Privacy Policy

Effective date: 1 November 2026 (previous version: 29 September 2026) · Datgel Asia Pte. Ltd. (UEN 201132358H)

We build apps that families — including children — use every day, so protecting personal data is at the heart of how we work.

This Privacy Policy explains how Datgel Asia Pte. Ltd. (“Datgel”, “we”, “us” or “our”) collects, uses, discloses and protects personal data when you use the Datgel consumer application through which you reached this Policy, together with its related website and online services (each an “App” and, together, the “Service”). We handle personal data in accordance with Singapore’s Personal Data Protection Act 2012 (PDPA), and we apply comparable protections wherever your data is processed.

By creating an account or using the Service, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not use the Service.

Who we are

The Service is operated by:

• Datgel Asia Pte. Ltd. (UEN 201132358H)
• Registered office: 1 North Bridge Road, #08-08, High Street Centre, Singapore 179094
• Data protection contact / Data Protection Officer: hello@zenreader.co

For personal data collected through the Service, Datgel is the organisation responsible for that data (the data controller).

A note for families (the short version)

• Only an adult can create an account. Where an App supports families, adults add members — which may include children (“readers”).
• Some of our apps use the device microphone. For example, an App that helps a child practise reading aloud records the reader’s voice so it can check the reading and so authorised family members can play it back.
• We use the data we collect only to provide the Service and, if you opt in, to send you occasional Zen Reader news — never to sell your data, never for third-party advertising, and never to build advertising profiles of you or your children.
• A family’s data stays within the family, except with the service providers named below and with a teacher the family manager chooses to link to a child.
• You are in control: you can review, correct or delete your content and accounts at any time — see Your rights and choices and our delete-your-account page.

Personal data we collect

Depending on the App and the features you use, we may collect the following categories of personal data:

• Account & family data — the email address used to sign in, display name, and (where the App supports families) family name, roles, and invitations you send or accept, together with authentication data (secure session tokens; any PIN/biometric settings are stored only on your device). You can sign in with a one-time code sent to your email, with a password (which our authentication provider stores only in a protected, hashed form), or with your Apple, Google or Microsoft account — in which case that company confirms it is you and shares your email address (and may share basic profile details such as your name) with us; we never receive your password for that account.
• Teacher links — where the family manager links a teacher to a child, the teacher’s email address and account, which child they are linked to, and when the link was made or ended (see Sharing with a teacher).
• Member (including child) profile data — a display name and role for each member you add, and the activity generated by their use of the App. A member’s email is only used where you choose to give them their own sign-in.
• Content you provide — the files, documents, text and images you import, scan or create in the App (for example PDFs or photos), and any titles, notes or metadata you add.
• Voice recordings — where an App records audio (for example, of a reader reading aloud), the recording captured through the device microphone, together with any resulting transcript, scoring and session results.
• Usage, device & diagnostic data — app version, operating system, device type, feature-usage events (such as opening an item or starting a session), app-usage sessions and how long they last, and crash reports and error logs. We keep these to a minimum. By default they are not linked to you; if the family manager turns on Share anonymous app-usage data, we associate them with an identifier for your family (and the signed-in member) so we can understand how the App is used and whether readers improve — see Product analytics and improving the Service.
• Device identifiers — when you sign in, we record an identifier for each device you use the App on, together with the device’s make and model, so that you can see your signed-in devices, remove one you no longer use, and so we can apply the limit on how many devices your plan covers. Where you turn on push notifications, our notification provider also creates an identifier for that device so it can deliver them. These are not advertising identifiers: we do not collect the Advertising ID, and we never use any identifier to advertise to you, to target ads, or to track you across other apps or websites.
• Payment data — for paid plans, our payment provider processes your card or payment details; we never receive or store your full card number or security code. We receive your subscription status and a reference for each payment. For a card payment we also receive, and keep, the first digits of the card number (which identify the card’s issuer, not you), the name of the bank that issued the card, the country where it was issued and the card’s billing country, because tax law requires us to keep evidence of the country a customer is in (for example, the EU VAT rules on where a digital service is supplied). Where you give them to us, we also keep the billing details needed to issue a valid receipt or tax invoice — the account holder’s first and last name, billing address, country and phone number.
• Communications — the content of support requests, feedback and other correspondence you send us, including any screenshots you attach, and your conversations with our in-app assistant, Jas.
• Email preferences — whether you have opted in to Zen Reader news emails, and when you did so or opted out.

We collect this data directly from you when you set up an account, add content, use the App’s features, subscribe, or contact us.

Children’s data

Where an App is intended for or used by children, it is designed to be set up and managed by a parent, guardian or other responsible adult. We do not knowingly allow a child to create an account on their own.

• Consent. A child’s profile and activity are created by the adult who manages the family. By adding a child and using features that collect their data (such as recording their reading), you confirm that you are the child’s parent or guardian (or are otherwise authorised) and that you consent, on the child’s behalf, to the collection and use of their data as described in this Policy.
• What we collect about a child. A display name, any recordings and transcripts, scores, progress history and achievements, and the content assigned to them.
• How it is used. Only to run the App’s features, to let authorised members of the same family view progress, and to let a teacher the family manager has linked to that child see the child’s work (see Sharing with a teacher). Children’s data is never sold, never used for advertising or ad-targeting, and never disclosed to anyone else except the service providers listed below that help us operate the Service.
• Analytics about a child. If the family manager turns on Share anonymous app-usage data, limited usage and diagnostic events are linked to your family and its members so we can measure how the App is used and whether readers improve. This is off by default, is covered by the parental consent above, is never used for advertising or ad-targeting, and never shares a child’s recordings, the content they read, their profile details or their school marks with our analytics provider — only usage events and, at most, coarse anonymised segments (such as an age band). See Product analytics and improving the Service.
• Access is limited to the family — and to a teacher only if you choose. A family’s data is private to that family. Family managers can review members’ activity; other roles see only what their role permits. A teacher sees a child’s work only if the family manager links that teacher to that child, and never sees anyone else in the family.
• Deletion. You can remove an individual recording, an item, a member profile or the whole family at any time (see Your rights and choices).

If you believe a child’s data has been provided to us without the consent of a parent or guardian, please contact hello@zenreader.co and we will delete it promptly.

Sharing with a teacher

Where an App supports it, the family manager can link a teacher to a child — either by inviting the teacher’s email address or by approving a request the teacher sends. Nothing is shared with a teacher unless the family manager does this. The teacher needs their own account.

• What the teacher sees. That one child’s work in the App: their reading sessions, results and recordings; spelling, handwriting and composition work, including photos of it; listening and Oral Practice sessions and feedback; word-list and flash-card results; school marks; notes shared with them; and the books that child has worked on. The teacher can add their own notes, corrections, marks and tasks for the child.
• What the teacher does not see. Anyone else in your family (including your other children), your family’s other books, the child’s email address, your account and billing details, or your family’s settings.
• Emails. We email the teacher your invitation, or email you the teacher’s request; these name the child and the person who asked.
• Ending it. The family manager can remove a teacher at any time in the App, and the teacher loses access to the child’s work straight away. A teacher also loses access while their own subscription has lapsed.

How and why we use personal data

We use personal data to provide and improve the Service, on the following bases:

• To provide the App’s features — for example, where an App assesses reading aloud: recording a reading, converting speech to text, comparing it against the source text, scoring it, and saving the results so your family can review them.
• To operate your account and family — signing you in, keeping you signed in across launches, managing invitations, roles and devices, and syncing your content across your devices.
• To process payments — managing subscriptions, renewals and receipts for paid plans.
• To support you — responding to requests, sending service notices (such as invitations, security or account messages) and, where enabled, reminders and other in-app notifications. We use an AI assistant to help sort support requests, as described under Service providers and disclosure.
• To send you Zen Reader news, only if you opt in — occasional emails about new features, reading tips and offers, no more than about once a month. They go only to adults who have said yes (by ticking the option, which is never pre-ticked, or answering yes to our one-off email asking whether you would like them), every one carries an unsubscribe link, and you can also turn them off in your account. Children are never sent them, and we never use them to build advertising profiles.
• To meet our legal obligations — for example keeping tax records, receipts and the evidence of a customer’s country that tax law requires for card payments.
• To keep the Service safe and reliable — diagnosing problems, preventing abuse and securing accounts.
• To improve the Service and measure learning effectiveness — understanding which features are used and whether readers actually improve over time, so we can make our apps better and focus on what genuinely helps children read. In aggregate this uses de-identified usage data; where the family manager consents, it also uses usage data linked to your family and its members — never your recordings or the content of what you read. See Product analytics and improving the Service.

Where the PDPA requires consent, we rely on the consent you give when you set up and use the Service (and the parental consent described above for children’s data). You may withdraw consent as described below, though doing so may mean we can no longer provide parts of the Service.

Recordings, content and AI processing

Because some of our apps listen to a microphone or process the content you provide, we want to be clear about what happens to it:

• Transcription. On devices that support it, speech-to-text runs on your device, with one exception: a long recording (for example, a whole-book reading) that would take many minutes to process locally may instead be sent securely to our speech-to-text provider, and you can turn that off in the app’s settings to keep all speech-to-text on the device. On other devices, a recording is sent securely to our speech-to-text provider. In every case where a recording is sent, it is used solely to produce the transcript, and is not used by that provider to train its models. Our speech-to-text provider is named under Service providers and disclosure. On Apple devices, “on your device” means Apple’s own speech recogniser, which Apple may run on its own servers under Apple’s privacy terms when the device lacks the language it needs.
• Storage & playback. Recordings and content are stored in your family’s private cloud storage so that authorised family members can access them and review progress. You can delete them at any time.
• AI helpers. When you use optional AI helpers (for example text polishing, translation, metadata enrichment or optical character recognition), the relevant text or image is sent to our AI or processing provider only to return the requested result, and is not used to train third-party models. The features that use AI, and what each one sends, are:
  • Comprehension questions — the text of the page or pages your child has just read, with the book’s title and reading level, is sent to Anthropic to write multiple-choice questions. Your child’s answers are marked in the App and kept in your family’s account; they are not sent to Anthropic.
  • Composition feedback — photos of the pages of your child’s handwritten composition are sent to Anthropic to read the handwriting. Your child checks, and can correct, the text it read; that text, with the composition’s title and your child’s school year, is then sent to Anthropic for feedback. The photos are kept in your family’s private cloud storage.
  • Oral Practice — your child talks with Jas, our in-app assistant, about a book. Each spoken answer is turned into text on your device where the device can do that; otherwise a recording of it is sent to Groq to be transcribed. Where an answer is recorded, the recording is kept in your family’s private cloud storage so the family (and a linked teacher) can play it back. The text of the conversation — and, for picture-description practice, the picture from the book page — is sent to Anthropic so Jas can reply and give feedback at the end, and Jas’s replies may be spoken by a cloud voice from Microsoft.
  • Ask Jas — the messages and files you send to Jas are sent to Anthropic to write Jas’s replies, and Jas’s spoken replies use a cloud voice from Microsoft. Conversations are stored on our servers so you can come back to them, and when a conversation ends a copy is emailed to our team so we can check the quality and safety of Jas’s answers and fix problems.
  • Reading text off a page, translation, book details, handwriting and test marking, and homework help — the page image or text concerned is sent to Anthropic, Google or Microsoft, as listed under Service providers and disclosure.
• Your choice and consent. Sending your family’s content to the AI providers named under Service providers and disclosure is off until you allow it. The first time a feature needs it, the App asks the family manager — naming what would be sent, who would receive it and where they are — and sends nothing unless they agree. That decision covers the whole family, and the family manager can change it at any time under AI features in the App’s Settings. While it is off, the App reads text and transcribes speech on your own device where it can, and the features that have no on-device equivalent are simply unavailable.
• No advertising or model-training on your content. We do not use your or your child’s content to serve ads, and we do not permit our providers to use it to train their AI models.

Product analytics and improving the Service

To make our apps better and to understand whether Zen Reader actually helps children read, we collect product-analytics data about how the App is used. We want to be clear about what this is, and about your control over it.

• What we collect. Feature-usage events (for example opening a book, starting an assessment or moving to the next page), app-usage sessions and how long they last, and error and crash diagnostics. We do not collect the words a reader reads, their recordings, or the content of your books for this purpose.
• Linking to your family. With the family manager’s consent (see below), we associate these events with an identifier for your family and for the signed-in member, so we can measure how a family uses the App and whether its readers improve over time. Without that consent, this data is collected only in a de-identified, aggregate form.
• Reader profile and school marks. Where you choose to provide them, details such as a reader’s age, their exposure to the language, and self-reported school assessment marks help us understand which reading habits help most. This detailed information is kept in your family’s private, access-controlled cloud store and is not sent to our analytics provider; at most, coarse anonymised segments (for example an age band) may be used in analytics.
• Why we do this. Only to improve the App and to measure learning effectiveness — what works and what doesn’t — so we can help children read with more confidence.
• What we never do. We do not sell this data, we do not use it for advertising or third-party ad-targeting, and we do not use it to train AI models.
• Where it is held. This analytics is processed using Microsoft Azure Application Insights (a Microsoft Azure service). It may be transferred and stored outside Singapore (see International transfers) and is kept only for as long as described under Retention before it is deleted or anonymised.
• Website statistics (this website, not the App). On zenreader.co we use Cloudflare Web Analytics to count page visits and see which pages people find useful. It is cookie-free: it sets no cookies, does not track you across other websites, does not build a profile of you, and does not collect personal data — only aggregate figures such as page views, referring site, country and browser type. Because it collects no personal data, it needs no consent and there is nothing to opt out of; it is entirely separate from the App analytics described above.
• Your choice and consent. Linking app-usage data to your family is off by default. It is controlled by the setting called Share anonymous app-usage data in the App’s Settings, and is turned on only when the family manager — the responsible adult for the family — gives consent, which also covers the children in that family. Because Zen Reader is available worldwide, we apply this parental-consent approach consistently with Singapore’s PDPA guidance on children’s personal data and with comparable children’s-privacy rules elsewhere (such as the EU General Data Protection Regulation, the UK Age Appropriate Design Code, and the US Children’s Online Privacy Protection Act).
• How to opt out or delete. The family manager can turn Share anonymous app-usage data off at any time in the App’s Settings, which stops any further linking of app-usage data to your family. To ask us to delete analytics we have already collected, email hello@zenreader.co (see Your rights and choices).

Service providers and disclosure

We do not sell personal data and we do not disclose it except as set out here and under Sharing with a teacher. To run the Service, we share personal data with trusted service providers, only to the extent needed and under contracts that require them to protect it. The providers we use, and what each is for, are set out below; depending on the App and the features you use, not all of them will apply to you. If we engage a new provider, we update this list — see Changes to this Policy.

• Cloud database, authentication and file storage providers (such as Supabase) — for your account data, content and recordings and backend functions.
• Speech-to-text provider (Groq, Inc., United States) — for converting a recording to text in the cases described under Recordings, content and AI processing, where the transcription does not run on your own device — a child reading aloud, or speaking in Oral Practice. Recordings sent for transcription are used solely to produce the transcript.
• AI and OCR providers (Anthropic, Google Cloud Vision and Microsoft Azure AI Vision and Azure Speech) — for optional text- and image-processing helpers, such as translation and reading aids, reading the text off a page you photograph or scan, marking handwriting, filling in a book’s details, homework help, comprehension questions, composition feedback, Oral Practice conversations and feedback, and the in-app assistant and its spoken replies.
• Analytics and diagnostics providers (such as Microsoft Azure Application Insights) — for diagnostics, crash reporting and app-usage data; aggregate and de-identified by default, or linked to your family where the family manager consents (see Product analytics and improving the Service).
• Website analytics and advertising-measurement providers (Cloudflare Web Analytics, and Google Analytics, Google Ads and Meta where you accept them) — for understanding how our website is used and whether an advertisement brought you here; see Cookies and our website.
• Notification providers (such as OneSignal, Apple and Google) — for push notifications where you enable them.
• Email providers (such as Twilio SendGrid) — for account and service emails (such as sign-in codes, invitations and teacher links) and, if you opt in, Zen Reader news.
• Business email and support tools (Microsoft 365, and our support desk, Atlassian Jira Service Management, which we run ourselves on Microsoft Azure) — for receiving and handling the support requests, feedback and other correspondence you send us, and for the copies of Ask Jas conversations our team reviews.
• AI help with support requests (Anthropic) — we use an AI assistant to read new support requests, including any screenshots attached, and sort them: for example, whether a request is a question, a problem or a suggestion, and which of our own work items it belongs to. It does not reply to you, does not change your account and does not decide your request; a member of our team handles every request. Where a request reports a problem in the App, the AI may also help us prepare a fix, which a person reviews before it is used.
• Payment providers (such as Airwallex, or the applicable app store) — for processing paid plans. For a card payment, Airwallex also tells us the card’s first digits, issuing bank and issuing country, which we keep as tax evidence (see Payment data above).
• Accounting and invoicing providers (Xero) — for issuing receipts and tax invoices for paid plans, and for our own accounting records. This receives the account holder’s billing details (name, email address, and any billing address, phone number and country given to us) and what was bought; it never receives a reader’s profile, recordings, transcripts or results.
• App distribution and hosting providers (such as the Apple App Store, Google Play, Microsoft Azure and Cloudflare) — for distributing the App and hosting our website.

We may also disclose personal data where required to comply with a law, regulation, court order or lawful request from an authority; to enforce our terms; to protect the rights, safety or property of Datgel, our users or others; or in connection with a merger, acquisition or sale of assets, in which case we will require the recipient to honour this Policy.

International transfers

Datgel is based in Singapore, and some of our service providers store or process data in other countries (including the United States and the European Union). Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient is bound to provide a standard of protection comparable to the PDPA — for example, through contractual commitments with our providers.

Retention

We keep personal data only for as long as needed to provide the Service to you and for the purposes described in this Policy, and then we delete or anonymise it. If you delete content or an account, we remove it from active systems, except for the books in your library described below; residual copies in encrypted backups are purged on our normal backup-rotation cycle. We may retain limited records where we are legally required to do so (for example, billing records), after which they are deleted.

When a subscription ends. If your subscription or free period ends and is not renewed, we keep your family’s data for three months from that date so you can download it or pick up where you left off. During that time the Family Manager can export everything — every reading, spelling and word-list record as spreadsheets, plus every recording, photo and scan — from zenreader.co/export. We email the Family Manager when the subscription ends, again a month before the deadline, and again a week before it, and each message names the exact date.

After that date we delete the family’s data from our live systems, and it cannot be recovered. Residual copies in encrypted backups are purged on our normal backup-rotation cycle. Subscribing again before the deadline stops the deletion and leaves everything exactly as it was. You can also ask us to delete your data sooner at any time — see delete your account.

Files you send to the in-app assistant. When you send a file to Ask Jas — usually a photograph or a scan of a worksheet — we keep that file for 90 days from the day you send it, and then we delete it. The conversation itself stays in your history; once a file has been deleted, the message that carried it will say the file is no longer available. You do not have to wait for that date: deleting a conversation deletes the files sent in it straight away.

Books you delete or change. So that a mistake can be undone, when a book or a page in your family’s library is deleted, edited or given a new picture, we keep its earlier version (its text, pinyin, translations and pictures) for 180 days. During that time a Family Manager or Parent can put it back in the App with Restore…. After 180 days the earlier version is deleted. A book that someone has already used (read, spelled, tested or practised from) is not erased when you delete it. It is hidden from the library and kept with your child’s results, so that they still make sense, until you restore it from Settings → Deleted books or delete your family’s account. When your family’s account is deleted, including the deletion after a subscription ends described above, all of this is deleted with it.

App-usage and diagnostic data. The usage events and diagnostics described under Product analytics and improving the Service are kept in Microsoft Azure Application Insights for 90 days in a form we can search (crash and error reports for two years). After that they are moved to lower-cost archive storage, where they are kept for up to 12 years in total from when they were collected, and then deleted. To ask us to delete analytics linked to your family sooner, email hello@zenreader.co.

Card payment evidence. The card details we keep as evidence of a customer’s country (see Payment data) are kept for 10 years from the end of the year of the payment, because tax law requires it.

Security

We use reasonable technical and organisational measures to protect personal data, including encryption in transit, encrypted storage of sensitive credentials on your device, access controls that keep each family’s data private to that family (and to any teacher it chooses to link to a child), and secure, reputable cloud infrastructure. No method of transmission or storage is completely secure, but we work to protect your information and to respond quickly if a problem arises.

Data breach notification

If a data breach occurs that is likely to result in significant harm to affected individuals or is of a significant scale, we will notify the Personal Data Protection Commission (PDPC) and affected individuals as required by the PDPA.

Your rights and choices

Under the PDPA, you may:

• Access the personal data we hold about you and ask how it has been used;
• Correct inaccurate or incomplete personal data;
• Withdraw consent to our collection, use or disclosure of personal data; and
• Delete your data or account.

You can do much of this yourself inside the App — edit your profile and family, remove content and recordings, or manage devices and notifications. To make a formal access, correction, withdrawal or deletion request, email hello@zenreader.co from the address you use to sign in, or follow the steps on our delete-your-account page. We will respond within the timeframes required by the PDPA. If you are unhappy with how we handle your request, you may contact the PDPC (pdpc.gov.sg).

Cookies and our website

Our apps do not use advertising cookies or tracking cookies, and we never serve third-party advertising on our website.

Cookies we set without asking. Our website uses the cookies and local storage necessary for the site to function and, where applicable, to keep you signed in to your account. We also use Cloudflare Web Analytics to count visits — it is cookieless and does not collect personal data or build a profile of you, so it needs no consent.

Cookies we ask about first. We would also like to use Google Analytics to understand how the website is used, and advertising cookies from Google and Meta to see whether an advertisement brought you here, so we know which advertisements are worth paying for. These set cookies (such as _ga, _gcl_au and _fbp) and are optional: we ask you first, and they stay switched off — setting no cookie and sending no data that identifies you — unless you accept. The website works exactly the same either way. We do not use them to build advertising audiences, to show you personalised or retargeted advertising, or to follow you across other websites, and we never use anything your family does inside the app for advertising. Google LLC and Meta Platforms act as our service providers for this and may process the data outside Singapore (see International transfers).

Changing your mind. Select Cookie preferences at the foot of any page to accept or decline at any time. Declining also deletes any analytics or advertising cookies already set. Most browsers additionally let you block or delete cookies through their own settings.

Links to other websites

The Service may contain links to third-party websites. We are not responsible for the privacy practices of those sites; we encourage you to read their privacy policies. This Policy applies only to the Service.

Changes to this Policy

We may change this Policy from time to time — for example to reflect new features, new service providers, or changes in law or our practices. We reserve the right to update it at any time. When we make a material change, we will take reasonable steps to notify you before it takes effect — for example by posting a notice in the App, updating the effective date at the top of this Policy, and/or emailing the address associated with your account. Your continued use of the Service after a change takes effect means you accept the updated Policy. If you do not agree to a change, please stop using the Service and, if you wish, delete your account.

Contact us

For any question about this Policy or your personal data — including access, correction or deletion requests — contact our data protection contact at hello@zenreader.co, or write to Datgel Asia Pte. Ltd., 1 North Bridge Road, #08-08, High Street Centre, Singapore 179094. We aim to respond within a reasonable time and in any case as required by law.