only if you have granted microphone permission.
• Text You Provide including words you look up, sentences you write or speak, and any text you select for translation.
• Learning Activity including the words you save, look up or practise; your quiz and exercise answers; and your scores, streaks and progress.
• Purchase Information including your subscription status and transaction history, received from the Apple App Store or Google Play. We never see or store your payment card details.
• Device and Diagnostic Data including device type, operating system version, app version, crash diagnostics, and in-app events such as which screens are opened and which features are used.

How we collect personal information

We collect personal information in a variety of ways, including:

• when you interact directly with us, including face-to-face, over the phone, over email, or online;
• when you complete a form, such as registering for any events or newsletters, or responding to surveys;
• when you apply for a job with us;
• from third parties, such as details of your use of any website we operate (from our analytics and cookie providers and marketing providers. Where we collect personal information about you from a third party source other than you (other than the personal information which we have specified will be collected by us in accordance with this Privacy Policy) we will take reasonable steps to notify you of such collection, including the fact that the information has been collected, the purpose for which the information has been collected, the intended recipients of the information, and the name and address of the agency that is holding the information, as required by law. See the "Cookies" section below for more detail on the use of cookies);
• automatically as you use our app or web platform, including your learning activity, technical data and usage events;
• from your device microphone, but only while a voice feature is actively running, and only after you have granted microphone permission at the operating-system level and enabled AI features in the app; or
• from publicly available sources, such as social media or the New Zealand Companies Office.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose your personal information for the following purposes:

• to enable you to access and use our software, including to provide you with a login;
• to do business with you, register your attendance at our events, assess your application, manage your appointments;
• to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;
• to contact and communicate with you about any enquiries you make with us via any website we operate;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics (including profiling on our website), market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;
• to run promotions, competitions and/or offer additional benefits to you;
• to generate word meanings, examples, translations, review content and quiz questions;
• to transcribe and assess your speech, and to give you pronunciation and grammar feedback;
• to operate the Chit-Chat conversation coach and voice coaching, and to produce your session reports;
• to manage your account, subscription and entitlements;
• to diagnose crashes, fix defects and understand which features are used so we can improve our products;
• if you have applied for employment with us, to consider your employment application; and
• to comply with our legal obligations or if otherwise required or authorised by law.

Use of Artificial Intelligence

We use AI tools and platforms to provide language learning services and create educational content. This may involve:

• Processing your personal information through AI algorithms to generate personalised language learning content, conversations, exercises, and educational materials;
• Using AI to analyse your learning preferences, progress patterns, language proficiency, and usage behaviour to customise learning experiences and provide targeted educational recommendations;
• Incorporating your personal information into AI-generated learning materials, including but not limited to language exercises, conversation practice, grammar explanations, and educational content;
• Using AI tools to optimise learning outcomes, track progress and measure engagement with personalised educational content.

AI Data Processing Safeguards

• We comply with the terms of service and privacy policies of all AI platforms used;
• Personal information processed by AI systems remains subject to this Privacy Policy and New Zealand privacy laws;
• We take reasonable steps to ensure AI-generated language learning content using your personal information is accurate, appropriate, and educationally sound;
• We do not knowingly allow AI systems to create content that could be harmful, discriminatory, culturally inappropriate, or violate your privacy rights;
• Where technically feasible, we implement measures to prevent AI systems from retaining your personal information beyond the necessary processing period.

Your Rights Regarding AI Processing

• You have the same rights regarding personal information processed through AI as outlined elsewhere in this Privacy Policy;
• You may request information about how your personal information has been used in AI-generated learning content;
• You may object to the use of your personal information for AI training purposes, though this may limit our ability to provide personalised learning services;
• If you believe AI processing has resulted in inaccurate or inappropriate learning content, you may request correction or removal where technically possible.

Third-Party AI Platforms

To deliver these features we send data to third-party AI providers for processing. Your information is processed by those providers in accordance with their own privacy policies as well as our agreements with them. The providers below are used across both the WordBuddy mobile app and the WordBuddy web platform.

We do not send your name, email address, or account identifiers to any AI provider. We do not use your data for advertising, and we do not sell it.

Your control. In the mobile app, AI features can be switched off at any time in Profile → Settings. Turning them off immediately stops all further sharing with the providers listed above for that app.

Protection. We have agreements with each provider above requiring them to protect your data to a standard equal to or better than the protections described in this Privacy Policy, and to process your data only to deliver the feature you requested.

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• marketing or advertising providers such as Google, LinkedIn, Facebook, Instagram or Twitter;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators including, but not limited to, Paypal, Stripe and Shopify Payments;
• our existing or potential agents or business partners or suppliers;
• sponsors or promoters of any promotions or competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Meta Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

In addition to the AI providers named in the "Use of Artificial Intelligence" section above, we use service providers for account authentication and database hosting, content delivery, subscription management, crash reporting and product analytics. Each is bound by contract to process your data only on our instructions and to protect it to a standard equal to or better than the protections in this Privacy Policy.

Your rights and controlling your personal information

• Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.
• Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.
• Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
• Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
• Turn off AI features: In the mobile app, go to Profile → Settings and switch off "AI features and voice practice". No further data will be shared with the AI providers listed in the "Use of Artificial Intelligence" section above.
• Revoke microphone access: You can withdraw microphone permission at any time in your device's system settings.
• Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the New Zealand Privacy Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Voice recordings. Audio captured by our voice features is streamed to the providers listed above and processed in real time. We do not store your voice recordings on our servers. Transcripts and feedback from conversation sessions are saved to your account so that you can review your session reports, and are deleted when you delete your account.

Security measures. Data is encrypted in transit using TLS. Learning data stored on your device is held in an encrypted local database. API keys for our AI providers are held server-side and are never included in the app.

International transfers

We and our service providers — including the AI providers listed above — are located in the United States and other countries, so your personal information may be transferred outside your country of residence. Where we transfer personal data out of the EEA or the UK, we rely on Standard Contractual Clauses or another lawful transfer mechanism.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party's websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from single sign-on accounts

If you connect your account with us using a single sign-on account, such as Apple, Facebook or Google, we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.

The personal information that we may receive includes:

• your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows; and
• any other personal information you choose to share.

We use the personal information we receive from the single sign-on provider to create a profile for you on our platform.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.