Privacy Policy

1. Who We Are

This Privacy Policy explains how International Test Limited ("we", "us", "our") collects and uses personal data when you use internationalenglishtest.com.

• Company name: International Test Limited
• Country of establishment: United Kingdom
• Email: hello@internationalenglishtest.com

We act as the data controller for personal data collected through this website.

2. What Data We Collect

We only collect personal data that is necessary to provide our services.

a) Information you provide

• First and last name
• Email address
• Account login credentials (passwords are stored in encrypted form)
• Profile information you choose to add

b) Automatically collected data

• IP address
• Browser and device information
• Pages visited and usage statistics
• Cookies and similar technologies

c) Payment data

Payments are processed by third-party payment providers (such as Stripe). We do not store or process your payment card details.

3. How We Use Your Data

We use your data to:

• Create and manage your account
• Deliver tests, results, and certificates
• Provide customer support
• Improve and secure our platform
• Process payments and prevent fraud
• Send service-related emails

If you explicitly opt in, we may also send:

• Product updates
• Offers and marketing communications

You can unsubscribe at any time.

4. Legal Basis for Processing

We process your personal data based on:

• Contractual necessity – to provide the services you request
• Legal obligations – accounting, fraud prevention, compliance
• Legitimate interests – improving and securing our services
• Consent – for marketing communications (where applicable)

5. Cookies & Analytics

We use cookies and similar technologies to operate and improve our website. This may include:

• Essential cookies (required for functionality)
• Analytics tools (e.g. Google Analytics)
• Usability tools (e.g. heatmaps or session recordings)

Sensitive information (passwords, payment details, form inputs) is never recorded. You can manage cookies through your browser settings or our cookie banner.

6. Data Sharing

We may share personal data with trusted service providers who process data on our behalf, such as:

• Hosting and infrastructure providers
• Analytics and security tools
• Payment processors (e.g. Stripe)

All service providers are contractually required to protect your data.

7. International Data Transfers

Your data may be processed in the United Kingdom and, where necessary, in other countries. Where data is transferred internationally, we ensure appropriate safeguards are in place in accordance with UK GDPR.

8. Data Retention

We retain personal data only for as long as necessary to:

• Provide our services
• Meet legal and regulatory requirements
• Resolve disputes and enforce agreements

Usage and analytics data is typically retained for shorter periods.

9. Your Rights

You have the right to:

• Access your personal data
• Request correction or deletion
• Object to or restrict processing
• Request data portability
• Withdraw consent at any time (where applicable)

To exercise your rights, contact us at hello@internationalenglishtest.com

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) or your local data protection authority.

10. Children's Data

Our services are not intended for children under the age of 13. We do not knowingly collect personal data from children without parental consent.

11. Voice Recordings (English Speaking Test)

When you take the English Speaking Test, we record your spoken answers using your device's microphone. Your browser asks for microphone permission the first time you tap the record button. Nothing is recorded before you tap, and you can stop each recording at any time.

What we record and keep

The audio of each answer, when it was recorded, its length, and simple quality measurements taken in your browser (whether speech was detected and how loud it was). These measurements are used only to ask you to record again if an answer could not be heard. We do not use your recordings to identify you by your voice.

Why we use your recordings

Only to assess your spoken English and to produce your certificate and report. No assessment of any kind runs before you get your certificate.

Automated assessment

Your speaking level and scores are decided automatically by an AI model (Google's Gemini API), without a person reviewing your answers. The model scores each answer against five CEFR-aligned criteria (fluency, coherence, grammar, vocabulary and pronunciation) and your level is calculated from those scores. You can ask for your result to be reviewed by a person by emailing hello@internationalenglishtest.com while your recordings are still kept. Once your recordings have been deleted, a review of the audio is no longer possible.

Legal basis

• While you take the free test and until you decide whether to get a certificate: taking steps at your request before entering into a contract with us (UK GDPR Article 6(1)(b)).
• When you get a certificate: performance of our contract with you (UK GDPR Article 6(1)(b)). The automated assessment is necessary to provide the certificate you ask for (UK GDPR Article 22(2)(a)); you can request human review as described above.
• Keeping certificate records so they can be verified: our legitimate interest in issuing verifiable certificates (UK GDPR Article 6(1)(f)).

Who processes them

• Supabase stores your recordings and test record. Our Supabase project is hosted in the European Economic Area (Ireland).
• Google (Gemini API) receives your recordings to assess your answers after you get your certificate.

Both act as our processors under data processing terms.

International transfers

• Supabase: the recordings are stored in Ireland. Transfers from the UK to the EEA are covered by the UK's adequacy regulations for the EEA. Where Supabase or its sub-processors access data from outside the UK/EEA, Supabase's Data Processing Addendum applies the EU Standard Contractual Clauses together with the UK Addendum issued by the Information Commissioner.
• Google: Google may process or temporarily store data in any country where it or its agents have facilities. Google's Data Processing Addendum for the Gemini API Paid Services covers transfers from the UK through the UK Extension to the EU-US Data Privacy Framework, with the Standard Contractual Clauses as a fallback.

How long we keep them

We keep your recordings only as long as needed to assess your test and handle review requests, then delete them. Your scores, report and certificate are kept.

Deleting your recordings

You can ask us to delete your recordings earlier at any time by emailing hello@internationalenglishtest.com. Deleting them does not cancel your certificate, but a human review of your answers will then no longer be possible.

Your other rights

You can ask for a copy of your recordings, ask us to correct your data, or object to processing, as described in "Your Rights" above. You can also complain to the Information Commissioner's Office (ICO).

12. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page.

13. Contact

If you have any questions about this Privacy Policy or your personal data, please contact: hello@internationalenglishtest.com