Privacy Policy

1.1. This Privacy Policy explains how personal data is processed when you use the "IELTS Test" online IELTS preparation platform (the "Platform") available at the website where this document is published, including its international versions en.ielts-test.online, in.ielts-test.online and cn.ielts-test.online.
1.2. The Platform provides full IELTS mock exams (Listening and Reading are checked automatically; Writing and Speaking are assessed by an AI examiner against the public IELTS band descriptors), online courses with smart presentations, practice tasks and flashcards, and guides. Results of mock exams and AI assessments are estimates for preparation purposes and are not official IELTS results.
1.3. This Policy is addressed to users outside any single national framework and is drafted to meet the requirements of the EU General Data Protection Regulation (GDPR) and other applicable data protection laws. Where you are located in the EU/EEA, the UK or another jurisdiction with similar rights, you have the rights described in section 8.
1.4. IELTS is a registered trademark of the British Council, IDP: IELTS Australia and Cambridge University Press & Assessment. The Platform is an independent project and its mock exams are not the official IELTS test.

2.1. The data controller is Aziya Global Limited, a company registered in Hong Kong, Business Registration No. 81186235, address: Unit B6, 12th Floor, No. 888 King's Road, Quarry Bay, Hong Kong (the "Company", "we", "us").
2.2. Contact for all matters relating to this Policy and for data-protection requests: viktor.pavliukov@aziyaglobal.com.
2.3. For the purposes of this Policy, "personal data" means any information relating to an identified or identifiable natural person.

3.1. We process only the data necessary to operate the Platform and provide the services you request:
- identification and contact data: e-mail address, name, optional phone number;
- account data: sign-in is by a one-time code sent to your e-mail; we do not use passwords and do not store passwords;
- learning data: learning progress, courses taken, practice tasks and flashcards, mock-exam answers, Writing texts and Speaking voice recordings;
- payment records: fact, date, amount and service name received from the payment service provider; we do not store card data;
- partner programme data: your personal link, referrals, credited share and payout information where you participate;
- technical data: IP address, device and browser information, date and time of access, cookies and similar technologies.
3.2. Speaking voice recordings are stored privately and used only to assess the candidate. Recordings are transcribed and Writing texts and Speaking answers (as transcriptions) are sent to AI service providers for scoring.
3.3. We do not process special categories of personal data or knowingly infer such data from your Writing or Speaking answers.

4.1. We process personal data only where we have a legal basis under the GDPR. The main purposes and bases are:
- to register your account, authenticate you by one-time code and provide access to the Platform, courses, mock exams and guides — performance of a contract;
- to check Listening and Reading answers automatically and to assess Writing and Speaking via AI against the public band descriptors and to show you results and feedback — performance of a contract;
- to process payments and manage subscriptions and purchases. Prices are shown on the Platform in US dollars (for example, a single mock exam or a monthly "Learning" subscription that renews monthly until cancelled; cancellation stops future renewals and access remains until the end of the paid period) — performance of a contract and compliance with legal obligations relating to accounting;
- to operate the partner programme: to generate your personal link, attribute registrations and payments made by users who registered via the link, calculate the share credited to you (25% unless an individual rate is agreed and shown in your account) and, on your request, to consider payouts under a separate agreement after verification of your identity and tax status — performance of a contract and legitimate interests in operating the programme; where a payout request does not meet the verification conditions we may reject it and the credited amount remains available;
- to communicate with you, respond to requests and provide technical support — performance of a contract and legitimate interests in providing support;
- to ensure security, prevent fraud and abuse, troubleshoot and maintain the Platform — legitimate interests in keeping the Platform secure and functional;
- to improve the Platform and analyse aggregated use — legitimate interests, and, where required, consent;
- to send service-related notices about your account, purchases or changes to terms — performance of a contract and legitimate interests;
- to send marketing communications only where you have given consent — consent, which you may withdraw at any time;
- to use analytics cookies and similar technologies — consent obtained via the cookie banner (see section 9);
- to comply with legal obligations, enforce terms and respond to lawful requests from authorities — compliance with a legal obligation and legitimate interests.
4.2. Where we rely on legitimate interests, we balance those interests against your rights and freedoms. You may object to processing based on legitimate interests as described in section 8.
4.3. Where we rely on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

5.1. Processing is carried out using automated means. Access to personal data is limited to authorised personnel who need it to operate the Platform and to processors acting on our instructions.
5.2. We do not sell personal data. We share personal data only with:
- hosting providers — servers for the Platform are located in Austria (EU); the Chinese version cn.ielts-test.online is hosted in Hong Kong;
- the e-mail delivery provider that sends sign-in codes and service notifications;
- payment service provider lava.top, which processes payments on its secure pages; we receive only payment records and do not receive or store card data;
- AI service providers that transcribe Speaking recordings and score Writing and Speaking answers on our behalf;
- analytics providers, but only if you consent via the cookie banner;
- professional advisers, auditors and authorities where disclosure is required by law or to protect our rights.
5.3. All processors act under contracts that require them to process data only on our instructions and to implement appropriate confidentiality and security measures.

6.1. Your personal data is primarily processed and stored in the EU (Austria). The Chinese version is hosted in Hong Kong.
6.2. Transfers outside the EU/EEA may occur when we use service providers located in other countries, including Hong Kong and providers of AI scoring and payment processing, and when you use cn.ielts-test.online hosted in Hong Kong.
6.3. Where personal data is transferred outside the EU/EEA to a country not recognised as providing an adequate level of protection, we use appropriate safeguards, such as standard contractual clauses approved by the European Commission, and, where necessary, additional technical and organisational measures. You may request information about the safeguards applied by contacting us at viktor.pavliukov@aziyaglobal.com.
6.4. Speaking transcriptions and Writing/Speaking answers sent to AI service providers are transferred only to the extent necessary to provide the scoring service.

7.1. We retain personal data while your account exists and is used to provide the Platform to you.
7.2. When you delete your account or when data is no longer necessary for the purposes for which it was collected, we delete or anonymise it within 30 days, unless a longer retention period is required by law (for example, for accounting or tax records) or to resolve disputes and enforce agreements.
7.3. Speaking voice recordings may be deleted earlier than the general retention period. Transcriptions and scores derived from them are retained as part of your learning data until account deletion.
7.4. If you withdraw consent for analytics, we stop the related processing going forward; data already collected on the basis of consent remains lawful until withdrawal.

8.1. Subject to applicable law and its limitations, you have the following rights:
- right of access — to obtain confirmation whether we process your data and to receive a copy;
- right to rectification — to correct inaccurate or incomplete data;
- right to erasure — to request deletion of your data where it is no longer necessary, where you withdraw consent, where you object and there are no overriding legitimate grounds, or where processing is unlawful;
- right to restriction — to request that we limit processing in certain circumstances, for example while a rectification or objection request is being considered;
- right to data portability — to receive data you provided to us on the basis of consent or contract in a structured, commonly used and machine-readable format and to transmit it to another controller where technically feasible;
- right to object — to object at any time to processing based on legitimate interests, including profiling based on those interests, and to object to direct marketing;
- right to withdraw consent — where processing is based on consent, to withdraw it at any time;
- right to lodge a complaint — to complain to a supervisory authority in your EU/EEA member state, in the UK or in another jurisdiction where you have the right to do so.
8.2. You may exercise your rights by contacting us at viktor.pavliukov@aziyaglobal.com. We may need to verify your identity (for example, via the e-mail address associated with your account) before acting on a request.
8.3. We will respond without undue delay and in any event within one month of receipt of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests, and we will inform you of any extension and the reasons for it.
8.4. You will not be charged for exercising your rights unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act, as permitted by law.
8.5. For partner programme payouts, verification of identity and tax status is required under a separate agreement; this is distinct from the general rights requests described above.

9.1. The Platform uses cookies and similar technologies. You can manage your choices via the cookie banner and your browser settings. Blocking certain cookies may affect functionality, such as staying signed in.
9.2. Categories of cookies we use:
- essential cookies — strictly necessary to provide the Platform, to authenticate you via one-time code, to keep you signed in, to remember your settings and to process payments and security. These are set on the basis of our legitimate interests and the need to perform the contract; they do not require consent.
- analytics cookies — used only with your consent to understand how the Platform is used and to improve it. These are set only if you accept them via the banner. You may withdraw consent at any time via the banner or browser settings, which will apply going forward.
9.3. Analytics processing is carried out only where you have consented. If you do not consent, only essential cookies are used.
9.4. You may delete or block cookies in your browser at any time. Information on how to do this is available in your browser's help documentation.

10.1. We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or destruction, including transmission over HTTPS, access controls, and limited access on a need-to-know basis.
10.2. No method of transmission or storage is completely secure. If you have reason to believe your account has been compromised, please contact us promptly at viktor.pavliukov@aziyaglobal.com.

11.1. The Platform is not directed to children under 16. We do not knowingly process personal data of children under 16 without the consent or authorisation of a parent or legal guardian.
11.2. If you are under 16, you may use the Platform only with the consent of your parent or guardian. If we learn that we have collected data from a child under 16 without appropriate consent, we will delete it promptly. Parents or guardians may contact us at viktor.pavliukov@aziyaglobal.com to exercise rights on behalf of the child.

12.1. We may update this Policy from time to time to reflect changes in our processing, technology, legal requirements or other reasons. The updated version will be published on the Platform and the "Published" date at the top will be revised.
12.2. Where changes are material, we will provide additional notice, for example via the Platform or by e-mail, where appropriate. We encourage you to review this Policy periodically.
12.3. The current version is always available at the website where this document is published.

13.1. For questions, requests or complaints relating to this Policy and the processing of personal data, contact: Aziya Global Limited, Unit B6, 12th Floor, No. 888 King's Road, Quarry Bay, Hong Kong, e-mail: viktor.pavliukov@aziyaglobal.com.
13.2. This Policy and any disputes relating to it are governed by the laws of the Hong Kong Special Administrative Region. This does not limit any mandatory consumer rights or protections you have under the laws of your country of residence that cannot be waived by agreement.