Privacy Policy

1. Scope and Role

This Privacy Policy explains how FluentExam ("FluentExam," "we," "us," or "our") collects, uses, stores, and shares information when you access or use our website, Platform, practice exams, and related services (collectively, the "Services").

FluentExam is responsible for personal information processed in connection with the Services, except where third parties—such as Merchants of Record or payment providers—process data as independent controllers under their own privacy notices.

2. Information We Collect

2.1 Information You Provide

• Account information: name or identifier, email address, password, and optional profile details.
• Practice data: written answers, multiple-choice responses, exam selections, and study preferences.
• Audio recordings: your voice responses for speaking practice and related metadata.
• Communications: messages you send to support or feedback forms.

2.2 Payment Information

Purchases are processed by third-party Payment Partners or Merchants of Record. They collect and process payment details under their own terms. FluentExam receives limited transaction data (such as purchase amount and status) to allocate credits. We do not store full payment card numbers.

2.3 Information Collected Automatically

When you use the Services, we may collect:

• Device information (browser type, operating system, device identifiers).
• Usage data (pages viewed, time spent, features used, exam sessions, error logs).
• IP address and general location (city or region level).
• Cookies and similar technologies (session cookies, preferences, analytics tools).

3. How We Use Information

We use the information described above to:

• Operate, maintain, and improve the Platform and Services.
• Provide practice exams, scoring, feedback, and reports.
• Allocate and track credits and manage your account.
• Communicate with you about exam results, important updates, and support requests.
• Monitor for cheating, abuse, or security incidents.
• Comply with legal, tax, and payment-provider requirements.
• Analyze usage patterns to improve content, features, and user experience.

Where permitted, we may also use aggregated or anonymized data for analytics and product development.

4. Legal Bases (EU / EEA / UK)

If you are in the European Economic Area, United Kingdom, or a jurisdiction with similar data-protection laws, our processing relies on:

• Performance of a contract (providing the Services you request).
• Legitimate interests (improving Services, security, fraud prevention).
• Consent (for optional communications, certain analytics, or cookies where required).
• Legal obligations (tax records, accounting, compliance).

5. Data Retention

We retain personal information only for as long as reasonably necessary:

• Account data: retained while your account is active and for a reasonable period thereafter.
• Exam attempts and scores: retained to show historical performance and improve grading.
• Audio recordings: retained for 90 days, then permanently deleted.
• Payment records: retained in accordance with tax and accounting requirements.
• Support communications: retained for a limited period for quality and record-keeping.

6. Sharing of Information

We do not sell your personal information. We may share information with:

• Service providers supporting our operations (hosting, storage, analytics, email delivery).
• Payment Partners / Merchants of Record, which act as independent controllers of payment data.
• Grading staff or contractors, who may access responses for quality assurance.
• Legal and regulatory authorities, when required by law or to protect our rights.

7. International Transfers

The Services may be operated using infrastructure in multiple countries. Your information may be transferred to jurisdictions with different data-protection laws. When required, we implement appropriate safeguards to protect personal information.

8. Your Rights

Depending on your location, you may have rights such as:

• Access: request a copy of personal information we hold about you.
• Rectification: request correction of inaccurate or incomplete information.
• Erasure: request deletion of personal information.
• Restriction: request limitation on certain types of processing.
• Data portability: request transfer of your data in a structured format.
• Objection: object to processing based on legitimate interests or direct marketing.
• Withdrawal of consent: withdraw consent where processing is based on consent.

To exercise these rights, contact privacy@fluentexam.com.

9. Children's Privacy

The Services are not intended for children under 16. We do not knowingly collect personal information from children under 16.

10. Security

We implement technical and organizational measures to protect personal information, including encryption, secure password hashing, access controls, and monitoring. However, no online service can guarantee absolute security.

11. Cookies and Tracking Technologies

We use cookies to keep you logged in, remember preferences, and perform analytics. Where required by law, we will request your consent before placing non-essential cookies.

12. Changes and Contact

We may update this Privacy Policy from time to time. For questions or requests, contact privacy@fluentexam.com.