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PrivacyPolicy.

Last updated · 2026-05-167 min read
Jump to section · 12 sections
  1. What we collect
  2. How we use it
  3. Who we share with
  4. AI grading & your submissions
  5. Your rights
  6. Data retention
  7. Children
  8. Security
  9. International transfers
  10. Cookies
  11. Changes
  12. Contact

What we collect

You give us

  • Email address (account).
  • Name (optional).
  • Practice submissions: written answers, voice recordings, multiple-choice responses.
  • Payment info — processed by Stripe and RevenueCat. We never see your card number.

We collect automatically

  • Device type, operating system, app version.
  • Usage analytics — which features, how long, when.
  • IP address — security and approximate geolocation.
  • Crash reports.

How we use it

  • Run your account.
  • Grade your practice and predict your CLB score.
  • Improve clbpass — find what works, see where users get stuck.
  • Send transactional email (receipts, password resets).
  • Send marketing email — opt-in only.
  • Prevent fraud and abuse.
  • Meet legal obligations.

Who we share with

Third-party processors who handle data on our behalf. Each has its own privacy commitments. We pick ones that handle data responsibly.

  • Stripe

    web payments

  • RevenueCat

    subscriptions

  • Loops

    email

  • Vercel

    website hosting

  • Apple · Google

    distribution + IAP

  • Anthropic

    AI grading

  • PostHog

    analytics

  • Sentry

    error monitoring

We do not sell your personal data. Ever.

AI grading & your submissions

When you submit a practice answer for AI grading, the text or audio is sent to our AI provider (currently Anthropic) for analysis. They do not retain it for training general-purpose models without explicit consent.

We may use anonymized, aggregated practice data to improve clbpass — for example, noticing 70% of users miss a grammar rule and adjusting drills accordingly. Aggregate data cannot be linked back to you.

You can delete individual practice submissions at any time from your account. Deletion is permanent within 30 days.

Your rights

Wherever you live, you can:

  • Ask what data we have about you.
  • Ask us to correct inaccurate data.
  • Ask us to delete your account.
  • Export your data in a portable format.
  • Withdraw consent for marketing emails.

Data retention

Account data
Until you delete it
Practice submissions
Until you delete them or your account
Payment records
7 years (Canadian tax law)
Anonymized analytics
Indefinitely (no longer linked to you)

Children

clbpass is for users 18 and over. We don't knowingly collect data from anyone younger. If we learn we have, we delete it.

Security

Industry-standard encryption — HTTPS everywhere, encrypted databases at rest, hashed passwords. No system is perfectly secure, but we take this seriously. If a breach affects you, we'll notify you and the relevant authorities promptly.

International transfers

clbpass is operated from Canada. If you use it from elsewhere, your data is transferred to Canada and to countries where our processors operate — primarily the United States for Stripe, Anthropic, and similar.

Transfers happen under standard contractual clauses and the processors' own compliance frameworks.

Cookies

Our website uses minimal cookies:

  • Essential — login, security, session state.
  • Analytics — anonymized and privacy-conscious.

No third-party advertising or cross-site tracking cookies. Where required, a consent banner appears.

Changes

We may update this policy. Material changes get an email notice. The version posted with the latest date at the top is always current.

Contact

founder@clbpass.comclbpass, Toronto, Ontario, Canada