Privacy Policy

Last updated: 20 April 2026

1. Who we are

FluentScore ("we", "us", "our") operates the platform at fluentscore.app. We are the data controller within the meaning of the EU General Data Protection Regulation (GDPR, Regulation 2016/679).

Contact: privacy@fluentscore.app

2. Data we collect and why

2.1 Account data

When you sign in with Google, we receive your name, email address, and profile picture via OAuth 2.0. We use this to create and maintain your account.
Legal basis: Art. 6(1)(b) GDPR — performance of a contract.

2.2 Test progress and scores

We store your answers, section scores, and overall test results so you can resume tests and track progress over time.
Legal basis: Art. 6(1)(b) GDPR — performance of a contract.

2.3 AI-processed responses

Your Speaking and Writing responses are sent to Anthropic's Claude API for evaluation against ETS-style rubrics. These responses are transmitted securely and are not stored by Anthropic beyond the duration of a single API call (subject to Anthropic's own privacy policy).
Legal basis: Art. 6(1)(b) GDPR — performance of a contract.

2.4 Payment data

Subscription billing is handled entirely by Stripe. We store only your Stripe Customer ID — we never see or store your card number or bank details.
Legal basis: Art. 6(1)(b) GDPR — performance of a contract; Art. 6(1)(c) — legal obligation (accounting records).

2.5 Analytics

Only with your consent, we use Vercel Analytics and Speed Insights to measure page performance and usage patterns. These tools do not use third-party tracking cookies; they rely on aggregated, privacy-preserving metrics.
Legal basis: Art. 6(1)(a) GDPR — your consent (opt-in via cookie banner).

2.6 Preferences stored locally

Your language preference (lang) and colour theme (theme) are saved in your browser's localStorage. This data never leaves your device and is not transmitted to our servers.

3. Sub-processors

We share data with the following third parties where necessary to provide the service:

Where processors are located in the United States, transfers are covered by Standard Contractual Clauses (SCCs) adopted by the European Commission (Decision 2021/914) or an applicable adequacy decision.

4. Retention

• Account & test data — retained until you request deletion.
• Stripe billing records — retained for 10 years (French commercial accounting law, Art. L123-22 C. com.).
• Analytics data — retained for up to 90 days in aggregated form by Vercel.

5. Your rights

Under the GDPR you have the right to:

• Access — obtain a copy of the personal data we hold about you (Art. 15).
• Rectification — ask us to correct inaccurate data (Art. 16).
• Erasure — ask us to delete your data ("right to be forgotten") (Art. 17).
• Portability — receive your data in a structured, machine-readable format (Art. 20).
• Restriction — ask us to limit how we process your data (Art. 18).
• Objection — object to processing based on legitimate interests (Art. 21).
• Withdraw consent — revoke analytics consent at any time via the cookie banner (no effect on prior processing).

To exercise any right, email privacy@fluentscore.app. We will respond within 30 days. You may also lodge a complaint with your national supervisory authority. In France: the CNIL.

6. Children

FluentScore is not directed at children under 16 years of age. We do not knowingly collect personal data from minors. If you believe a minor has registered, please contact us immediately.

7. Changes to this policy

We may update this policy to reflect changes in our practices or applicable law. Material changes will be communicated by updating the "Last updated" date above. Continued use of the service after changes constitutes acceptance.

8. Contact

Questions or requests: privacy@fluentscore.app