Privacy Policy

Personal Information

When you create an account, we collect:

• Name
• Email address
• Password (encrypted)
• Profile preferences

Practice Content

When you use our Service, we collect:

• Speaking recordings and transcripts
• Written essays and answers
• Reading and listening responses
• Practice session data and scores
• Progress and analytics data

Usage Information

We automatically collect:

• Device information (type, operating system, browser)
• IP address and location data
• Pages visited and features used
• Session duration and frequency
• Cookies and similar tracking technologies

Payment Information

Payment information is processed by Airwallex. We do not store complete credit card details. We only retain:

• Last 4 digits of card
• Payment method type
• Billing history

We use your information to:

• Provide the Service: Process your practice sessions, generate feedback, track progress
• Improve our AI: Train and improve our AI models using anonymized practice data
• Personalize experience: Recommend study materials, identify weak areas
• Process payments: Handle subscriptions and billing
• Communicate: Send account updates, support responses, important notices
• Ensure security: Detect fraud, prevent abuse, protect user accounts
• Comply with law: Meet legal obligations and respond to legal requests
• Analytics: Understand usage patterns and improve the Service

For users in the EU/EEA, we process your data based on:

• Contract performance: To provide the Service you signed up for
• Consent: When you explicitly agree (e.g., marketing emails)
• Legitimate interests: To improve our Service, prevent fraud, ensure security
• Legal obligations: To comply with applicable laws and regulations

We Share Data With:

We DO NOT:

• Sell your personal information to third parties
• Share your practice content publicly without permission
• Use your data for purposes other than stated here

We implement industry-standard security measures:

• Encryption in transit (HTTPS/TLS)
• Encryption at rest for sensitive data
• Secure authentication (bcrypt password hashing)
• Regular security audits
• Access controls and monitoring
• Cloudflare DDoS protection

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

We retain your data:

• Account data: Until you delete your account
• Practice content: As long as your account is active
• Anonymized data: Indefinitely for AI training and analytics
• Payment records: 7 years for tax and legal compliance
• Logs: 90 days for security and debugging

After account deletion, we may retain anonymized data for research and AI improvement.

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Portability: Receive your data in a structured, machine-readable format
• Restriction: Request limitation of processing in certain cases
• Object: Object to processing based on legitimate interests
• Withdraw consent: Withdraw previously given consent at any time
• Opt-out: Unsubscribe from marketing communications

How to Exercise Your Rights

To exercise any of these rights, contact us at [email protected]

We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

We use cookies and similar technologies for:

• Essential: Authentication, session management, security
• Functional: Remember your preferences and settings
• Analytics: Understand how you use the Service (anonymized)
• Performance: Monitor service performance and errors

Managing Cookies

You can control cookies through your browser settings. Disabling essential cookies may affect functionality.

We operate globally through Cloudflare's network. Your data may be processed in countries outside your residence, including the United States.

For EU users, we ensure adequate protection through:

• Standard Contractual Clauses (SCCs)
• Service providers with adequate data protection
• Encryption and security measures

Our Service is not intended for children under 13. We do not knowingly collect data from children under 13.

Users aged 13-17 should have parental consent to use the Service.

If you believe we have collected data from a child under 13, contact us immediately at [email protected]

Our Service may contain links to third-party websites or services. We are not responsible for their privacy practices. Please review their privacy policies.

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the new policy on this page
• Updating the "Last updated" date
• Sending an email notification for material changes

Continued use after changes constitutes acceptance of the new policy.

If you have questions or concerns about this Privacy Policy or our data practices:

• Email: [email protected]
• Support: [email protected]
• Data Controller: AI Creative Innovations Ltd
• Registration: BVI Company
• Address: Road Town, Tortola, British Virgin Islands