This English version is provided for reference. The Vietnamese version is the binding one. Read the Vietnamese version.

Thì Thầm Privacy Policy

Version 1.1. Effective: 30 October 2026

Thì Thầm ("the app") is published for Vietnamese speakers worldwide by ITGRATE VIETNAM LIMITED LIABILITY COMPANY (CÔNG TY TNHH ITGRATE VIỆT NAM, "we"). This policy explains how the app handles your data and what data we receive. In short: your voice and text are processed entirely on your phone and are never sent anywhere.

Data controller

• Company: CÔNG TY TNHH ITGRATE VIỆT NAM (English name: ITGRATE VIETNAM LIMITED LIABILITY COMPANY)
• Enterprise code (tax code): 0316879820, registered in Vietnam
• Registered office: 37 Hoàng Diệu, Xóm Chiếu Ward, Ho Chi Minh City, Vietnam
• Legal representative: Nguyễn Ngọc Bảo
• Personal data contact: dev@itgratevn.com

We are the personal data controller for the data listed under "Data we receive". This policy is written under Vietnam's Law on Personal Data Protection No. 91/2025/QH15 and Decree No. 356/2025/ND-CP.

Scope

This policy covers the Thì Thầm app on Android (Google Play) and iOS (App Store), in every country where the app is available. If you live outside Vietnam, the law where you live may give you additional rights. See "Your rights where you live".

Data the app processes on your phone

• Microphone audio: recorded only when you press the record button or tap the bubble. The audio stays in the app's memory for recognition. It is not saved to a file and is not sent anywhere.
• Transcripts: created on your phone. The list of transcripts stays in the app's memory and is gone when the app closes. The app does not save transcripts to a file or database.
• The content of the focused text field (Android only, when you turn on the "Thì Thầm: chèn văn bản" accessibility service): see Accessibility service below.
• Device information: RAM, free storage, chip type and CPU core count. The app reads these on the phone to recommend a model size and does not send them anywhere.

The app does not use your voice to identify who you are. It has no accounts, ads, analytics or crash reporting, it does not track you across other apps or websites, and it sends no personal data to us. We do not sell or share your personal data.

Data we receive

We receive personal data only in these two cases:

• When you email support at dev@itgratevn.com: we receive your email address, display name, the message and anything you choose to attach. We use it only to answer you and fix the problem you report. By sending the email, you agree to us processing it for that purpose. You can withdraw this consent at any time. We delete support emails no later than 24 months after the last exchange, unless the law requires us to keep them longer.
• If you buy the app or in-app content: Google Play or the App Store handles the payment under its own privacy policy. We do not receive your card or payment account details. We only receive transaction reports (order number, product, price, country and date of purchase), which we keep for 10 years as accounting records under Vietnam's Law on Accounting.

Legal bases

• Support emails: your consent when you send the email, and our legitimate interest in answering you and fixing the app.
• Transaction reports: our legal obligations for accounting and tax.

International transfers

We are based in Vietnam. If you live in another country and email us, your email is transferred to Vietnam. Emails are stored with our email provider, whose servers may be outside Vietnam. Transaction reports come from Google's or Apple's servers. Where Vietnamese law or the law where you live requires safeguards for these transfers, such as an impact assessment or standard contractual clauses, we put them in place.

Internet connection

The app uses the internet only to download the AI models (PhoWhisper and Qwen2.5) from Hugging Face (huggingface.co) when you choose to. As with any web download, Hugging Face receives your IP address and basic technical details of the connection, under its own privacy policy: https://huggingface.co/privacy. We do not receive this information, and no audio, text or personal information is sent with the download.

Accessibility service (Android only)

The Android app includes an optional accessibility service (AccessibilityService) named "Thì Thầm: chèn văn bản". It is off by default and only works after you turn it on yourself in Settings › Accessibility, after agreeing to the notice in the app. The iOS app has no such service.

• Its only purpose: insert the bubble's transcript into the focused text field of another app.
• What the service is allowed to do: like any accessibility service, once turned on, Android lets it see the content of windows on the screen and tells it when a text field gets focus.
• What it actually reads: only the content and cursor position of the focused text field, only at the moment the text is inserted. It does not read or keep any other screen events or content.
• Password fields are always skipped.
• What it reads is not stored, not logged and not sent anywhere.
• You can turn the service off at any time in Settings › Accessibility. When it is off, the transcript is copied to the clipboard instead.

Clipboard and notifications

When you tap Copy, or when the bubble cannot insert the text, the transcript is put on the phone's clipboard. Other apps, such as your keyboard, can read the clipboard as the operating system allows. On Android, while the bubble runs, the app's notification shows a short preview of the latest transcript. Depending on your notification settings, it can appear on the lock screen.

Permissions the app requests

• Microphone (Android and iOS): records your voice for recognition.
• Internet and network state: downloads the AI models.
• Display over other apps (Android, SYSTEM_ALERT_WINDOW): shows the recording bubble.
• Foreground service with the microphone type, and notifications (Android): keeps the bubble running and tells you when it is running.
• Accessibility service (Android, optional): see above.

Data stored on your phone and how to delete it

The app only stores the AI model files you downloaded and the name of the active model. You can delete PhoWhisper models you no longer use in Settings › Change model (Cài đặt › Đổi mô hình). Uninstalling the app deletes all models, including the Qwen2.5 model, and all app data. The app does not back up data to the cloud.

Your rights

Under Vietnam's Law on Personal Data Protection, for the data we receive you have the right to:

• know how it is processed, and give or refuse consent;
• see it, and correct it or ask us to correct it;
• withdraw consent, and ask us to delete it or restrict its processing;
• ask us for a copy of it, and object to its processing;
• complain, report, sue and claim compensation as the law provides.

Send requests to dev@itgratevn.com. We answer within 30 days, or sooner if the law that applies to you requires it. We do not charge you and do not treat you differently for using these rights. Withdrawing consent does not affect processing done before, or data we must keep by law, such as accounting records. If you are not satisfied with how we handle your request, you can complain to the Department of Cybersecurity and High-Tech Crime Prevention (A05) of the Ministry of Public Security.

Your rights where you live

• European Union, European Economic Area, United Kingdom and Switzerland: you have the rights given by the GDPR, the UK GDPR or the Swiss Federal Act on Data Protection, including access, correction, deletion, restriction, a portable copy of your data, objection to processing based on legitimate interest, and withdrawal of consent. You can also complain to the data protection authority where you live or work.
• United States (including California): we do not sell personal information, do not share it for cross-context behavioral advertising, and do not use sensitive personal information. You can ask to know, access, correct and delete the personal information we received about you.
• Canada, Australia and other countries: you have the rights your local data protection law gives you, and you can complain to the competent authority there.

To use any of these rights, email dev@itgratevn.com.

Data security and breaches

Only staff who answer support or keep the accounts can access the data above. If a personal data breach happens, we notify the competent authorities and the people affected within the time limits the law sets.

Children

The app is not directed at children under 13, and it does not collect personal data from anyone, including children. If a child emails our support, we handle the data under the rules for children's personal data, including getting a parent's or guardian's consent where the law requires it. If we learn that we received a child's data without the consent required, we delete it.

Changes to this policy

When this policy changes, we update the version and effective date at the top, publish the new version at the policy's public address, and include it in the next app release. The Vietnamese version is the legally binding one, unless the law where you live says otherwise. The English version is for reference.

Contact

ITGRATE VIETNAM LIMITED LIABILITY COMPANY (CÔNG TY TNHH ITGRATE VIỆT NAM), 37 Hoàng Diệu, Xóm Chiếu Ward, Ho Chi Minh City, Vietnam. Tax code: 0316879820. Email: dev@itgratevn.com