🔒 Privacy Policy

Welcome to Band9PTE ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website band9pte.com.au, our mobile applications for iOS and Android (the "Apps"), and related services.

1. Information We Collect

1.1 Personal Information (Website Accounts)

If you create an account on our website, we collect information that you voluntarily provide when you:

• Create an Account: Email address, name, and password
• Take Practice Tests: Your test answers, responses, audio recordings (for speaking tests), and written content
• Contact Us: Name, email address, and message content
• Subscribe to Updates: Email address for newsletters or notifications

1.2 Automatically Collected Information

When you visit our website, we automatically collect certain information:

• Device Information: Browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, test completion rates
• IP Address: Your Internet Protocol address for security and analytics
• Cookies: Small data files stored on your device (see Cookie Policy below)

1.3 Test Performance Data

We collect and store:

• Your test answers and responses across all PTE modules
• AI-generated scores and feedback
• Performance analytics and progress tracking data
• Audio recordings of speaking practice (processed and deleted after scoring)
• Time taken to complete questions and modules

1.4 Information Collected by Our Mobile Apps

The iOS and Android apps are built to work without an account. The apps collect:

• Voice recordings (speaking practice): when you answer a speaking question, the app records your voice and sends it to our scoring service, which converts it to text and marks it. Recordings are used only to produce your score and are deleted after scoring — we do not keep them.
• Written responses: text you type for written tasks (essays, emails, summaries and fill-in-the-blank answers), sent to our scoring service to produce your score and feedback.
• App device identifier: a randomly generated ID kept on your device and sent with scoring requests so we can apply rate limits and prevent abuse. It is not linked to your name, email or any account.
• Advertising identifier: our advertising partner (Google AdMob) may access your device's advertising identifier (Android Advertising ID or Apple IDFA) to display and measure ads. On iOS we ask your permission first; you can decline and still use the app. See section 3.3 for how to reset or limit it.
• App diagnostics: our advertising SDK collects app performance information such as launch time, hang rate and energy usage, used for analytics and fraud prevention.
• Study reminders (optional): if you switch reminders on, they are scheduled locally on your device. We do not send push notifications.
• Data kept on your device: practice progress, score history, reminder settings and any ad-free window are stored locally. Clearing the app's data or uninstalling it removes this.

The apps do not collect your name, email address, phone number or password, do not require sign-in, and do not access your contacts, photos, calendar or precise location.

2. How We Use Your Information

2.1 Primary Uses

• Service Delivery: Provide PTE practice tests, AI scoring, and instant feedback
• Account Management: Create and maintain your user account
• Performance Tracking: Track your progress and provide personalized recommendations
• AI Scoring: Process your answers through AI models to generate accurate scores
• Communication: Send test results, important updates, and service notifications

2.2 Service Improvement

• Analyze usage patterns to improve our platform
• Develop new features and practice materials
• Enhance AI scoring accuracy and feedback quality
• Identify and fix technical issues

2.3 Legal and Security

• Comply with legal obligations and regulations
• Prevent fraud, abuse, and unauthorized access
• Protect user safety and platform integrity
• Enforce our Terms and Conditions

3. Third-Party Services

3.1 Services We Use

We use the following third-party services that may collect information:

• Supabase: Database and authentication services (stores user accounts and test data)
• Advance AI: AI scoring engine for analyzing test responses
• Google Analytics: Website traffic and user behavior analysis
• ElevenLabs: Text-to-speech for audio generation in listening tests
• Cloud Storage: Secure storage of test materials and user data

3.2 Services Used by the Mobile Apps

The apps rely on these processors, which handle data only on our behalf and only to run the service:

• Cloud hosting and scoring API: receives your voice recording or written response, returns your score and feedback, and does not store the submission
• Speech-to-text and AI scoring providers: convert spoken answers to text and mark written and spoken responses
• Google Firebase Storage: serves the practice material (question audio and images) to the app
• Google Mobile Ads (AdMob): displays the advertising that keeps the app free

3.3 Advertising — Website and Mobile Apps

Website: we use Google AdSense to display advertisements. Google may use cookies to serve ads based on your prior visits to our website or other websites.

Mobile apps: the apps use Google AdMob (Google Mobile Ads), which may access your device's advertising identifier and the device data described in section 1.4 in order to display ads and measure their performance.

Your choices:

• iOS: Settings → Privacy & Security → Tracking — deny or withdraw permission for Band 9 PTE at any time
• Android: Settings → Google → Ads — reset or delete your advertising ID, or opt out of personalised advertising
• Web: opt out of personalised advertising via Google Ads Settings

Declining personalised advertising does not remove ads; it makes them less relevant to you.

4. Cookies and Tracking Technologies

4.1 Types of Cookies We Use

• Essential Cookies: Required for authentication and core functionality
• Performance Cookies: Track test progress and user sessions
• Analytics Cookies: Google Analytics for usage statistics
• Advertising Cookies: Google AdSense for relevant ad delivery

4.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may limit functionality of our service.

4.3 Cookies in Our Mobile Apps

The mobile apps do not use browser cookies. They keep your practice data locally on the device, and our advertising partner may use the advertising identifier for ad delivery and measurement as described in section 3.3.

5. Data Security

5.1 Security Measures

We implement industry-standard security measures:

• SSL/TLS encryption for data transmission
• Secure password hashing and storage
• Regular security audits and updates
• Access controls and authentication requirements
• Secure API communications with third-party services

5.2 Data Retention

• Account Data: Retained while your account is active
• Test Results: Stored for progress tracking (can be deleted on request)
• Audio Recordings: Processed immediately and deleted after scoring
• App Voice Recordings: Uploaded for AI scoring, then deleted — never stored by us
• App Written Responses: Used to generate your score and feedback; not retained on our servers
• App Data on Your Device: Practice progress, scores and settings stay on your device until you clear the app data or uninstall
• Analytics Data: Retained for up to 26 months (Google Analytics default)

6. Your Privacy Rights

6.1 Rights Under GDPR and Privacy Laws

You have the following rights:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and data
• Portability: Receive your data in a portable format
• Objection: Object to certain processing of your data
• Withdraw Consent: Revoke consent for data processing

6.2 Exercising Your Rights

To exercise any of these rights, please contact us at:

• Email: support@band9pte.com.au
• Subject Line: "Privacy Request - [Your Request Type]"
• We will respond within 30 days

6.3 Deleting App Data

The apps do not create an account, so there is no server-side profile to delete. You can remove everything the app stores by clearing its data or uninstalling it, and you can reset or delete your advertising identifier in your device settings (section 3.3). Voice recordings and written responses are processed for scoring and not retained, so there is nothing further for us to erase.

7. Children's Privacy

Our service is intended for users aged 16 and above. We do not knowingly collect personal information from children under 16. If you believe we have inadvertently collected such information, please contact us immediately.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers, including:

• Standard contractual clauses
• Compliance with GDPR and international privacy laws
• Secure data transfer protocols

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy with a new "Last Updated" date
• Sending email notifications to registered users
• Displaying a prominent notice on our website

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of sale of personal information
• Right to deletion of personal information
• Right to non-discrimination for exercising CCPA rights

Note: We do not sell your personal information to third parties.

12. Contact Information

For privacy-related questions, concerns, or requests:

• Email: support@band9pte.com.au
• Advertising Inquiries: ads@band9pte.com.au
• Website: band9pte.com.au
• Response Time: We aim to respond within 48-72 hours

13. Consent

By using our website and services, you consent to this Privacy Policy and agree to its terms. If you do not agree, please discontinue use of our services.