Privacy Policy

Last Updated: 13 Mar 2025

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

• User-Generated Content: Audio recordings from your spoken practice sessions and AI conversation exercises, for feedback and evaluation.
• Optional Contact Information: Name and email, if voluntarily provided, for account management and customer support.
• Technical and Usage Data: Device type, operating system, IP address, browser, in-app activities, and session data for service improvement and technical support.

Sensitive Permissions: Microphone Access

Our app explicitly requests microphone access to provide these core functionalities:

• AI-driven Conversations: Interactive conversations on provided scenarios (e.g., job interviews, social situations). Your audio responses are recorded, evaluated using AI, and feedback is provided after completion.
• IELTS Speaking Practice Tests: Simulated speaking tests, optionally evaluated by AI models, providing personalized feedback to improve speaking skills.

Your audio data is securely processed and stored via Google's secure infrastructure (Firebase and Google Cloud Storage). Microphone recordings are strictly limited to these purposes. You may withdraw permission anytime through your device settings, but doing so will limit essential app features.

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 audio through AI models to deliver evaluations, enhance learning experiences, and 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 Firebase Authentication, Firebase Storage, Firebase Functions, Google Cloud Storage, Vertex AI: Securely storing and processing user-generated content for AI evaluations. See Google's Privacy Policy.
• Firebase Analytics and Crashlytics: Improving user experience and app stability. See Firebase Privacy Policy.
• AdMob (Google): Serving personalized advertisements. See Google Ad Policy.
• Facebook Advertising: Delivering targeted ads. See Facebook Privacy Policy.

You may opt out of personalized ads through your device settings, but you may still see non-personalized ads.

4. International Transfers and Data Storage

Your data, including audio recordings, may be stored and processed using Google’s secure infrastructure (Firebase, Google Cloud Storage) in locations outside your home country. We implement safeguards to comply with applicable data protection laws. For more details, review Google’s security standards here.

5. Data Retention

We keep your Personal Data only as long as necessary for the purposes described, or as required to meet legal obligations and resolve disputes. Data no longer needed is regularly deleted or anonymized.

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.

For data deletion details, please visit: simplestepsedu.ca/account_data_deletion

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.