Privacy Policy
Last reviewed: 2026-10-30
At CLBMaster, we take your privacy seriously. This Privacy Policy describes how we collect, use, disclose, and protect your personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws (including Quebec's Law 25, BC PIPA, and Alberta PIPA) when you use our platform, Android application, or Teacher & Coach Portal to prepare for the CELPIP exam.
1. Information We Collect
We collect personal information that you provide directly to us, including:
- Account & Profile Data: Your email address, encrypted password hash (or Google OAuth sign-in verification), current plan or access pass status, and your current and target CLB skill levels. CLBMaster uses a single unified account—we do not store a separate student or teacher role, as any user may study as a student and/or coach others via the Teacher Portal.
- Practice Submissions & Voice Recordings: Written essays, speaking voice audio recordings (stored in Google Cloud Storage), AI-generated speech transcripts, mock test and module responses, and custom Writing/Speaking tasks created in the Teacher Portal.
- Teacher-Student Connection Data: Invitation emails, connection status, assigned tasks, teacher notes, coaching comments, and teacher-adjusted CLB scores when you link accounts with a teacher or student.
- Optional Integrations, Mobile & Billing Metadata: Telegram chat ID and username (if you choose to link our Telegram practice bot), Android push notification device tokens, payment transaction metadata via Stripe or Google Play (we never store raw credit card numbers), and communications with our support team.
2. How We Use Your Information & AI Processing
- AI-Assisted Evaluation & Automated Processing: To provide instant CLB score estimates, transcripts, grammar feedback, script refinements, and vocabulary suggestions, your written responses and speaking voice recordings are processed using automated AI and large language model providers (including Google Gemini and OpenRouter). Your voice recordings are used strictly to transcribe and evaluate your spoken English fluency, pronunciation, vocabulary, and task fulfillment—never for biometric voiceprint identification—and are not sold to third parties.
- Personalized Study & Coaching: To track your progress across Reading, Listening, Writing, and Speaking, generate personalized AI study action plans, and facilitate homework assignments and reviews between connected students and teachers.
- Service & Study Communications: To send account verification emails, password resets, teacher/student invitation notices, inactivity warnings, and optional daily study/streak reminders (which you can toggle on or off in your Account Settings or unsubscribe from via email).
- Platform Improvement & Security: To monitor, debug, and improve the accuracy, reliability, and security of our platform.
3. Sharing Information with Connected Teachers & Coaches
Your practice data is private to your account by default. Access to student data in the Teacher Portal is authorized strictly per active connection. If you choose to connect with a teacher or coach (either by sending an invitation from your Account Settings or by accepting an invitation from a teacher):
- What Is Shared: Your connected teacher will have access to your email address, target CLB levels, practice and mock test history, written essays, speaking audio recordings, AI evaluation breakdowns, and assigned homework status so they can review your work, submit responses on your behalf when authorized, and provide coaching feedback.
- Withdrawing Consent (Revoking Access): You may revoke a teacher's access at any time with a single click in your Account Settings under Teacher & Coach Access. Revoking access immediately stops sharing your profile, recordings, and practice history with that teacher.
4. Cross-Border Data Transfers & Service Providers
While CLBMaster primarily serves learners and educators in Canada, some of our trusted third-party cloud hosting, storage (Google Cloud), email delivery, payment processing (Stripe, Google Play), error monitoring (Sentry), and AI evaluation service providers (Google Gemini, OpenRouter) process and store data on servers located outside of your province or outside of Canada (including in the United States). While personal information is outside of Canada, it is subject to the laws of the jurisdiction in which it is held and may be accessible to courts, law enforcement, and national security authorities of that jurisdiction. We contractually require our service providers to safeguard your data and use it only to provide services on our behalf.
5. Analytics, Cookies & Session Recording
To understand user interaction, diagnose technical issues, and continuously improve our learning tools, we use third-party analytics and session replay services, including Microsoft Clarity.
- What We Capture: Usage metrics, page interactions (clicks, scrolling, navigation patterns), and browser/device diagnostics.
- Privacy & Data Masking: Sensitive information, passwords, payment details, and personal input form fields are strictly masked and protected before transmission to analytics servers.
- Third-Party Privacy: For more details on how Microsoft collects and uses data, please review the Microsoft Privacy Statement.
6. Data Retention, Practice History Limits & Inactive Accounts
We store your practice data and recordings to help you track your progress over time. We implement appropriate technical and organizational safeguards—including encryption in transit, restricted access controls, and PII redaction in system logs—to protect your personal data against unauthorized access, loss, or alteration.
- Rolling 50-Attempt Retention Limit: To minimize unnecessary storage of personal data and voice recordings, CLBMaster retains up to your 50 most recent module attempts per skill. When you exceed 50 attempts in a skill, the oldest attempts and their associated Google Cloud Storage audio files are automatically deleted.
- 6-Month Inactivity Purge: Accounts with no login or practice activity for 6 months (180 days) receive advance email warnings (30 days and 10 days prior to deletion). If the account is not kept active during the 30-day grace period, the account and all associated data, scores, and cloud audio recordings are permanently purged.
7. Your Privacy Rights in Canada
Under Canadian privacy laws (PIPEDA and applicable provincial legislation), you have the right to:
- Access & Correction: Request access to the personal information we hold about you and update or correct inaccurate account details.
- Withdraw Consent & Delete Data: Withdraw consent for teacher data sharing at any time in Account Settings, disconnect optional integrations (such as Telegram), or permanently delete your account and all associated essays, scores, and voice recordings using the Delete Account tool in Account Settings.
- Automated Decision-Making Inquiries: Request information about how our automated AI evaluation systems process your submissions or submit feedback on any AI evaluation directly on the result screen.
8. Contact Us & Privacy Inquiries
If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal information is handled, please contact our Privacy Officer / Support Team at [email protected] or visit our Support page.