Privacy Policy

1. Who we are

TCKR Labs FZCO is a free zone company incorporated in the Emirate of Dubai, United Arab Emirates, with its registered place of business at Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates.

We are the data controller of the personal data described here, under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and, for users in the European Economic Area and the United Kingdom, the General Data Protection Regulation (the "GDPR").

2. What we collect

We collect only what the service needs. We never ask for or keep special categories of data (such as health or biometric data), government ID numbers or full card numbers.

• Account: your name and email address, which Google or Apple share with us when you sign in, and, if you add them, a username and a profile photo. We never see your Google or Apple password. If you sign in with Apple and hide your email, we only receive the address Apple gives us.
• Your learning: your answers, scores and times in practice exams, in simulated exams and in the exams the Exam Generator writes for you (with the topic you typed); your Writing texts and their corrections; your notes; the words you look up in the dictionary; your progress in the Lingo game (challenges, stars, XP, streaks, badges and daily gifts); and the statistics we work out from all of these.
• Purchases: the plan you bought, its status and dates, your AI credits and their movements, and the reference the payment provider gives us for each payment.
• Messages: what you send us through the support form or by email.
• Technical data: your IP address, browser or device type, operating system, language and time zone, and the logs our servers keep to run securely.
• In the apps: the notification token of each app you use, so it can receive its notifications.

3. What other learners can see

The Lingo game has leaderboards. Other learners of the same level can see your name (your first and last name, or your username if you have not given a name) and your profile photo next to your score. You can change both in your profile at any time. Nothing else about you is shown to other learners.

4. Why we use it

• To provide the service you signed up for (contract, Article 6(1)(b) GDPR): your account and sign-in, keeping your progress across devices and levels, marking your exams, PRO, AI credits, purchases and support.
• For our legitimate interests (Article 6(1)(f) GDPR): keeping the service secure, preventing fraud and the abuse of purchases and refunds, fixing problems and improving the service.
• To meet legal obligations (Article 6(1)(c) GDPR): keeping accounting and tax records and answering lawful requests from authorities.
• With your consent (Article 6(1)(a) GDPR): measuring how this website is used. You can withdraw it at any time, and everything else works the same.

The PDPL recognises the same grounds. We do not sell your data, use it for advertising profiles, or make automated decisions about you that have legal or similarly significant effects.

5. Artificial intelligence (OpenAI)

Some features are powered by OpenAI (OpenAI, L.L.C. and OpenAI Ireland Ltd.), which processes data on our behalf under a data processing agreement. It receives only what the feature needs:

• Writing correction: the text you wrote and the task it answers.
• Exam Generator: the part, the options and the topic you chose.
• Lingo challenges marked by AI: your written answer or, in a Speaking challenge, your recording, which is turned into text and then marked. The recording is not stored on our servers after it has been marked.
• Dictionary: the word you looked up.

Your name, email address and account number are never sent with these requests. Please do not write personal information in your answers. OpenAI does not use this data to train its models and keeps it only for a limited period to detect abuse. The results (corrections, scores, generated exams) are stored in your account so that you can see them again.

Speaking practice in the exams works differently: what you record there stays on your device, in your browser or in the app, and is never uploaded.

6. Payments

Purchases on this website are processed by Stripe, Inc., which collects your card and billing details under its own privacy policy. Purchases in the apps are processed by Apple (App Store) or Google (Google Play). We receive only what we need to give you what you paid for: the product, its status and dates, and a reference to the payment. We never receive or store your card number.

Deleting your account does not cancel a subscription on its own, so an account can only be deleted once every plan that still renews has been cancelled: on this website from your subscription page, and in the App Store or on Google Play for plans bought there.

7. Who we share it with

We never sell, rent or trade your personal data. We share it only with:

• Google and Apple, to sign you in.
• Stripe, Apple and Google, to process payments.
• OpenAI, for the artificial intelligence features described above.
• Google (Google Analytics and Firebase): usage statistics on this website if you accept them, and statistics and notifications in the apps.
• Our hosting providers: Google Cloud (our servers, databases and stored files) and Vercel (this website).
• Other learners, only what the leaderboards show.
• Authorities, when the law or a court requires it, or to protect the rights and safety of our users and of the service.

Our providers act on our instructions and are bound by confidentiality and data protection terms.

8. Cookies and storage on your device

This website keeps a few things in your browser:

• Strictly necessary: your signed-in session, and the progress you make before signing in (exam results, a Writing draft and the first Lingo challenges), which moves to your account the first time you open that level signed in. These need no consent.
• Preferences: your theme, language, sounds and similar settings.
• Analytics: Google Analytics cookies, only if you choose Accept in the cookie notice. If you choose No thanks, the analytics script is never loaded.

We do not use advertising cookies. To change your cookie choice, clear this site's data in your browser and the notice will ask again. Clearing it also signs you out and removes any progress not yet saved to an account.

9. How long we keep it

• Account data (name, email, profile): while your account exists, and up to six years after it is closed where the law requires it or a legal claim may need it.
• Learning data (answers, scores, texts, notes, game progress): while your account exists, then deleted or anonymised within 90 days of closing it. Resetting your progress in Settings removes it straight away.
• Purchase and billing records: up to six years, for accounting and tax.
• Support messages: up to 24 months after the matter is resolved.
• Server logs and analytics: usually 12 to 24 months.
• Recordings sent for marking in Lingo: not kept once marked.
• Progress kept in your browser before you sign in: until you sign in to that level or clear this site's data.

Data in backups that cannot be changed straight away is kept out of use until it is deleted in turn.

10. Your rights

You can ask us to:

• give you a copy of your personal data (Article 15 GDPR, Article 13 PDPL);
• correct it (Article 16 GDPR, Article 15 PDPL);
• delete it (Article 17 GDPR, Article 16 PDPL), except what the law makes us keep;
• restrict its use or object to it (Articles 18 and 21 GDPR, Article 17 PDPL);
• send it to you or to someone else in a portable format (Article 20 GDPR, Article 14 PDPL);
• stop using it where you gave your consent, at any time.

Much of this you can do yourself: edit your name, username and photo in your profile, and reset your progress or delete your account in Settings. For anything else, write to us from the email address of your account. We answer within 30 days and may ask you to confirm that the account is yours.

If you are not satisfied, you can complain to the data protection authority where you live or work (in the European Economic Area or the United Kingdom), or to the UAE Data Office.

11. Deleting your account

Your account is shared by this website and the four level apps, so deleting it removes it everywhere, together with your progress, and your AI credits are lost. You can delete it:

• on this website: open any level, then Settings, then Delete account;
• in an app: Settings, then Delete account;
• by email: write to info@tckrlabs.com from the email address of your account, and we will delete it and confirm.

Any plan that still renews must be cancelled first (see Payments).

12. Children

Cambridge Academy is not directed to children under 16, and we do not knowingly collect personal data from children under 16 without the consent of a parent or guardian. If you believe a child has given us personal data without that consent, write to info@tckrlabs.com and we will delete it.

13. International transfers

We are based in the United Arab Emirates and our providers process data in other countries, including the United States and the European Union. When data leaves the UAE, the European Economic Area or the United Kingdom, we rely on adequacy decisions or on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914, with the UK addendum where it applies), together with measures such as encryption and data minimisation, as Chapter V of the GDPR and Articles 22 and 23 of the PDPL require. You can ask for details at gdpr@tckrlabs.com.

14. Security

Data travels encrypted (TLS 1.2 or higher), access to it is limited to the people who need it, and our systems are protected and monitored. No system is completely secure. If a breach puts your rights at risk, we will tell the competent authority within 72 hours, and you where the law requires it.

15. Changes to this policy

We may update this policy. The date at the top shows the latest version. If a change matters, we will tell you on the site or by email at least 30 days before it takes effect.

16. Contact

TCKR Labs FZCO, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates. Email: info@tckrlabs.com.

Our representative in the European Union (Article 27 GDPR): Paula Klein, Balmes 241, 4th Floor, 08006 Barcelona, Spain. Email: gdpr@tckrlabs.com.

The rules for using the service are in our Terms of Use.