Privacy Policy

This Privacy Policy explains how Mobiqo LTD ("we", "us", "our"), a company registered in England and Wales, collects, uses, protects and otherwise processes personal data of users ("you") of the LexiPTE website, apps and services (the "Services"). We are the controller of this data. Your privacy and trust are important to us.

We may update this Policy from time to time. If we make changes we consider important, we will tell you in the Services or by email before they take effect.

Information you give us. "Personal data" means any information relating to an identified or identifiable person. Depending on how you use the Services, we collect:

• Account data: your email address, name and profile picture (from Google or Apple if you sign in with them, or uploaded by you), and your study goals and preferences, such as your exam type and target score.
• Study data: your answers, written responses, mock exam results, progress, scores, feedback and achievements.
• Voice recordings: audio you record for Speaking practice and mock exams, and the transcripts and feedback produced from it.
• Transaction data: your subscription plan, status, renewal dates and payment history. Card and bank details are entered on Stripe's checkout page and are never stored by us.
• Support data: messages you send us and our replies.

Information collected automatically. When you use the Services we record technical data needed to run and secure them: IP address, browser and device type, operating system, language, pages requested and the date and time of requests. Depending on the law of your country, your IP address may be personal data.

Information from other sources. If you sign in with Google or Apple, we receive your name, email address and, from Google, your profile picture. With Apple you can choose to hide your email address, in which case we receive a private relay address. We treat this information as personal data under this Policy.

We use your information only for these purposes:

• Providing the Services: to create and run your account, save your progress, show your history and results, and give you access to the features of your plan.
• AI scoring and feedback: when you ask for it, we send your answer or recording together with the question to our AI provider, which scores it and returns feedback and, for recordings, a transcript. Scores are generated automatically; they are practice estimates with no legal or similarly significant effect on you.
• Personalisation: to suggest what to practise next and adapt the Services to your exam and goals.
• Payments: to activate, renew and cancel your subscription, and to process refunds.
• Communication: to send sign-in codes and important account, subscription and service messages, and to answer your support requests. If we ever send marketing emails, each one will include a way to unsubscribe.
• Improvement and security: to fix problems, keep the Services secure, prevent fraud and abuse, and improve features and question quality.
• Product analytics and session recordings: to understand which features help people prepare, where they get stuck, and to find confusing screens. See section 9 for what is recorded and how to object.
• Legal obligations: to keep accounting and tax records, respond to lawful requests from authorities, enforce our terms, and protect our rights and the rights and safety of others.

We do not sell your personal data and do not use it for third-party advertising.

We share personal data only with service providers that process it on our behalf, under contracts that require them to protect it and use it only to provide their services to us:

• Vercel: website hosting, delivery, cookie-free visitor analytics and performance measurements.
• Neon: our database (accounts, study data, subscriptions).
• Cloudflare R2: storage of voice recordings, profile pictures and course media.
• Google (Gemini API): AI scoring of answers and recordings. We send the request with storage switched off, and under the terms of the paid Gemini API Google does not use this content to train its models.
• Resend: delivery of sign-in codes and service emails.
• Mixpanel (United States): product analytics and session recordings, linked to your account ID, email and name when you are signed in.
• Google and Apple: sign-in, if you choose to use them.

Payments. Web payments are handled by Stripe and Link, Stripe's payment service, which acts as the seller of record for the transaction. They receive your payment details, billing country and email directly and process them as independent controllers under their own privacy policies, including for fraud prevention and tax compliance. In-app purchases are processed by Apple or Google.

We may also disclose information if we believe in good faith it is required by law or by a court order or other legal process, or is necessary to protect the rights, property or safety of us, our users or others. We will tell you about such a disclosure where we lawfully can. If our business or its assets are sold or merged, your information may be transferred to the new owner, who will be bound by this Policy.

Our servers and database are located in Australia, and some of our providers process data in the United States and other countries. When we transfer personal data from the UK or the European Economic Area to a country without an adequacy decision, we rely on appropriate safeguards such as the UK International Data Transfer Addendum and the EU Standard Contractual Clauses in our providers' data processing terms. Contact us if you would like more information.

• Account and study data: for as long as your account exists. When you delete your account, we delete your profile, study data, recordings and profile picture.
• Voice recordings: for up to 1 year from recording, then deleted automatically.
• Transaction records: for as long as tax and accounting law requires, usually 6 years.
• Analytics events: up to 5 years, then deleted. Session recordings: up to 30 days.
• Technical logs: for a short period, normally no more than 30 days, unless needed to investigate a security incident.

When we no longer need personal information, we securely delete it.

We use reasonable technical and organisational measures to protect your personal data, including encryption in transit, private storage with time-limited access links, and access limited to people who need it. However, no system can be completely secure, and we cannot guarantee that information will never be accessed, disclosed, altered or destroyed by a breach of our safeguards. If a breach is likely to affect you, we will tell you and the relevant authority as the law requires.

Under data protection law you have the right to:

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing of your personal data;
• request transfer of your personal data;
• withdraw consent at any time, where we rely on consent.

You can update your profile and delete your account yourself from your profile page. For any other request, email support@mobiqo.tech from the address on your account. We may ask you to verify your identity before acting on a request. We respond within one month. You will not have to pay a fee, unless a request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee or refuse it.

You also have the right to complain to a data protection authority: in the UK, the Information Commissioner's Office (ico.org.uk); in the EU, the authority in your country; in Australia, the Office of the Australian Information Commissioner. We would appreciate the chance to deal with your concerns first.

• Providing the Services, AI scoring and payments: performance of our contract with you (Art. 6(1)(b) UK GDPR / GDPR).
• Personalisation, security, fraud prevention and improving the Services: our legitimate interests in running and developing a safe, useful service (Art. 6(1)(f)).
• Product analytics and session recordings: our legitimate interests in understanding how the Services are used and improving them (Art. 6(1)(f)). You can object at any time (section 9).
• Marketing emails, if we send any: your consent (Art. 6(1)(a)).
• Tax, accounting and legal requests: legal obligation (Art. 6(1)(c)).

Cookies are small text files a website stores in your browser. We use:

• Session cookies: keep you signed in and protect sign-in requests. Strictly necessary.
• Exam preference: remembers whether you study for PTE Academic or PTE Core, for up to 1 year.
• Local storage: keeps drafts of your written answers and small display settings on your device.
• Analytics (Mixpanel): a random identifier in local storage that lets Mixpanel count visits and connect the pages and actions of one visitor: pages viewed, buttons used, answers submitted, AI feedback requested, paywall views and purchases. Session recordings capture how you move through pages, including the questions shown and the answers you type; your email address and sign-in codes are always masked, and card details never pass through our pages.
• Vercel Web Analytics and Speed Insights: measure visits, pages viewed, referral sources, browser and device information, and page performance without analytics cookies. We do not send account IDs, names, emails, answers or recordings as custom events to Vercel.

Analytics and session recordings are on for all visitors. They are never used for advertising and never sold. If you object to them, email support@mobiqo.tech and we will delete the analytics data linked to your account. We do not use advertising or cross-site tracking cookies. Stripe sets its own cookies on its checkout page for payment and fraud prevention. You can also block or delete cookies in your browser settings, but signing in will not work without the session cookie.

The Services are not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has given us personal data without the consent of a parent or guardian, email support@mobiqo.tech and we will delete it.

If you have any questions, concerns or complaints about this Policy or our privacy practices, contact us at support@mobiqo.tech. See also our Terms of Service.