Privacy Policy

Last Updated: 25 Sep 2026

This policy applies to the IELTS Speaking - AI Coach app, version 3.0 and later. For earlier versions of the app, see our previous app privacy policy.

This Privacy Policy describes how SimpleSteps Education Inc. (“we,” “our,” or “us”) collects, uses, discloses, and safeguards your personal data (“Personal Data”) when you use our Android application and related services designed to enhance your English-speaking skills, including preparation for the IELTS speaking test. Our platforms, including websites, mobile applications, and related services, are collectively called the “Services.”

Data Controller: SimpleSteps Education Inc.
Website: simplestepsedu.ca
Email: info@simplestepsedu.ca

By using our Services, you acknowledge you have read, understood, and consent to this Privacy Policy. If you disagree with any part, please discontinue using the Services.

1. Types of Data We Collect

• Account Information: Your email address, the display name you choose, and your sign-in method (email and password, or Google Sign-In through Firebase Authentication).
• Your Practice: Audio recordings of your spoken answers, drills and live conversations; their transcripts; messages you send to the AI coach; and the scores, band estimates and feedback generated from them.
• Learning Profile: Your study plan, progress, and details the app infers from your practice (for example, skills you are working on, or preferences you mention). You can review, correct or dismiss these in the app under “What your coach knows”.
• Purchases and Allowances: Google Play purchase and subscription records (product, status, purchase token, renewal dates) and how much of your allowance you have used. We never receive your card or payment details; Google Play handles payment.
• Device Identifier: A one-way hashed form of your device’s Android ID, used to apply free allowances and free trials once per device and to prevent abuse (fraud prevention).
• Technical and Usage Data: Device type, operating system, app version, time zone, IP address, notification token, in-app activity, crash reports, and performance data, for running the Services, reminders, analytics and support. Firebase Analytics may also use your device’s advertising ID for analytics and to measure where app installs come from; you can reset or delete it in your device’s settings.
• Feedback and Reports: Feedback you send us and AI content you report from within the app.

Sensitive Permissions: Microphone Access

The app requests microphone access only when you start recording, for these core features:

• Speaking Practice, Drills and Mock Tests: Your answers are recorded and, when you ask for feedback, uploaded and evaluated by AI.
• Live Conversations: Your voice is streamed in real time to an AI conversation partner while the conversation is running. A copy of the conversation stays on your phone so you can listen back; your answers are uploaded only if you ask for feedback on the conversation.
• AI Coach: Voice messages you send to the coach are uploaded and transcribed.

Recordings are used only for these purposes. You may withdraw microphone permission at any time through your device settings, but speaking features will then not work.

Note for CCPA and similar laws: We may collect identifiers, internet/network activity, and usage-based inferences, directly or automatically, through interactions with our Services.

2. How We Use Your Data and Legal Bases

• Providing and Improving Services: Processing your recordings, transcripts and messages with AI models to produce evaluations, coach replies, live conversations and your study plan, and to improve our offerings.
• Optimizing User Experience: Analyzing app usage, resolving technical issues, and refining functionality.
• Security and Compliance: Protecting against fraud, misuse, and complying with applicable laws.
• Communication and Support: Responding to inquiries, managing accounts, and delivering customer support.

Our legal bases for processing may include performance of a contract (delivering requested services), legitimate interests (improving service, ensuring security), and explicit consent (especially for microphone usage). You may withdraw consent at any time.

3. Google Services and Third-Party Technologies

We use Google’s services and infrastructure, including:

• Google Cloud (Cloud Run, Cloud SQL, Cloud Storage), Firebase Authentication and Firebase Storage: Running our servers, and storing your account, practice history and recordings. See Google's Privacy Policy.
• Vertex AI (Google Gemini models): Evaluating your recordings, transcribing speech, generating coach replies and study plans, and powering live conversations. Google processes this content as our service provider.
• Google Play Billing: Processing subscriptions and purchases, which we verify with Google Play.
• Firebase Cloud Messaging: Sending notifications, such as when your feedback is ready or a practice reminder.
• Firebase Analytics, Crashlytics and Performance Monitoring: Improving user experience and app stability. See Firebase Privacy Policy.

Advertising: The current version of the app shows no ads. Earlier versions showed ads through AdMob (Google) and Facebook (Meta) advertising, which may have used your device’s advertising identifier for personalized ads; if you still use an earlier version, you can opt out of personalized ads in your device settings. See the Google Ad Policy and Facebook Privacy Policy.

4. International Transfers and Data Storage

Your account data and new recordings are stored on Google Cloud in Mumbai, India (asia-south1). Recordings from earlier versions of the app may be stored in the United States. AI processing by Google may take place in other countries, including the United States (for example, live conversations). We rely on Google’s safeguards and contractual commitments for these transfers; see Google’s security standards here.

5. Data Retention

We keep your Personal Data while your account exists, so your history, recordings and plan remain available to you. You can delete individual results in the app, and you can delete your whole account at any time (see section 9). After an account deletion, your data is removed from our live systems; copies in our encrypted database backups and storage recovery expire within about a week. We keep only a record that the deletion took place (an internal account identifier and timestamps). Google Play keeps its own purchase records.

6. Disclosure of Your Data

• Service Providers: We share data (including audio recordings) under strict agreements with trusted providers like Google, solely for service delivery and analytics.
• Legal Compliance: Data may be disclosed to comply with legal requirements, protect rights, or ensure user safety and service integrity.
• No Sale of Data: We do not sell, lease, or trade your Personal Data.
• Aggregated or Anonymized Data: Non-identifiable information may be used for analytics and service improvements.

7. Cookies and Similar Technologies

We use cookies, SDKs, and similar tools to enhance user experiences and measure performance. You can disable some of these in your device settings, but this may affect functionality.

8. Security

We employ industry-standard security measures to protect Personal Data. However, no internet transmission or electronic storage method is fully secure.

9. Your Rights and Choices (Including Data Deletion)

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict processing of your Personal Data.

Deleting your account: In the app, open your profile (“You”) and choose Delete account. This removes the data stored on your phone immediately and starts deletion of your data on our servers. You can also request deletion without the app; see simplestepsedu.ca/ai_coach_account_deletion. Deleting your account does not cancel a Google Play subscription; cancel it in Google Play.

10. Roles and Responsibilities

We act as the data controller for collected Personal Data. Third-party service providers act as data processors, bound by contractual obligations to protect your data.

11. Changes to This Privacy Policy

We may update this policy periodically. Significant changes will be communicated via an updated “Last Updated” date and, if required, by obtaining your consent. We recommend reviewing this policy regularly.

12. Children’s Privacy

Our Services are not intended for users under 16. If you believe we inadvertently collected Personal Data from a child under 16, please contact us at info@simplestepsedu.ca, and we will delete it promptly.

13. GDPR and CCPA Rights

If you reside in a region protected by laws such as the GDPR (EU/EEA) or CCPA (California), you may have rights to access, rectify, delete, or limit the processing of your Personal Data, as described elsewhere in this Policy. To exercise these rights, please contact us at info@simplestepsedu.ca.

14. Contact Us

Email: info@simplestepsedu.ca
Website: simplestepsedu.ca

By using our Services, you explicitly consent to this Privacy Policy and our processing of your Personal Data. If you disagree, please discontinue using our Services.