Privacy Policy
Last Updated: August 2026
This Privacy Policy explains what personal data CELTESTPIP collects, why we collect it, who we share it with, where it is processed, how long we keep it, and what rights you have over it.
It applies to https://www.celtestpip.com, our mobile applications, and all related services (the "Service"). It forms part of our Terms of Service.
1. Who We Are
STARMOON TECHNOLOGIES INC., operating as CELTESTPIP, is the data controller for the personal data described in this Policy.
- Legal entity: STARMOON TECHNOLOGIES INC.
- Operating as: CELTESTPIP
- Location: Vancouver, British Columbia, Canada
- Contact: [email protected]
Please send all privacy enquiries to the contact address above.
This Policy is written to meet Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Law 25, the EU General Data Protection Regulation (GDPR), and the UK GDPR.
2. Personal Data We Collect
2.1 Account information
When you create an account, we collect your full name and email address. Authentication and credential storage are handled by our authentication provider (see Section 6); we never see or store your password.
2.2 Practice and performance data
As you use the Service, we collect and store your answers, submissions, scores, level estimates, skill breakdowns, practice history, progress, and study goals. This is what makes your history, analytics, and personalized recommendations work.
2.3 Audio and speech data
When you complete a Speaking task, we record your spoken response and:
- Store the audio file so you can replay your attempt and so we can generate feedback
- Send it for automatic transcription to our speech-to-text provider
- Send the resulting transcript to an artificial intelligence provider to generate your score and written feedback
We use your voice only to assess your spoken English for study purposes. We do not use voice data to identify you, to verify your identity, or to create a voiceprint or any other biometric identifier. Accordingly, we do not treat it as biometric data under Article 9 GDPR. We do not use your recordings to train artificial intelligence models.
Speaking recordings are deleted on the schedule in Section 8.
2.4 AI CELPIP Coach chat data
When you use the AI CELPIP Coach, we collect and store:
- The messages you send, including anything you paste in
- The messages the assistant replies with, including tool results shown back to you
- Session metadata: chat ID, timestamps, platform (web, iOS, or Android), browser, and your thumbs-up or thumbs-down feedback
- A transient context block assembled at request time so the assistant can personalize its replies. This contains your first and last name, Pro membership status, and read-only data the assistant requests, such as subscription details, recent practice history, skill scores, and refund status.
You control what you send. Do not paste sensitive information such as passwords, full payment card numbers, government identification numbers, or medical records into the chat. The assistant never needs that data.
2.5 Payment information
Payments are processed by Stripe. We do not receive or store your full payment card number. We retain the transaction record, amount, currency, plan purchased, date, and Stripe's customer and subscription identifiers, which we need for access control, accounting, tax, and refunds.
2.6 Usage and device information
We automatically collect IP address, approximate location derived from it, device and browser type, operating system, referring URL, pages viewed, actions taken, and timestamps. We use IP-derived country and region to decide which cookie consent rules apply to you (see Section 5.3).
2.7 Teacher listings
If you publish a listing in our teacher directory, the information you enter, including your name, photo, biography, qualifications, and rates, is published publicly on the Service. Do not enter anything there you do not want to be public.
2.8 Partnership programme data
If you join our partnership programme, we collect the referral identifiers, attributed purchases, commission balances, and payout requests needed to run the programme and pay you.
2.9 Push notifications
If you allow notifications on your device or browser, our push notification provider stores a device push token and, when you are signed in, an identifier linking that token to your account, together with your notification preferences. We use this to send you study reminders and service updates. You can turn notifications off at any time in your device or browser settings, and delivery stops.
2.10 Cookies and tracking technologies
See Section 5.
3. Legal Bases for Processing
If you are in the EEA or the UK, we rely on the following legal bases under Article 6(1) GDPR.
| Purpose | Legal basis |
|---|---|
| Creating and managing your account; delivering practice content; generating your scores and feedback; the AI Coach; processing payments and refunds | Contract, Art. 6(1)(b). Necessary to provide the Service you asked for. |
| Security, fraud prevention, abuse detection, service reliability, debugging, and product improvement | Legitimate interests, Art. 6(1)(f). We balance these against your rights, and we use the minimum data needed. |
| Analytics and advertising cookies in regions that require opt-in; optional marketing emails | Consent, Art. 6(1)(a). You may withdraw it at any time. |
| Keeping tax, accounting, and transaction records | Legal obligation, Art. 6(1)(c). |
In Canada, we rely on your consent, express or implied depending on the sensitivity of the data and the purpose, as PIPEDA and Quebec Law 25 require. Creating an account and using the Service constitutes consent to the processing necessary to deliver it.
4. How We Use Personal Data
We use personal data to:
- Create and manage your account and authenticate you
- Provide access to the content and features you have purchased
- Generate your scores, level estimates, feedback, analytics, and study recommendations
- Transcribe and assess your speaking responses
- Operate the AI CELPIP Coach, including persisting your chat history so you can resume conversations
- Process payments, renewals, and refunds
- Communicate with you about your account, purchases, and support requests
- Maintain security, prevent fraud and abuse, and enforce our Terms
- Diagnose errors and improve the reliability and quality of the Service
- Measure and optimize our advertising, where you have consented or not opted out
- Comply with legal obligations
We do not sell your personal data. We do not use your practice submissions, speaking recordings, or chat content to train artificial intelligence models, and we do not use chat content for advertising.
5. Cookies, Analytics, and Advertising
5.1 Categories
- Essential cookies. Required for the Service to work: authentication, security, session state, and storing your cookie preferences. Always active.
- Analytics and advertising cookies. Set by us and third parties to measure traffic, understand how the Service is used, and attribute and optimize our advertising. Optional, and controlled by your consent as described in 5.3.
5.2 Analytics and advertising partners
When enabled, these partners may receive your device and browser data, the pages you view, the actions you take, and, when you are signed in, a hashed and irreversible version of your email address used only to match conversions to ad campaigns.
We use, or may use: Google (Analytics 4, Google Ads, YouTube Ads, with Google Consent Mode), Meta (Pixel and Conversions API), TikTok (Pixel and Events API), OpenAI (Ads Pixel and Conversions API), Reddit, Microsoft (Advertising and Clarity), LinkedIn (Insight Tag), X, Snapchat, Pinterest, Amazon, Quora, Taboola, and Outbrain.
Not all are active at any given time; we enable them as our needs require. Each processes data under its own privacy policy. We never share your raw email address, password, or payment details with them.
5.3 Your choices
- If you are in a region that requires opt-in consent, specifically the EEA, the United Kingdom, Switzerland, or Quebec, these technologies are disabled until you accept them through our cookie banner.
- Elsewhere they are enabled by default and you may opt out at any time.
- You can change or withdraw your choice at any time using "Cookie Settings" in the footer, or through your browser settings.
Declining does not affect your ability to use the Service.
6. Data Sharing
We do not sell, rent, or trade your personal data. We share it only with service providers who process it on our behalf, under contract, and only for the purposes below.
| Category of recipient | Why | Data involved |
|---|---|---|
| Hosting, database, and authentication providers | Running the Service, storing your data, signing you in | Account, practice, submission, and chat data |
| Payment processor (Stripe) | Taking payment, managing subscriptions and refunds | Name, email, payment method, transaction records |
| Speech-to-text provider | Transcribing your speaking responses | Your speaking audio and its transcript |
| Artificial intelligence providers | Generating your scores, feedback, and AI Coach replies | Your written and transcribed responses, AI Coach messages, personalization context |
| Error monitoring provider | Detecting and diagnosing faults | Technical error data, which may include an account identifier |
| Referral attribution provider | Running our partnership programme | Referral identifiers, attributed purchase events |
| Push notification provider | Delivering notifications you have allowed | Device push token, account identifier, notification preferences |
Our artificial intelligence providers operate under zero-retention or contractually limited retention terms and do not use your data to train their models.
If you would like to know which specific companies we currently use in any of these categories, email [email protected] and we will tell you.
We may also disclose personal data:
- To comply with law, a regulation, a court order, or a valid request from a public authority
- To protect rights and safety, including enforcing our Terms and investigating fraud, security incidents, or abuse
- In a business transfer, such as a merger, acquisition, reorganization, or sale of assets. We will notify you before your data becomes subject to a different privacy policy.
7. Where Your Data Is Processed
We are based in Canada, but your personal data is stored and processed in the United States, where our hosting and database providers operate. Other providers described in Section 6 may process data in the United States or elsewhere.
This means your personal data is transferred outside Canada, the EEA, and the UK, and may be accessible to courts, law enforcement, and national security authorities of those countries under their laws.
Safeguards. For transfers of EEA and UK personal data, we rely on the Standard Contractual Clauses approved by the European Commission and, for the UK, the International Data Transfer Addendum, together with the technical and organizational measures described in Section 9.
To request details of the safeguards in place, contact [email protected].
8. Data Retention
We keep personal data only as long as we need it for the purpose we collected it, or as long as the law requires.
| Data | Retention period |
|---|---|
| Speaking audio recordings | 30 days from submission, then automatically deleted. Your score, feedback, and transcript are kept as part of your practice history. |
| AI CELPIP Coach chats | 60 days from the last message, then automatically expired and removed. |
| Account information | While your account is active, then removed when you delete your account (see Section 10). |
| Practice and performance history | While your account is active, so your progress and analytics remain available. |
| Payment and transaction records | 6 years from the end of the relevant tax year, as Canadian tax and accounting law requires. We keep these even after account deletion. |
When a retention period ends, we delete the data or irreversibly anonymize it. Anonymized and aggregated statistics that cannot identify you may be kept indefinitely.
9. Data Security
We protect personal data with encryption in transit (HTTPS/TLS), encryption at rest through our hosting and database providers, access controls and least-privilege permissions for our team, delegated authentication so we never handle your password, and error monitoring to detect faults quickly.
No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach occurs that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as the applicable law requires.
10. Your Privacy Rights
Depending on where you live, you have the following rights.
If you are in the EEA or the UK, under Articles 15 to 22 GDPR:
| Right | What it means |
|---|---|
| Access (Art. 15) | Get a copy of the personal data we hold about you |
| Rectification (Art. 16) | Correct data that is inaccurate or incomplete |
| Erasure (Art. 17) | Have your data deleted, where no overriding basis to keep it applies |
| Restriction (Art. 18) | Limit how we process your data in certain circumstances |
| Portability (Art. 20) | Receive your data in a structured, machine-readable format, or have it sent to another controller |
| Object (Art. 21) | Object to processing based on legitimate interests, including profiling |
| Withdraw consent (Art. 7(3)) | Withdraw consent at any time, without affecting processing already carried out |
If you are in Canada, PIPEDA and, in Quebec, Law 25 give you the right to access the personal information we hold about you, to have it corrected, to withdraw consent subject to legal and contractual limits, and, in Quebec, to data portability and to be informed about automated decisions.
What you can do yourself
- Delete your account. Go to Profile, then Delete account. This signs you out immediately, prevents further sign-in, and cancels any active subscription. Within 7 days we erase your personal data, apart from records we are required by law to keep, such as the payment records described in Section 8. Deletion cannot be undone.
- Update your account information at any time from your profile.
- Opt out of non-essential email using the unsubscribe link in any message.
- Turn off push notifications in your device or browser settings.
- Change your cookie choices through "Cookie Settings" in the footer.
- Stop using the AI CELPIP Coach, which is entirely optional. The rest of the Service works without it.
Everything else
For any other request, email [email protected]. We will respond within the time the applicable law requires, which is generally 30 days. We may need to verify your identity first. Exercising these rights is free, unless a request is manifestly unfounded or excessive.
11. Automated Processing
The Service scores your written and spoken responses automatically and generates feedback and level estimates using artificial intelligence.
These are educational assessments for study purposes only. They are unofficial estimates, they are not official test results, and they do not produce legal effects or similarly significant effects for you within the meaning of Article 22 GDPR. They do not determine access to employment, credit, immigration, education, or any other benefit.
If you believe a score is materially wrong, contact [email protected] and a person will review it.
12. Children's Privacy
The Service is intended for people aged 16 and over. We do not knowingly collect personal data from anyone under 16.
If you believe a person under 16 has given us personal data, contact [email protected] and we will delete it promptly.
13. Third-Party Services
The Service links to third-party websites and services that we do not control. This Policy does not apply to them, and we are not responsible for their content or privacy practices. Review their policies before providing personal data.
14. Changes to This Policy
We may update this Policy. When we do, we will revise the "Last Updated" date above and post the new version here.
For material changes, such as a new purpose for processing, a new category of data, or a new sub-processor that materially changes where your data goes, we will give you reasonable notice by email or in-product notice before the change takes effect. Where the law requires consent, we will ask for it.
15. Complaints
If you have a concern, contact us first at [email protected]. We take every complaint seriously and will work to resolve it.
You also have the right to complain to a supervisory authority:
- Canada: the Office of the Privacy Commissioner of Canada, or the Commission d'accès à l'information du Québec if you are in Quebec
- EEA: your national data protection authority, listed on the European Data Protection Board website
- United Kingdom: the Information Commissioner's Office
16. Contact Us
STARMOON TECHNOLOGIES INC. (operating as CELTESTPIP) Vancouver, British Columbia, Canada
- 📧 Email: [email protected]
- 🌐 Website: https://www.celtestpip.com