Privacy policy

1. Information we collect

1.1 Information you provide

We collect information you voluntarily provide when using the Service, including but not limited to:

• Account information (name, email address, authentication tokens)
• Learner profile (CEFR level, exam date, target tracks, study preferences)
• Payment and billing information (processed by our third-party payment processor)
• Communications with us (support inquiries, feedback, error reports)
• Voice recordings and audio data submitted through speaking practice
• Writing submissions submitted through writing practice

1.2 Information collected automatically

When you use the Service, we automatically collect certain information, including:

• Device information (device type, operating system, browser, unique identifiers)
• Log data (IP address, access times, pages viewed, referrers)
• Usage data (lessons started, answers submitted, time on task, learning progress, spaced-repetition state)
• Approximate location based on IP address
• Cookies and similar tracking technologies

1.3 Information from third parties

We may receive information about you from third-party services, such as authentication providers (e.g., Google Sign-In), analytics providers, and payment processors.

2. How we use your information

We use the information we collect for various purposes, including but not limited to:

• Providing, maintaining, and improving the Service
• Personalising your study plan, lesson recommendations, and review schedule
• Grading writing and (where offered) speaking submissions and providing feedback
• Processing transactions and sending related information
• Communicating with you about the Service, updates, and exam-preparation tips
• Analysing usage patterns to enhance learner experience
• Improving our content, AI-grading models, and speech-recognition systems
• Conducting research and development
• Detecting, preventing, and addressing technical issues, fraud, or security concerns
• Complying with legal obligations
• Any other purpose with your consent or as permitted by law

3. Voice recordings and audio data

The Service may collect voice recordings for pronunciation practice and speech-recognition features. By using these features, you grant us a perpetual, worldwide, royalty-free licence to use, store, process, analyse, and create derivative works from such recordings for purposes including but not limited to grading your practice, improving our speech-recognition technology, training AI models, enhancing the Service, and conducting research. Voice data may be retained as described in Section 6 and may be used in anonymised or aggregated form indefinitely.

4. Writing submissions and AI grading

Writing submissions you provide through the Service are processed by our automated grading systems and may be reviewed by staff for quality assurance and content moderation. By submitting writing through the Service, you grant us the same licence described in Section 3 with respect to your written content. Writing submissions may be retained as described in Section 6 and may be used in anonymised or aggregated form to improve our grading systems.

5. Disclosure of information

We may share your information in the following circumstances:

• Service providers: third-party vendors and processors who perform services on our behalf, including payment processing, cloud hosting, analytics, error monitoring, AI inference, text-to-speech, and customer support.
• Business transfers: in connection with any merger, acquisition, sale of assets, financing, or transfer of all or part of our business, your information may be transferred as a business asset.
• Legal requirements: we may disclose information if required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• With your consent: we may share information with your consent or at your direction.
• Aggregated or de-identified data: we may share aggregated or de-identified information that cannot reasonably be used to identify you.

6. Data retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Even after account termination or deletion, we may retain certain information as necessary for our legitimate business interests, to comply with legal obligations, resolve disputes, enforce agreements, and for backup and archival purposes. Aggregated or anonymised data may be retained indefinitely.

Automatic deletion of user-generated content: in line with the General Data Protection Regulation (GDPR) and the principle of data minimisation, voice recordings and writing submissions are subject to automatic deletion after a defined retention period, except where you have explicitly saved them to your account or where we are required to retain them. Once deleted, this content cannot be recovered. You may download your saved content at any time through your account settings.

7. Data security

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorised access, use, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security and shall not be liable for any unauthorised access, hacking, data loss, or other breaches that may occur despite our reasonable security measures.

8. Cookies and tracking technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your use of the Service. These technologies help us authenticate sessions, analyse usage, administer the Service, and gather aggregate demographic information. You may control cookies through your browser settings, but disabling cookies may affect the functionality of the Service. By using the Service, you consent to our use of cookies and tracking technologies as described herein.

9. Third-party links and services

The Service may contain links to third-party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices or content of such third parties. We encourage you to review the privacy policies of any third-party services you access through our Service. Your interactions with third-party services are governed by their respective policies.

10. International data transfers

Your information may be transferred to, stored, and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home country. By using the Service, you consent to the transfer of your information to such countries. We will take appropriate measures to ensure that your personal information remains protected in accordance with this Policy and applicable law.

11. Your rights and choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• The right to access your personal information
• The right to rectify inaccurate information
• The right to request deletion of your information (subject to legal and operational requirements)
• The right to restrict or object to certain processing
• The right to data portability
• The right to withdraw consent
• The right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

To exercise these rights, contact us using the information in Section 15. We may require verification of your identity before processing your request. We reserve the right to deny requests that are unreasonable, repetitive, or technically impractical, or where we are not required by law to comply.

12. Marketing communications

We may send you communications about new lessons, exam-prep tips, and product updates. You may opt out of marketing communications by following the unsubscribe instructions in those communications or by contacting us. Even if you opt out of marketing communications, we may still send you transactional or administrative messages related to your account or the Service.

13. Changes to this policy

We reserve the right to modify this Policy at any time in our sole discretion. Any changes will be effective immediately upon posting the revised Policy on this page with an updated effective date. Your continued use of the Service after any changes constitutes your acceptance of the revised Policy. It is your responsibility to review this Policy periodically for updates.

14. Disclaimer

While we take reasonable measures to protect your information, we make no warranties or representations regarding the security of your data. The Company shall not be liable for any unauthorised access, disclosure, or loss of personal information resulting from circumstances beyond our reasonable control, including but not limited to hacking, cyberattacks, system failures, or actions of third parties.

15. Contact us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:

Email: support@inburgerencoach.nl

Service: inburgerencoach.nl, inburgerencoach.com
Legal entity: MK Digital Solutions
Chamber of Commerce (KvK): 99591219
VAT number: NL005396845B54