Privacy Policy

1. Introduction

The Smart Language ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our language teaching and learning platform.

This policy applies to all users of our Service, including individual learners, teachers, educational institutes, and administrators. Our data is processed in Europe and we comply with the General Data Protection Regulation (GDPR).

2. Information We Collect

Account Information

When you create an account, we collect:

• Name and email address
• Account type (student, teacher, institute administrator)
• Institute affiliation (if applicable)
• Payment information (processed securely by our payment processor)

Authentication is handled by Clerk, our third-party authentication provider. Your login credentials are managed securely by Clerk in accordance with their privacy practices.

Learning Data

As you use our platform, we collect:

• Language preferences and target certifications
• Proficiency level (A1-C2) and learning goals
• Exercise responses and test submissions
• Speaking recordings (audio) for AI evaluation
• Writing submissions for AI evaluation
• Progress data, scores, and performance analytics
• Time spent on exercises and engagement patterns

Teacher & Institute Data

For teachers and institute administrators, we additionally collect:

• Class and student roster information
• Assignment configurations and custom content
• Grading overrides and feedback provided
• Analytics preferences and report configurations
• Institute name and contact details

Technical Data

We automatically collect:

• Device information (type, operating system, browser)
• IP address and approximate location
• Usage patterns and feature interactions
• Error logs and performance data

3. How We Use Your Information

We use the collected information for:

Providing Our Services

• Delivering personalized exercises and learning paths
• Processing AI-powered speaking and writing evaluations
• Generating progress reports and performance analytics
• Enabling teacher-student interactions and feedback
• Providing mock tests and exam preparation resources

Platform Operations

• Processing payments and managing subscriptions
• Communicating about your account, updates, and support
• Analyzing usage patterns to improve our platform
• Ensuring security and preventing fraud
• Complying with legal obligations

For Institutes

• Generating institution-wide analytics and reports
• Identifying at-risk students through engagement alerts
• Supporting teacher coaching with confidence logs
• Enabling data export for institutional reporting

4. AI Processing & Transparency

Our platform uses artificial intelligence extensively. We are committed to transparency about how AI processes your data:

What AI Processes

• Audio recordings for pronunciation, fluency, and content evaluation
• Written responses for grammar, vocabulary, coherence, and task completion
• Learning patterns to generate personalized recommendations
• Performance data to identify areas for improvement

Important Disclosures

• All assessments are AI-generated unless a teacher explicitly overrides them
• For practice only — our evaluations are educational tools, not official certifications
• No official standing — results should not be used for employment, immigration, or academic decisions
• Limitations apply — AI assessments may not perfectly reflect official exam outcomes

Data Not Used for Training

We do not use your data to train AI models. Your submissions are processed in real-time for evaluation purposes only and are not retained for machine learning training.

5. Data Sharing

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

• Your Institute: If you are a student or teacher within an institute, your learning data and progress may be visible to authorized administrators and teachers within that organization
• Authentication Provider (Clerk): For secure account management and login
• Payment Processors: For secure payment processing
• Cloud Service Providers: For hosting and data storage (EU-based)
• AI Service Providers: For processing evaluations (data is not retained by these providers)
• Legal Requirements: When required by law or to protect our rights

6. Institute Data Responsibilities

For educational institutes using our platform:

• The institute acts as the data controller for student data within their organization
• We act as a data processor, processing data on the institute's behalf
• Institutes are responsible for obtaining appropriate consents from students and parents (where applicable)
• Student data belongs to the students and their institute; we facilitate access, not ownership
• Institutes may request data export or deletion for their entire organization

7. Data Security

We implement robust security measures to protect your data:

• Encryption of data in transit (TLS) and at rest
• Secure authentication via Clerk (third-party authentication provider)
• Role-based access controls
• Regular security assessments and monitoring
• EU-based data processing and storage

8. Your Rights (GDPR)

Under GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate personal data
• Erasure: Request deletion of your personal data
• Portability: Receive your data in a structured, machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to certain processing activities
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at privacy@thesmartlanguage.com.

9. How to Request Data Deletion

To request deletion of your data, email us at delete@thesmartlanguage.com with:

• Subject line: "Data Deletion Request"
• The email address associated with your account
• Your full name (as registered)
• Whether you want full account deletion or specific data removal
• For institutes: specify if the request covers the entire organization

We will process your request within 30 days and send confirmation once complete.

10. Data Retention

We retain your data for as long as your account is active or as needed to provide services:

• Account data is deleted within 30 days of account closure request
• Learning data and progress records are deleted with your account
• Audio and text submissions are processed in real-time and not stored long-term
• Payment records are retained as required by law (typically 7 years)
• Anonymized analytics may be retained indefinitely for platform improvement

12. International Transfers

Your data is processed primarily in the European Union. Any transfers outside the EU are done with appropriate safeguards, including Standard Contractual Clauses where applicable.

13. Children's Privacy

Our Service may be used by students under 16 when provided through an educational institute. In such cases:

• The institute is responsible for obtaining necessary parental consents
• We process student data only as directed by the institute
• Parents may contact the institute to exercise rights on behalf of their children

Individual accounts require users to be at least 16 years old.

14. Changes to This Policy

We may update this Privacy Policy periodically. We will notify users of material changes via email or through the Service at least 30 days before changes take effect. Continued use after changes constitutes acceptance.