Privacy Policy

1. Introduction and Scope

1.1 What This Policy Covers. This Privacy Policy (this "Policy") applies to the App and to the Site. It explains the categories of data handled in connection with the App and the Site, the locations where that data is processed and stored, the parties who can access it, the purposes and legal bases for the processing carried out by the Developer, and the rights and choices available to you.

1.2 Definitions. In this Policy:

• "App" means Keyu (课语), Bundle ID com.gacing.LectureCaptions, an application for Apple's iOS and iPadOS distributed through the Apple App Store at apps.apple.com/app/id6809385865, including Test Builds of the App distributed through the Site (Section 6.3).
• "Test Build" means a development-signed build of the App distributed through the Site for installation on registered devices, outside the App Store.
• "Site" means the website accessible at keyu.gacing.com.
• "Developer" means the individual developer of the App, who distributes the App through the App Store under the developer's own legal name, shown as the seller on the App's App Store product page, and who uses the signature "GACING" in copyright notices and on the Site.
• "You" and "your" mean any natural person who downloads, installs, or uses the App or who accesses the Site. If a natural person uses the App on behalf of a school, a business, or another organization, then "you" and "your" include that organization, and that person is treated as acting on the organization's behalf.
• "Apple" means Apple Inc.
• "Terms" means the Terms of Use for the App and the Site, published on the Site.
• "Diagnostic Data" has the meaning given in Section 5.2.

1.3 The App in Brief. The App is a study aid that uses the device microphone, or an external microphone connected to the device (such as AirPods or other Bluetooth earphones, a wired or USB microphone, or the receiver of a wireless lavalier microphone plugged into the device), to capture the sound of a class or lecture, generates captions in real time, and translates each sentence into a language you select. By default, each captioning session simultaneously records audio; you can turn recording off on the "About" page. Sessions can be reviewed in the App, and captions, translations, and recordings can be exported and shared in the formats the App provides. The App is free of charge and contains no in-app purchases, subscriptions, advertising, accounts, or sign-in.

1.4 Relationship to the Terms of Use. The Terms refer to this Policy, and the two documents should be read together. This Policy is a notice describing data handling; it is not incorporated into the Terms as a contractual term and does not form part of the contract between you and the Developer.

1.5 Data Handling in Summary. Captioning, translation, and recording take place on your device, and the Developer cannot access the data stored on your device, including your audio, recordings, captions, translations, and exports, or the sessions stored in your iCloud Drive when you turn on iCloud Sync (Section 4.6). The Developer receives or handles information only in the following cases: Diagnostic Data, including the App's run logs and diagnostic records, that you send to the Developer yourself (Section 5); crash reports and usage statistics that Apple may provide (Section 4.4); Site connection data processed to deliver the pages you request (Section 6); and messages that you send by email, including any export files you choose to attach (Section 7).

1.6 Roles. For the purposes of data protection law, the Developer is the controller of the Diagnostic Data described in Section 5, the Site connection data described in Section 6, and the correspondence described in Section 7. Apple independently determines the purposes and means of the processing it performs in connection with its services (Section 4), including the download of language resources, iCloud Backup, the iCloud Drive used for iCloud Sync, and the data it makes available to the Developer. The servers described in this Policy are servers operated by the Developer on infrastructure supplied by hosting providers; the Site server is hosted at DMIT, Inc. in Los Angeles, California, United States (Sections 6.1, 7.3, and 9.3).

2. Data Overview

2.1 Overview Table. The table below summarizes each category of data handled in connection with the App and the Site.

2.2 How to Read This Table. Sections 3 through 7 describe each category in detail. Section 8 states the purposes and legal bases for the processing that the Developer carries out. Section 11 states the retention rules. Section 12 explains how to exercise control over each category.

3. Data Processed and Stored on Your Device

3.1 Real-Time Audio Processing. When you start a captioning session, the App captures sound through the device microphone or through an external microphone connected to the device, such as AirPods or other Bluetooth earphones, a wired or USB microphone, or the receiver of a wireless lavalier microphone plugged into the device. Sound from an external microphone reaches the device over Bluetooth or a cable. The sound is processed in real time on your device, using Apple's speech recognition and translation system frameworks, to produce captions and translations. Starting a captioning session requires the iOS microphone and speech recognition permissions, as described in Sections 4.1 and 12.2. The live audio stream is not stored apart from the session recording described in Section 3.2.

3.2 Session Recordings. The "About" page includes a "Save Session Recordings" switch, which is on by default. When the switch is on, every captioning session simultaneously records audio; the recording is saved on your device in the App's own audio file format, and recording files are excluded from iCloud Backup. If you turn on iCloud Sync, recordings are also stored in your iCloud Drive (Section 4.6). When the switch is off, sessions save only captions and translations, no recording file is created, and existing recordings are not affected. You can delete a session's recording on its own from the "Export" menu in the session details by selecting "Delete Recording"; only that recording is deleted, and the session's captions and translations are retained.

3.3 Captions, Translations, and Class Names. Caption text and its translations are saved together in the same file on your device, along with the class name of the session. If you turn on iCloud Sync, these items are also stored in your iCloud Drive (Section 4.6). If you enable iCloud Backup, these items are included in the backups maintained by Apple, as described in Section 4.3.

3.4 App Run Logs and Diagnostic Records. The App keeps run logs in its data directory on your device. Run logs rotate automatically by size: older content is cleared as new content is written. Diagnostic records are crash and hang records generated by iOS and stored on your device. Run logs and diagnostic records cannot be managed separately in the App's interface, and deleting a session does not delete them. Run logs and diagnostic records are deleted when you delete the App. If you enable iCloud Backup, run logs and diagnostic records are included in the backups maintained by Apple (Section 4.3). Run logs and diagnostic records reach the Developer only as part of a diagnostic log file that you send yourself (Section 5).

3.5 Review, Export, and Sharing. You may review sessions in the App and export or share captions, translations, and recordings in the formats the App provides. Exports are created only when you request them. Once you share an item or move it outside the App, its further storage and handling are under your control and subject to the terms of the destinations you choose.

3.6 No Developer Access. The Developer has no access to the audio, recordings, captions, translations, logs, or exports on your device, or to the sessions stored in your iCloud Drive when you turn on iCloud Sync, and cannot retrieve, view, or restore them.

3.7 Deletion. Deleting a session in the App deletes that session's captions, translations, and recording; run logs and diagnostic records are not affected (Section 3.4). Deleting a session's recording on its own deletes only that recording; the session's captions and translations are retained. If you turn on iCloud Sync, deleting a session or only its recording in the App also deletes the corresponding files in iCloud Drive, and they are no longer present on any device with sync turned on; after you turn sync off, deleting in the App deletes only the copy on that device, and copies remaining in iCloud Drive are deleted by you in iCloud Drive in the Files app or in iCloud storage management in iOS Settings, or by turning sync back on and deleting them in the App. Deleting the App deletes all of the App's data stored on the device, including all sessions, run logs, and diagnostic records. Deletion is performed on your device by you; the Developer cannot recover deleted data. Copies already included in an iCloud Backup are retained by Apple under its policies, and copies you have exported or shared remain under the control of their destinations.

4. Apple Services

4.1 On-Device Recognition and Translation. Speech recognition and translation are performed by Apple's system frameworks on your device. The App does not transmit your audio, captions, or translations to the Developer or to any server for processing. Starting a captioning session requires the iOS microphone and speech recognition permissions. You can withdraw these permissions as described in Section 12.2; withdrawal affects new captioning sessions and does not affect sessions already stored on your device.

4.2 Language Resources. The first time you use a recognition language or a translation language, iOS downloads the corresponding language resources from Apple. After the download completes, recognition and translation work offline. The download is a transaction between your device and Apple and is governed by Apple's privacy policy.

4.3 iCloud Backup. If you enable iCloud Backup in your device settings, the backups maintained by Apple include the App's data stored on your device: captions and translations (saved in the same file), class names, run logs, and diagnostic records. Recording files are marked to be excluded from iCloud Backup and are not included. iCloud Backup is an Apple service operated under Apple's terms and privacy policy.

4.4 Share with App Developers. If you have enabled "Share with App Developers" in iOS Settings, Apple may make crash reports and usage statistics available to the Developer in accordance with Apple's privacy policy. This data is provided in a form that cannot identify you.

4.5 Apple's Privacy Policy. Apple's processing of data described in this Section 4 is governed by the Apple Privacy Policy, available at apple.com/legal/privacy. Apple independently determines the purposes and means of that processing (Section 1.6).

4.6 iCloud Sync. iCloud Sync is off by default and can be turned on separately on each device on the App's About page; turning it on requires that the device is signed in to an Apple Account and that iCloud Drive is available. On a device where sync is turned on, that device's sessions (captions, translations, class names, and recordings) are moved into the App's folder in the iCloud Drive of your Apple Account; while a recording is in progress it is written locally first and moved after the session ends. Other devices signed in to the same Apple Account with sync turned on see the same set of sessions: captions, translations, and class names download automatically, and a recording downloads when you open its session. While sync is on, deleting a session, or deleting only its recording, on any device also deletes the corresponding files in iCloud Drive, and they are no longer present on any device. Turning sync off keeps the sessions already downloaded on that device; the sessions in iCloud Drive remain as they are, and other devices continue to sync. Recordings use your iCloud storage. iCloud Drive is an Apple service operated under Apple's terms and privacy policy, and Apple independently determines the purposes and means of its processing (Sections 1.6 and 4.5); the Developer does not access or receive the synced data and does not determine its processing. iCloud Sync uses iCloud Drive and is distinct from iCloud Backup described in Section 4.3; the rules for iCloud Backup are unchanged, and recording files remain excluded from iCloud Backup.

5. Diagnostic Data You Choose to Send

5.1 Sent Only When You Choose. The App generates a diagnostic log file on your device, and you decide whether and how to send it: you may send it through the system mail interface, or use the system share sheet to send it with another App or to save it to the Files app. The App itself does not send the diagnostic log file or any of its contents to the Developer; the Developer receives it only if you send it to the Developer yourself. Apart from this pathway that you initiate, the App does not send Diagnostic Data to the Developer.

5.2 Contents. "Diagnostic Data" means the following items, contained in the diagnostic log file generated by the App: (a) device model; (b) operating system version; (c) App version; (d) App run logs; and (e) the diagnostic records described in Section 3.4, meaning crash and hang reports generated by iOS MetricKit. Diagnostic Data does not include caption text, translations, or recordings.

5.3 Destination and Transmission. Diagnostic Data you send yourself is transmitted through the email service or the App you choose, to the recipients you choose. When you send it through the system mail interface, the App pre-fills the Developer's email address keyu@gacing.com, a subject line, and version information, and attaches the diagnostic log file; whether to send the message is your decision.

5.4 Use. Diagnostic Data is used only to diagnose and resolve technical problems with the App. It is not used for tracking or advertising. Diagnostic Data you send to the Developer is handled as correspondence under Section 7.

5.5 Deletion Requests. You may at any time request the deletion of Diagnostic Data that you sent to the Developer by sending an email to keyu@gacing.com. In your request, cite the address you sent it from and the approximate time you sent it.

5.6 Retention. Diagnostic Data you send to the Developer is deleted 90 days after the Developer receives it. A deletion request under Section 5.5 results in earlier deletion.

6. The Site

6.1 Operation, Hosting, and Domain. The Site is a static website operated by the Developer on a server hosted at DMIT, Inc. and located in Los Angeles, California, United States. The domain gacing.com is registered through Spaceship, an ICANN-accredited registrar, and the Site is hosted at the subdomain keyu.gacing.com.

6.2 Connection Data. When your browser requests a page from the Site, the Developer's web server processes your IP address and related connection data in real time as necessary to respond to the request. The Developer has not configured access logs for the Site. The Site sets no cookies, performs no access analytics, and loads no third-party scripts. The hosting provider and the network operators that carry internet traffic may process technical data such as IP addresses in accordance with their own policies in order to deliver pages.

6.3 Test Builds. A page of the Site distributes Test Builds of the App for wireless installation on registered devices. Test Builds are distributed by the Developer and are not distributed through the App Store.

7. Correspondence

7.1 What the Developer Receives. When you send an email to the Developer, the Developer receives your sending address and the content of your message, including any information and files you choose to include or attach.

7.2 Use. Personal information contained in correspondence is used to reply to you and to handle your request, for example to process a deletion request under Section 5.5, and is retained as necessary to comply with legal obligations, resolve disputes, and establish, exercise, or defend legal rights, as described in Section 7.3. Suggestions, ideas, and feedback that you send are handled as described in the Terms.

7.3 Storage and Retention. Mail sent to keyu@gacing.com is stored by the Developer. Correspondence is retained for the period necessary to handle your request and thereafter for any period necessary to comply with legal obligations, resolve disputes, and establish, exercise, or defend legal rights.

8. Purposes and Legal Bases

8.1 Processing on Your Device. Captioning, translation, recording, run logs, diagnostic records, and exports all take place on your device. These activities are not processing carried out by the Developer, and accordingly no legal basis for the Developer is stated for them. The Developer receives data generated by these activities only where this Policy says so: run logs and diagnostic records reach the Developer only within Diagnostic Data that you send yourself (Section 5), and export files reach the Developer only if you choose to attach them to correspondence (Section 7).

8.2 Diagnostic Data. Purposes: diagnosing and resolving technical problems with the App in response to the troubleshooting request you initiate by sending Diagnostic Data yourself. Legal basis: the Developer's legitimate interests in diagnosing technical problems and responding to your requests (Article 6(1)(f) of the General Data Protection Regulation).

8.3 Correspondence. Purposes: responding to and handling your requests, and retaining correspondence as necessary to comply with legal obligations, resolve disputes, and establish, exercise, or defend legal rights. Legal basis: the Developer's legitimate interests in responding to and handling requests and in establishing, exercising, and defending legal rights (Article 6(1)(f) of the General Data Protection Regulation).

8.4 Site Connection Data. Purpose: delivering the web pages you request. Legal basis: the Developer's legitimate interest in operating and delivering the Site.

8.5 Data Provided by Apple. Purpose: maintaining the stability and functionality of the App. The crash reports and usage statistics described in Section 4.4 are collected and delivered by Apple under Apple's terms and privacy policy; the Developer's legal basis for reviewing them is the legitimate interest in maintaining the App.

9. Sharing and Disclosure

9.1 No Sale, No Sharing, No Targeted Advertising, No Profiling. The Developer does not sell your personal information and does not share it for cross-context behavioral advertising, as the terms "sell" and "share" are defined under the California Consumer Privacy Act. The Developer does not use your information for targeted advertising and does not build profiles of you.

9.2 Limited Disclosure. The Developer discloses information only in the following cases: (a) where required by law or legal process; (b) where disclosure is necessary to establish, exercise, or defend legal rights; and (c) in connection with a transfer of the App or of a related business, in which case the information described in this Policy may be transferred to the successor.

9.3 Infrastructure Processing. The Site server is hosted at DMIT, Inc. in the State of California, United States, and the other servers described in this Policy are likewise operated by the Developer on infrastructure provided by hosting providers. The hosting providers process technical data as necessary to provide that infrastructure, as described in Sections 5.3, 6.2, and 7.3. This is the operation of hosting infrastructure, not a sale or sharing of personal information.

10. Cross-Border Processing

10.1 Processing Locations. The Site is hosted at DMIT, Inc. in the State of California, United States, and Site connection data is processed where the Site is hosted. Diagnostic Data you send to the Developer is handled as correspondence (Section 7), and correspondence is processed on servers operated by the Developer. Your information may be processed in jurisdictions other than the one where you are located. Apple determines the locations of its own processing under its policies.

10.2 Transfers From the European Economic Area and the United Kingdom. If you are located in the European Economic Area or the United Kingdom, your data may be processed outside that region, including in the United States, where the Site is hosted. Where applicable data protection law requires a transfer mechanism or derogation for this processing, the Developer relies on a mechanism or derogation made available by that law, including, where applicable, the derogations for specific situations in Article 49 of the General Data Protection Regulation for transfers that you carry out yourself by sending Diagnostic Data or an email.

11. Data Retention

11.1 Diagnostic Data. Diagnostic Data you send to the Developer is deleted 90 days after the Developer receives it. A deletion request under Section 5.5 results in earlier deletion.

11.2 Correspondence. Correspondence is retained as stated in Section 7.3.

11.3 On-Device Data. Recordings are retained on your device until you delete the relevant recording, the relevant session, or the App. Captions and translations are retained on your device until you delete the relevant session or the App. Run logs and diagnostic records are retained on your device until you delete the App; run logs rotate automatically by size, and deleting a session does not delete run logs or diagnostic records. Data included in an iCloud Backup is retained by Apple under Apple's policies. If you turn on iCloud Sync, session data in iCloud Drive is retained until you delete it (Section 4.6).

11.4 Data Provided by Apple. The retention of the crash reports and usage statistics described in Section 4.4 is determined by Apple's platform and policies.

12. Your Rights and Choices

12.1 On-Device Data. You can review, export, and delete sessions directly in the App, and you can delete all of the App's on-device data by deleting the App. You can turn iCloud Sync on or off on the App's About page; while sync is on, deleting a session, or deleting only its recording, in the App also deletes the corresponding files in iCloud Drive (Section 4.6). No request to the Developer is required, because the Developer cannot access this data.

12.2 System Permissions and Controls. You can grant or withdraw the App's access to the microphone and to speech recognition at any time in the iOS Settings app, under Privacy & Security > Microphone and Privacy & Security > Speech Recognition, or under the App's entry in Settings. Withdrawing these permissions prevents new captioning sessions from capturing and recognizing audio; sessions already stored on your device remain until you delete them. Notifications are optional: the App requests the notification permission only if you enable notifications on the App's About page, and you can turn notifications off in the App's entry in Settings. Live Activities on the Lock Screen can be turned off in the App's entry in Settings.

12.3 Diagnostic Data. No Diagnostic Data is sent to the Developer unless you send it yourself. You may request deletion of Diagnostic Data you sent at any time as described in Section 5.5.

12.4 California Residents. If you are a California resident, then to the extent that the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to the Developer and grants you these rights, you have the right to know what personal information is collected, the right to access, correct, and delete personal information, the right to opt out of the sale or sharing of personal information (which does not occur, as stated in Section 9.1), and the right not to be discriminated against for exercising these rights. To exercise any of these rights, email keyu@gacing.com. For requests concerning Diagnostic Data, include the address you sent it from and the approximate time you sent it, so that the Developer can locate it, as described in Section 5.5.

12.5 European Economic Area and United Kingdom. If you are located in the European Economic Area or the United Kingdom, then to the extent that the General Data Protection Regulation or the UK GDPR grants you these rights, you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection. To exercise any of these rights, email keyu@gacing.com. You also have the right to lodge a complaint with the data protection supervisory authority in your place of residence or work.

13. Children

13.1 Age Direction. The App and the Site are not directed to children under 13 years of age, or under any higher minimum age required by the law of your jurisdiction. The Developer does not knowingly collect personal information from such children. If you believe that a child has transmitted Diagnostic Data or correspondence to the Developer, contact keyu@gacing.com.

14. Security

14.1 Measures. Data stored by the App on your device is protected by the security architecture of iOS and iPadOS. The transmission of Diagnostic Data you send yourself is the responsibility of the email or App service provider you choose. The Developer maintains access restrictions on the servers and applications used to operate the services described in this Policy.

14.2 No Absolute Security. No method of transmission over the internet and no method of electronic storage is completely secure. The Developer cannot guarantee absolute security.

15. Changes to This Policy

15.1 Revisions. The Developer may revise this Policy. The revised Policy will be posted on this page, and the date noted on this page will be updated. If a revision is material, the change will be identified on the Site. Your continued use of the App or the Site after a revised Policy is posted constitutes your acknowledgment of the revision.

16. Contact

16.1 Contact. For questions about this Policy or to exercise any right described in it, contact the Developer at keyu@gacing.com. Requests under this Policy are accepted in any language.