Last updated: 26-09-2025

Welcome to thepte.com (“we”, “us”, “our”). This Privacy Policy explains how we collect, use, disclose, and protect the personal information you provide when you use our website, mobile applications, and services (collectively, the “Service”). By using the Service, you consent to the practices described below.

Key Points:

• We collect audio recordings, exam responses, and account information to provide PTE practice services
• We do not sell your personal data to third parties
• You have rights to access, correct, and delete your data
• Our mobile app requires microphone access for speaking practice

1. Who We Are

• Website: thepte.com
• Mobile Application: thePTE (iOS and Android)
• Jurisdiction: Dubai, UAE
• Contact: info@thepte.com
• Data Protection Officer: privacy@thepte.com

2. What Personal Data We Collect & Why

We collect only the information necessary to deliver and improve our PTE preparation services. The data we collect varies depending on whether you use our website or mobile application.

2.1 Data Collected Across All Platforms

Type of Data	Source / Method	Purpose	Legal Basis
Account Information Name, email address, username, password (encrypted)	Registration forms, account settings	Account creation, user identification, authentication, customer support	Contract performance, legitimate interest
Audio Recordings Voice recordings during speaking practice (Read Aloud, Repeat Sentence, Describe Image, Retell Lecture, Answer Short Question)	Microphone input during practice sessions	AI-powered pronunciation analysis, scoring, feedback generation, and algorithm improvement	Consent, contract performance
Exam Responses Text answers, multiple choice selections, essay responses, scores, timestamps	User submissions during practice tests and mock exams	Grading, performance analytics, personalized feedback, progress tracking	Contract performance, legitimate interest
Usage & Analytics Data Device information, IP address, browser type, operating system, app version, feature usage, session duration, error logs	Automatically collected via cookies, server logs, and analytics tools	Platform optimization, bug detection, usage analytics, security monitoring	Legitimate interest
Payment Information Payment method details (processed by third-party payment processors)	Payment forms during subscription/purchases	Processing transactions, subscription management	Contract performance, legal obligation
Communication Data Support tickets, feedback, survey responses	Direct communication with users	Customer support, service improvement	Contract performance, legitimate interest

2.2 Mobile App-Specific Data Collection

When you use our mobile application (thePTE), we additionally collect:

Data Type | Purpose | Required?

Device Identifiers (Device ID, advertising ID (IDFA/GAID)) | Analytics, crash reporting, personalized content | Yes (for core functionality)

Push Notification Tokens | Send practice reminders, test results, updates | Optional (can be disabled)

Camera Access (For Describe Image practice) | Capture images for image description practice tasks | Optional (user-initiated)

File Storage Access | Save practice recordings, reports, and offline content | Optional (for offline mode)

Network Status | Optimize data usage, enable offline features | Yes

2.3 Data We Do NOT Collect

We want to be transparent about what we don’t collect:

• We do not collect or store video recordings
• We do not collect biometric identifiers beyond audio (no facial recognition, fingerprint, etc.)
• We do not collect sensitive health information
• We do not access your contacts, photos, or other unrelated app data without permission
• We do not collect financial information directly (processed by secure third-party payment processors)
• We do not collect precise geolocation data

3. Permissions & App Features

Our mobile app requests specific permissions to provide you with the best PTE practice experience. Here’s why each permission is needed:

3.1 Microphone Permission

Required for: All speaking practice tasks (Read Aloud, Repeat Sentence, Describe Image, Retell Lecture, Answer Short Question, Speak About the Photo)

What we do: Record your voice responses to analyze pronunciation, fluency, and content. Recordings are processed to generate instant feedback and scores.

When used: Only when you actively start a speaking practice task. The microphone is never active in the background.

Your control: You can deny microphone permission, but this will disable speaking practice features. You can manage permissions in your device settings.

3.2 Camera Permission

Required for: Describe Image and Speak About the Photo tasks where you may photograph visual content

What we do: Capture images you choose to practice describing. Images are processed locally on your device when possible to analyze content.

Your control: Completely optional. You can use stock images provided in the app instead.

3.3 Storage Permission

Required for: Saving practice recordings, progress reports, and offline practice content

What we do: Store files locally on your device for offline access and report generation.

Your control: Optional. The app functions fully online without local storage.

3.4 Push Notification Permission

Purpose: Send you:

• Practice reminders and study schedules
• Test results and score notifications
• Weekly progress summaries
• Important platform updates

Your control: You can enable/disable notifications at any time in app settings or device settings.

4. Cookies & Tracking Technologies

We use cookies and similar technologies on our website:

• Essential Cookies: Required for login sessions, shopping carts, and platform functionality
• Performance Cookies: Analytics cookies (Google Analytics) to understand how users interact with our platform
• Functional Cookies: Remember your preferences (language, settings)
• Marketing Cookies: Used sparingly for relevant advertising (you can opt out)

Cookie Management: You can control or disable cookies via browser settings; however, disabling essential cookies may prevent you from using certain features. We do not use tracking cookies across third-party websites for marketing without your consent.

5. How We Use Your Data

We process your data for the following legitimate purposes:

1. Service Delivery & Feedback — Present practice exams, record audio, process responses, provide AI-generated feedback and scores
2. AI Model Training & Improvement — Analyze patterns to train and improve our speech recognition and scoring algorithms (anonymized data)
3. Personalization — Tailor practice content and difficulty based on your performance
4. Account Management — Manage subscriptions, process payments, send service updates
5. Security & Integrity — Detect fraud, abuse, unauthorized access, and protect platform security
6. Communication — Respond to inquiries, send important notices, provide customer support
7. Analytics & Research — Understand usage patterns to improve platform design and features
8. Legal Compliance — Meet regulatory requirements and respond to legal requests

Important: We do not use your audio recordings or exam responses for marketing purposes. We do not sell or license your personal data to third parties for advertising.

6. Third-Party Services & SDKs

Our Service integrates with trusted third-party services that may collect information:

6.1 Analytics & Performance

• Google Analytics: Website traffic analysis (anonymized IP)
• Firebase (Google): Mobile app analytics, crash reporting, performance monitoring
• Amplitude: Product analytics and user behavior analysis

6.2 Payment Processing

• Stripe / PayPal: Secure payment processing (we do not store full card details)
• Apple In-App Purchase / Google Play Billing: Mobile subscriptions

6.3 Speech Recognition & AI

• Custom AI Models: Our proprietary speech recognition and scoring technology
• Cloud AI Services: May use AWS, Google Cloud, or Azure for processing (with data protection agreements)

6.4 Customer Support

• Email Service Providers: For transactional and support emails
• WhatsApp Business: Support messaging (if you initiate contact)

These third parties are contractually obligated to protect your data and may only use it for the purposes we specify.

7. Data Retention

• Audio Recordings: Retained for as long as your account is active plus 90 days after deletion (for quality assurance). You can request immediate deletion.
• Exam Responses & Scores: Retained while your account is active to track progress. Deleted within 30 days of account termination.
• Account Information: Retained while your account is active plus as required by law (typically 7 years for financial records).
• Analytics Logs: Retained for 26 months, then anonymized or deleted.
• Payment Records: Retained for 7 years to comply with financial regulations.

Backup Data: Deleted data may persist in encrypted backup systems for up to 90 days for recovery purposes, after which it is permanently erased.

8. Disclosure & Sharing of Data

We share your data only in these limited circumstances:

• Service Providers: With trusted vendors who assist in operating the Service (cloud hosting, email delivery, payment processing, analytics) under strict confidentiality agreements
• Legal Requirements: To comply with laws, regulations, court orders, or governmental requests
• Business Transfers: In the event of merger, acquisition, or sale of assets (users will be notified)
• Safety & Security: To protect rights, safety, or property of users, thePTE, or others
• Aggregated/Anonymized Data: We may share non-personal, aggregated statistics for research or business purposes

We never share your audio recordings or individual exam responses with third parties for their marketing purposes.

9. International Data Transfers

We operate globally and may transfer your data across borders:

• Primary Storage: Data is primarily stored in secure cloud servers (AWS/GCP/Azure) in regions including the UAE, EU, and USA
• Transfer Mechanisms: We use Standard Contractual clauses, EU-U.S. Data Privacy Framework (where applicable), and other legally recognized transfer mechanisms
• UAE Data Protection: For users in UAE, data is processed in compliance with UAE data protection laws
• EU/UK Users: Adequate safeguards are in place for transfers from the EU/UK

Regardless of location, we maintain the same level of data protection.

10. Security of Your Data

We implement comprehensive security measures:

• Encryption: TLS/SSL for data in transit; AES-256 encryption for data at rest
• Access Controls: Role-based access, multi-factor authentication for staff
• Audit & Monitoring: Regular security audits, vulnerability assessments, access logging
• Infrastructure: Secure cloud infrastructure with DDoS protection, firewalls, and intrusion detection
• Staff Training: Regular privacy and security training for employees
• Incident Response: Formal breach notification procedures (72-hour notification for GDPR-regulated users)

While we maintain industry-standard security, no system is 100% secure. We encourage you to use strong passwords and keep your account credentials confidential.

11. Your Rights & Choices

Depending on your location and applicable laws, you have these rights:

11.1 Universal Rights

• Access: Request a copy of all personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your data (“Right to be Forgotten”) – subject to legal retention obligations
• Portability: Receive your data in a structured, machine-readable format (JSON/CSV)
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

11.2 Additional Rights for Specific Jurisdictions

EU/EEA/UK Residents (GDPR):

• Right to restrict processing
• Right to lodge a complaint with your local Data Protection Authority
• Right to automated decision-making explanation (where AI scoring is used)

California Residents (CCPA/CPRA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale/sharing (we do not sell data)
• Right to non-discrimination for exercising privacy rights

UAE Residents (UAE Data Protection Law):

• Right to access, correct, and delete personal data
• Right to withdraw consent
• Right to lodge a complaint with the UAE Data Office

11.3 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: privacy@thepte.com
• Subject Line: “Privacy Rights Request – [Your Name]”
• Verification: We may request proof of identity to protect your data
• Response Time: We will respond within 30 days (45 days for complex requests)
• No Fee: Most requests are free, except for repetitive or manifestly unfounded requests

12. Children’s Privacy

Our Service is designed for users 18 years and older. We do not knowingly collect data from children under 18.

• If we discover we have inadvertently collected data from someone under 18, we will delete it immediately
• Parents or guardians who believe their child has provided data should contact us at privacy@thepte.com
• We comply with the Children’s Online Privacy Protection Act (COPPA) and similar international laws

13. Data Breach Notification

In the unlikely event of a data breach:

• Regulatory Notification: We will notify relevant authorities within 72 hours (where legally required)
• User Notification: We will notify affected users without undue delay via email and in-app notification
• Incident Details: What happened, what data was affected, what we’ve done, what users should do
• Remediation: We will take immediate steps to contain the breach and prevent recurrence

14. Automated Decision-Making & AI Scoring

Our platform uses AI and automated systems to:

• Analyze speech patterns and pronunciation
• Score speaking and writing responses
• Generate personalized feedback
• Recommend practice content

Your rights regarding automated processing:

• You can request human review of automated scoring decisions
• You can opt out of AI-based personalization (though this may reduce service quality)
• We continuously monitor our AI systems for bias and accuracy

15. Do Not Track (DNT)

We respect Do Not Track browser signals. When DNT is enabled:

• We disable non-essential analytics cookies
• We limit cross-site tracking
• Essential functionality cookies remain active

16. Changes to This Policy

We may revise this Privacy Policy to reflect changes in our services, legal requirements, or practices:

• Notification: Material changes will be communicated via email and in-app notification
• Version History: Previous versions are available at thepte.com/privacy-policy/archive
• Effective Date: Changes take effect 30 days after posting (immediately for legal requirements)
• Continued Use: Your continued use after changes constitutes acceptance

17. Governing Law & Dispute Resolution

• Governing Law: This policy is governed by the laws of the UAE and applicable international data protection laws
• Jurisdiction: Any disputes will be resolved in the courts of Dubai, UAE
• Arbitration: For users outside UAE, disputes may be resolved through binding arbitration

18. Contact Us

If you have questions, concerns, or wish to exercise your rights:

thePTE – Privacy Team

• Email: privacy@thepte.com
• General Support: info@thepte.com
• Website: https://thepte.com
• Response Time: We aim to respond within 5 business days
• WhatsApp Support: +61435724790

Note: This Privacy Policy is effective as of the “Last Updated” date above and applies to all users of thePTE website and mobile applications. For questions not answered in this policy, please contact our privacy team.