Version 2.0 · Effective 7 October 2026
1. Scope
This Privacy Policy explains how SinhHub collects, uses, stores, shares and protects personal data when you use the website, member account, Learning Center, IELTS programs, AI-assisted features, payments, support and partnership inquiry functions.
SinhHub processes personal data in accordance with applicable law, including Vietnam’s Law on Personal Data Protection No. 91/2025/QH15 and its implementing rules where applicable.
2. Categories of data we may process
Depending on the feature you use, we may process:
• Account data: display name, email address, hashed password, email-verification status, account status, preferred language and security-related account information.
• Profile data: nickname, avatar choice, profile photo and Learning Center profile settings.
• Learning data: course enrollment, Stage placement, Unit and lesson progress, answers, results, study time, badges, learning history, promotion exams, reports and other evidence of learning activity.
• Learner-created content: Writing submissions, native-language ideas entered for Writing, notes, free-text responses and feedback acknowledgements.
• Audio and speaking data: speaking recordings, shadowing recordings, IELTS speaking recordings and technical metadata associated with those recordings.
• AI-related data: prompts, submissions sent for AI processing, AI-generated examples or feedback, provider/model metadata, usage records, processing status and credit charges or refunds.
• Commerce data: orders, products, prices, discounts, promotion codes, access periods, credit purchase requests, payment status and transaction references. If an external payment gateway is used, payment credentials may be collected directly by that provider rather than stored by SinhHub.
• Support and communication data: support tickets, replies, attachments, account email-change requests and other messages sent to us.
• Partnership inquiry data: organization name, contact person, email, phone or messaging contact, website and inquiry message.
• Technical and security data: IP-related logs, browser/device information, session data, timestamps, request/error logs and security or abuse-prevention records.
• Cookie and local preference data: session identifiers, CSRF/security cookies and language or functional preferences.
We do not ask you to include unnecessary sensitive personal information in learning tasks. Please avoid entering passwords, financial credentials, exact private addresses, confidential company information or other sensitive data unless a feature clearly requires it.
3. Why we process data
We use personal data to:
• create, verify, secure and maintain accounts;
• deliver courses, Learning Center activities, assessments, Writing and Speaking functions;
• save progress, learning history, recordings, reports and user-selected profile information;
• provide AI-assisted feedback, examples, transcription, analysis or learning support where the feature uses AI;
• calculate and manage Credits, orders, access entitlements, promotions and payment status;
• provide customer support and handle technical problems;
• respond to partnership and business inquiries;
• protect users, investigate abuse, prevent fraud and maintain service security;
• operate, diagnose and improve the reliability and usability of the service;
• comply with legal, accounting, security and dispute-resolution obligations.
4. Consent and other lawful processing
Where consent is required, we request it through the relevant account, policy or feature flow. Some processing is necessary to provide a service you request, perform an agreement, maintain security, comply with law or protect legitimate operational interests recognized by applicable law.
Withdrawing consent does not automatically erase processing that was lawfully completed before withdrawal and may make a feature unavailable when that feature cannot operate without the relevant data.
5. AI processing
SinhHub uses different AI arrangements depending on the feature and current system configuration. Processing may occur on SinhHub-controlled infrastructure or through external AI providers. Current features may use providers such as OpenAI or model services accessed through OpenRouter.
When an external AI feature is used, the data necessary for that feature—such as a Writing response, prompt, audio-derived content or task context—may be transmitted to the provider for processing. We aim to send only the information reasonably required for the requested function.
AI providers may process data in jurisdictions outside Vietnam. Where applicable, SinhHub will handle cross-border processing and provider arrangements in accordance with applicable personal-data law.
6. Other service providers and sharing
We may share or make data available to service providers only as reasonably needed for service operation, for example:
• hosting, infrastructure, storage and security providers;
• AI and transcription providers;
• email-delivery providers;
• payment providers when payment gateways are activated;
• embedded-content providers such as YouTube when you load their content;
• professional advisers or authorities where disclosure is required or permitted by law.
We do not sell personal data as a business model.
7. Retention
Retention depends on the type of data and why it is needed.
Account and core learning records may be kept while the account is active and for a reasonable period afterward when needed for support, security, dispute handling or legal obligations. Learning submissions and recordings are kept to provide learning history and feedback until deleted through an available user control, removed after a valid request, or no longer reasonably needed.
Order, payment, promotion and transaction records may be retained for accounting, fraud prevention and legal requirements. Support and partnership inquiries may be retained while the matter is active and for a reasonable follow-up period. Security logs are retained for an operational period appropriate to security and troubleshooting needs.
Where law requires a longer or shorter period, that legal requirement applies.
8. Your rights
Subject to applicable law and any lawful limitations, you may have rights to be informed about processing, give or withdraw consent, access data, request correction, request deletion, request restriction of certain processing, object to certain processing, obtain data where applicable, and make a complaint.
Some Writing and Speaking records can be deleted directly in the service. For broader access, correction or deletion requests, contact [email protected]. We may need to verify your identity before completing a request.
A deletion request may not require us to delete records that must lawfully be retained, such as certain transaction, fraud-prevention or legal records.
9. Children and younger learners
SinhHub does not currently require date of birth as part of standard member registration. If a learner is below the age at which applicable law permits independent consent, a parent or legal guardian should assist with account use and provide consent where required.
We do not encourage children or any learner to submit unnecessary sensitive information in learning responses or recordings.
10. Security
We use technical and organizational measures appropriate to the service, including password hashing, access controls, private storage for protected recordings, CSRF/session protections, rate limits, logging and operational security controls.
No Internet service can guarantee absolute security. Users should use a strong password, protect access to their email account and contact us if they suspect unauthorized access.
11. International processing
Some external technology providers may store or process data outside Vietnam. Where SinhHub uses such providers for a feature, we will take reasonable steps and follow applicable requirements for cross-border personal-data processing.
12. Cookies
SinhHub uses necessary session, security and functional cookies. Some embedded third-party content may set its own cookies. See the Cookie Policy for details.
13. Policy changes and contact
We may update this Privacy Policy when our services, providers, legal requirements or data practices change. Each published version shows its version and effective date. If a material change requires renewed consent, we may ask members to accept the new version before continuing to member services.
Privacy questions and data requests can be sent to [email protected] or through the contact information published on SinhHub.
