Privacy Policy

This Privacy Policy explains how Apex Proficiency, operated by Igor Gasperoni Stori (CNPJ 59.667.880/0001-05) ("we," "us"), collects, uses, shares, and protects your personal data when you use our CELPIP practice platform (the "Service"). It is written to comply with Brazil's General Data Protection Law (LGPD, Law No. 13,709/2018) and to give you a clear picture of your data no matter where you access the Service from.

1. Data we collect

• Account data: your email address, password (stored encrypted), and optional profile details such as full name, native language, target CELPIP band, exam date, and weekly study goal.
• Practice and progress data: your answers, timing, and scores for every practice attempt, your estimated level per skill, streaks, points, and study-plan activity.
• Writing and Speaking submissions: the essays you write and the audio you record during Writing and Speaking practice, together with the AI-generated and human-corrector feedback produced from them.
• Payment data: which plan you bought and when. Your card details are collected and processed directly by Stripe; we never see or store your full card number.
• Usage data: pages visited, general device and browser information, and aggregated usage patterns, collected through Google Analytics.

2. How we use your data

• To create and maintain your account and let you sign in securely;
• To run practice sections, grade your Writing and Speaking responses (first by an AI system, then confirmed by a human corrector), and show you your estimated level and progress over time;
• To process your payment and grant access to the plan you purchased;
• To provide customer support when you contact us;
• To keep the Service secure and prevent abuse;
• To understand, in aggregate, how the Service is used so we can improve it; and
• To send you service-related messages (such as progress reminders) and, only if you have not opted out, occasional emails about Apex Proficiency.

We do not sell your personal data, and we do not use your Writing or Speaking submissions for any purpose other than providing you with feedback and operating the Service.

3. Who we share data with

We share the minimum data necessary with the following service providers (subprocessors), each acting under their own privacy terms:

• Supabase, which hosts our database and handles authentication;
• Vercel, which hosts the application;
• Stripe, which processes payments;
• Anthropic, whose AI models generate the first-pass feedback on your Writing and Speaking submissions; and
• Google Analytics, which provides aggregated usage analytics.

Human correctors who review your Writing and Speaking submissions are staff or contractors of Apex Proficiency acting under confidentiality obligations. We do not share your data with third parties for their own marketing purposes. We may also disclose your data to courts, regulators, or other authorities when required by law.

4. Where your data is processed

Some of the providers above process data outside Brazil, including in the United States. When that happens, we rely on those providers' own safeguards and, where applicable, standard contractual mechanisms recognized under the LGPD for international data transfers.

5. How long we keep your data

We keep your account and practice data for as long as your account is active, so your progress history stays available to you. If you ask us to delete your account, we will delete or anonymize your personal data within a reasonable period, except where we must keep certain records (for example, payment records) to meet legal obligations.

6. Your rights

Under the LGPD, and regardless of where you live, you can ask us to:

• Confirm whether we process your data, and access a copy of it;
• Correct incomplete, inaccurate, or outdated data;
• Delete your account and personal data;
• Receive your data in a portable format; and
• Withdraw consent or object to a specific use of your data.

To exercise any of these rights, email support@apexproficiency.com. We will respond within 15 (fifteen) days.

7. Security

We use industry-standard measures, such as encrypted connections and access controls, to protect your data. No system is completely secure, and we encourage you to use a strong, unique password for your account.

8. Cookies and analytics

We use essential cookies to keep you signed in, and Google Analytics to understand aggregated usage of the Service. Google Analytics is only loaded in our production environment. You can control cookies through your browser settings.

9. Children's privacy

The Service is not directed at children under 16, and we do not knowingly collect personal data from them.

10. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last updated" date above and, where appropriate, notify you.

11. Contact

For any question about this Privacy Policy or your data, contact us at support@apexproficiency.com.