For any privacy question, data-subject request, or complaint, contact us at [email protected]. We will respond within 30 days.
We collect only the personal data needed to operate, secure, and improve the Service. The categories below describe what we collect and why.
| Category | Examples | Source |
|---|---|---|
| Account data | Email address, hashed password, display name, membership level and expiry | You, at registration |
| Exam content & answers | Your listening/reading/writing answers, selected options, written responses | Generated by you during practice or mock exams |
| Voice recordings | Audio recordings of your speaking-section responses | Captured with your consent during speaking tasks |
| AI scoring & feedback | AI-generated scores, evaluations, and feedback produced for your responses | Generated by the Service |
| Usage & technical data | IP address, browser type, device type, pages visited, timestamps, exam attempts, feature usage | Collected automatically |
| Support communications | The contents of emails or messages you send us | You |
We do not collect, store, or process payment card data. See Section 5.
We use your personal data to:
As the Operator is based in the People's Republic of China, our processing is primarily governed by the PRC Personal Information Protection Law (PIPL). For users located in other regions, we also respect applicable regimes such as the EU/UK GDPR and California CCPA/CPRA.
We process your personal data under the following bases:
For residents of California: we do not "sell" or "share" personal information as those terms are defined by the CCPA/CPRA. For EU/UK residents: you may withdraw consent and object to processing based on legitimate interests as described in Section 10.
All payments are processed by our Merchant of Record, Waffo Pancake. Card numbers, card verification codes, and other sensitive payment credentials are handled exclusively by Waffo Pancake (and its PCI-DSS certified payment service providers) and are never transmitted to or stored on our servers. We only receive from Waffo Pancake the minimum information needed to identify your order and activate your membership (for example, order ID, amount paid, and payment status).
We share personal data only with the following categories of processors:
| Processor | What they do | What they receive |
|---|---|---|
| Waffo Pancake (Merchant of Record) | Processes payments, taxes, refunds | Payment data; order metadata |
| Third-party AI model providers | Generate AI scores and feedback for your writing and speaking responses | Your written responses and voice recordings, as needed to produce the score/feedback |
| Cloud hosting & CDN providers | Host the Service and deliver static assets | Account data, exam content, usage data, technical logs |
| Email delivery provider | Transactional and support email | Email address and message contents |
Our subprocessors are bound by data-protection terms. The current list of named providers is available on request at [email protected]. We will notify you in advance of any new category of subprocessor that handles your personal data.
Your personal data may be processed in countries other than your own, including by the third-party AI providers and cloud-hosting services described in Section 6. Because the Operator is based in the PRC, transfers of personal information out of mainland China are subject to PIPL cross-border transfer requirements, and we will only transfer the minimum data necessary to provide the Service to you.
Where required by law, we put in place appropriate safeguards (such as standard contractual clauses or equivalent transfer mechanisms) for cross-border transfers.
We retain your personal data only as long as necessary for the purposes described in this Policy:
When data is no longer needed, we delete it or render it irreversibly anonymous. If you would like your data deleted sooner, see Section 10.
The Service uses only essential cookies and browser storage needed for authentication and basic functionality (such as keeping you logged in and remembering your exam progress). We do not use advertising, cross-site tracking, or third-party marketing cookies. We do not sell data derived from cookies.
Depending on where you live, you may have the right to:
To exercise any of these rights, contact us at [email protected]. We will verify your identity using reasonable means and respond within 30 days. If you are not satisfied with our response, you may complain to your local data-protection authority.
The Service is intended for users aged 18 and older and is not directed at minors. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact [email protected] and we will delete it.
We use reasonable administrative, technical, and physical safeguards — including encryption of credentials in transit and at rest, access controls, and regular reviews — to protect your personal data. No method of transmission or electronic storage is completely secure, however, and we cannot guarantee absolute security.
If we become aware of a personal-data breach affecting you, we will notify you and the relevant authorities as required by applicable law.
We may update this Privacy Policy from time to time. For material changes we will notify you by email or in-product notice at least 14 days before the new policy takes effect. The "Effective Date" at the top of this page indicates when the current version took effect. Continued use of the Service after the effective date constitutes acceptance of the updated policy.