Privacy Policy

This Privacy Policy explains how Talent Networking (a sole-proprietorship registered in Hubli, Karnataka, India), the operator of the LanguageTest.in platform (“we“, “us“, or “LanguageTest.in“), collects, uses, stores, and shares your personal data when you use our website and services. As a Data Fiduciary, we comply with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDP Act).

1. What We Collect

  • Account data: Name, email address, phone number (if provided), preferred language, and password (stored securely as a salted hash).
  • Exam data: Mock exam answers, audio recordings of your speaking responses, AI-generated scores, examiner feedback, attempt history, and progress metrics.
  • Payment data: We do not store credit card, debit card, or UPI credentials. Transactions are processed securely by Cashfree Payments; we only retain the payment ID, plan selected, amount, and payment status returned by their API.
  • Technical data: IP address, browser user-agent, device type, time-zone, and pages visited. This is collected via cookies and server logs solely for security monitoring and platform analytics.
  • Communications: Emails we send to you, including open and click tracking for transactional and product emails. (Marketing emails are only sent with your explicit consent).

2. How We Use Your Data

  • To create, operate, and maintain your account and deliver the exam service.
  • To run AI scoring on your written and spoken responses using third-party Large Language Model (LLM) and Speech-to-Text (STT) providers (see Section 5).
  • To process payments and issue invoices or receipts.
  • To send transactional emails (e.g., sign-up confirmations, password resets, exam-result notifications, billing receipts).
  • To prevent fraud, abuse, and comply with our legal obligations.
  • To improve the platform using aggregated and anonymised usage analytics.

3. Lawful Basis for Processing

Under the Indian DPDP Act, our lawful basis for processing your personal data is your consent (collected when you create an account and accept our Terms) and certain legitimate uses. These legitimate uses include providing the service you have requested, complying with applicable laws, and responding to medical or safety emergencies.

4. How Long We Keep Your Data

  • Active accounts: Data is retained for as long as your account remains active.
  • Closed accounts: Personal data is securely deleted within 30 days of an account deletion request, except where retention is strictly required by law (e.g., GST and financial records are kept for 8 years).
  • Exam audio recordings: Retained for 90 days, unless you actively opt to keep them longer within your account settings for progress tracking.
  • Email tracking events: Retained for 18 months.

5. Sharing With Third Parties

We share the minimum necessary data with the following processors, all of whom are contractually bound to strict confidentiality and data security standards:

  • Cashfree Payments: Payment processing (India).
  • Hostinger: VPS hosting and SMTP email delivery (EU/India).
  • Google Analytics 4: Aggregated traffic analytics. (You can opt out of this via your browser settings).

We do not sell your personal data under any circumstances, nor do we share your data with advertisers.

6. Cross-Border Transfers

Some of our trusted processors (notably the AI providers) operate servers outside of India. By using the Service, you consent to your anonymised exam responses being transferred internationally for the sole purpose of AI scoring. We do not transfer your name, email, or payment details to these AI providers.

For users located in the European Economic Area (EEA), the United Kingdom, or Switzerland, such transfers rely on Standard Contractual Clauses (SCCs) approved by the European Commission and the vendor’s Data Processing Agreement (DPA). Please see our GDPR Addendum (Section 13) for further details.

7. Security

We implement robust security measures, including HTTPS (TLS 1.3) for all web traffic, encrypted storage for passwords and SMTP credentials, strict role-based access controls, and regular server patching. While no method of internet transmission is 100% secure, we are committed to upholding industry best practices to protect your data.

8. Your Rights

Under the DPDP Act, you possess the right to:

  • Access a summary of the personal data we hold about you.
  • Correct inaccurate, incomplete, or outdated data.
  • Request the deletion of your account and associated data.
  • Withdraw your consent at any time (note that this does not affect the legality of prior processing).
  • Nominate another individual to exercise your rights in the event of death or incapacity.
  • Lodge a grievance with our designated Grievance Officer (see Section 11).

You can exercise most of these rights directly from your account settings page (Account -> Privacy). For further assistance, please contact us at privacy@languagetest.in.

9. Cookies

We use strictly-necessary cookies for user authentication and security (CSRF protection), and analytics cookies (Google Analytics) to understand site traffic. Strictly-necessary cookies cannot be disabled, as the site will not function without them. You can disable analytics cookies via your browser’s “Do Not Track” setting or by utilizing a cookie-blocking extension.

10. Children and Minors

Under the DPDP Act, individuals under 18 are considered children. Our service requires users to be at least 18 years old to independently create an account. We do not knowingly collect data from children under 18 without verifiable parental consent. If you believe a minor has provided us with personal data without proper consent, please contact us immediately, and we will delete the data within 7 days.

11. Grievance Officer

In accordance with the IT Act 2000 and the DPDP Act, our designated Grievance Officer is:

Talent Networking Hubli, Karnataka — 580020, India Email: grievance@languagetest.in We aim to acknowledge and resolve all grievances within 30 days.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of any material changes via email or an in-app banner at least 7 days before they take effect. Continued use of the Service after changes take effect constitutes your acceptance. The “Last updated” date at the top of this page reflects the current version.

13. GDPR Addendum — EEA, UK & Switzerland Users

This section applies exclusively to users located in the European Economic Area (EEA), the United Kingdom, or Switzerland. It supplements — and in the event of a conflict, prevails over — the general policy above for such users.

13.1 Data Controller

The data controller for your personal data is Talent Networking, Hubli, Karnataka — 580020, India. You can contact us at privacy@languagetest.in. As we do not routinely process the personal data of EU residents at a scale that triggers GDPR Article 27 requirements, we have not appointed an EU-based representative. If you believe an appointment is required in your specific case, please contact us.

13.2 Legal Bases Under GDPR

We rely on the following lawful bases (GDPR Art. 6) to process your personal data:

  • Contract (Art. 6(1)(b)): To provide the exam service you signed up for (account creation, running mock exams, scoring, issuing receipts).
  • Consent (Art. 6(1)(a)): For optional marketing communications, non-essential analytics cookies, and the storage of audio recordings beyond our default 90-day retention period.
  • Legal Obligation (Art. 6(1)(c)): For tax invoicing, mandatory record-keeping, fraud prevention, and responding to lawful authority requests.
  • Legitimate Interests (Art. 6(1)(f)): To secure our Service against abuse, prevent account takeovers, and improve our products via aggregated analytics. You may object to this processing at any time (see Section 13.4).

We do not process special-category data (GDPR Art. 9) unless you voluntarily include health- or belief-related information in your free-text exam responses. In such cases, processing is strictly limited to the purpose of AI scoring, and the data is deleted according to our standard retention schedule.

13.3 International Transfers

Your personal data is stored primarily on servers located in India (Hostinger VPS). Anonymised exam responses sent to our AI providers are transferred to their infrastructure in the United States, the European Union, or India, depending on the vendor. These transfers rely on:

  • Standard Contractual Clauses (SCCs) (EU Commission decisions 2021/914 and 2021/915) where the vendor supports them.
  • Vendor DPAs (Data Processing Agreements), which incorporate the UK International Data Transfer Addendum where applicable.
  • Transfer-impact assessments for each vendor, reviewed annually.

A copy of the SCCs or vendor DPA in force is available upon request at privacy@languagetest.in.

13.4 Your Rights Under GDPR

In addition to the rights listed in Section 8, EEA/UK/Swiss users have the right to:

  • Access (Art. 15): Obtain a copy of the personal data we hold about you.
  • Rectification (Art. 16): Correct inaccurate or incomplete data.
  • Erasure “Right to be Forgotten” (Art. 17): Request the deletion of your data, subject to overriding legal obligations.
  • Restriction of Processing (Art. 18): Pause the processing of your data while a dispute is being resolved.
  • Data Portability (Art. 20): Receive your data in a structured, commonly used, and machine-readable format.
  • Object (Art. 21): Object to processing based on our legitimate interests.
  • Not be Subject to Automated Decision-Making (Art. 22): Our AI scoring is strictly advisory; no legal or similarly significant decisions are made about you solely by automated means. You may request a human review of any AI score by emailing our support team.
  • Withdraw Consent: Withdraw consent at any time for processing based on consent, without affecting prior lawful processing.
  • Lodge a Complaint: Lodge a complaint with a supervisory authority in your EEA member state (edpb.europa.eu). UK users may complain to the ICO (ico.org.uk), and Swiss users to the FDPIC (edoeb.admin.ch).

We respond to all rights requests within 30 days, free of charge for reasonable requests. Most access, correction, and deletion requests can be fulfilled directly within your account settings.

13.5 Cookies & Consent Under ePrivacy

For visitors from the EEA, UK, and Switzerland, we set only strictly-necessary cookies by default. Analytics and non-essential cookies are set only after you provide explicit consent via our cookie banner. You can withdraw this consent at any time by clearing your cookies for this domain or using our on-site cookie preference tool.

13.6 Data Breach Notification

In the event of a personal data breach likely to result in a risk to the rights and freedoms of EEA/UK/Swiss users, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, and we will notify affected users without undue delay if the risk is deemed high.

13.7 Children in the EEA/UK

In the EEA, we do not knowingly offer information-society services to children under the age of 16 (or the lower age set by a specific member state) without verified parental consent. In the UK, we do not knowingly offer services to users under the age of 13 without parental consent. If you believe a child has provided us with data, please email privacy@languagetest.in, and we will delete it within 7 days.