Privacy Policy – BandForge

Last updated: 2026-02-12
Version: 2.0

1. Who We Are

This Privacy Policy explains how your personal information is collected, used, and protected when you use BandForge (the “Service”).

BandForge is operated by IP Pavlushkin Alexander (Individual Entrepreneur, registered in the Kyrgyz Republic), trading as BandForge (“we”, “us”, or “BandForge”).

• Website: linguo.me and ielts.linguo.me
• Contact: support@linguo.me

We process your data in compliance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws.

2. Data We Collect

Account data

• Name and email address (provided during registration)
• Authentication method (email/password or Google OAuth)

Writing data

• Essays, overview attempts, and drill responses you submit through the Service

Progress data

• Skill map status and drill completion history
• Session history and timestamps
• Band score estimates generated by AI

Device and technical data

• Browser type, operating system, screen size
• IP address (for security and analytics)

Analytics data

• Page views, clicks, scroll depth, session duration
• Heatmaps and session replays (anonymised)
• Collected via PostHog, Microsoft Clarity, and Google Analytics

Payment data

• Payments are handled entirely by Paddle.com as our Merchant of Record
• We do not collect, store, or have access to your credit card numbers, bank details, or other payment credentials
• We receive payment confirmation from Paddle (transaction ID, payment status, and purchase date)

3. How We Use Your Data

We use your data to:

• Provide the Service — process your writing submissions, generate AI feedback, track your skill progress, and deliver your personalised learning experience.
• Improve the product — analyse usage patterns, identify areas where users struggle, and improve drills, feedback quality, and user experience.
• Maintain security — detect abuse, prevent fraud, and protect the integrity of the Service.
• Communicate with you — respond to support requests and send important service updates. We will only send marketing communications if you opt in.

4. AI Processing

• Your writing submissions are sent to third-party AI providers for feedback generation (band score estimates, per-criterion analysis, suggestions for improvement).
• We currently use services from OpenAI, Google (Gemini), and Anthropic, and may use additional providers (including self-hosted fine-tuned models) in the future. The specific provider used may vary by feature and over time.
• Where available, we configure AI providers not to use your data for model training. For example, OpenAI’s API data usage policy states that API inputs and outputs are not used to train their models.
• AI outputs may be inaccurate or incomplete. See our Terms of Service (Section 8: AI Disclaimer) for details.

5. Payment Processing

• All payments are processed by Paddle.com Market Limited (“Paddle”) as our Merchant of Record.
• Paddle collects and processes your payment information directly. We never see or store your payment details.
• Paddle’s privacy policy: https://www.paddle.com/legal/privacy
• Paddle’s buyer terms: https://www.paddle.com/legal/terms
• For payment-related questions: https://paddle.net

6. Cookies

We use the following categories of cookies:

Essential cookies

• Session management and authentication
• These are necessary for the Service to function and cannot be disabled

Analytics cookies

• PostHog — product analytics, feature usage tracking, and session replay. See PostHog Privacy Policy.
• Microsoft Clarity — heatmaps, session replay, and behavioural analytics (first- and third-party cookies). See Microsoft Privacy Statement.
• Google Analytics — page views, user flow, and aggregated usage statistics. See Google Privacy Policy.

Payment cookies

• Paddle Checkout sets cookies for fraud prevention, payment flow, and session continuity. These are essential for completing purchases.

You can manage non-essential cookies via your browser settings or our cookie consent banner. Blocking analytics cookies will not affect the core functionality of the Service.

7. Legal Bases for Processing (GDPR)

We process your personal data based on:

8. Data Sharing

We share your data with the following third parties, solely for the purposes described:

We do not sell your personal data. We do not share your data with advertisers or data brokers.

9. Infrastructure & Data Storage

We may change hosting regions and providers as the Service scales. Your data may be processed in any of the regions listed above, or in additional regions in the future.

Where your data is transferred outside the UK or EU, transfers are protected by Standard Contractual Clauses (SCCs) and, where applicable, the UK International Data Transfer Addendum.

10. Data Retention

11. Your Rights

If you are in the UK or EU, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data (“right to be forgotten”)
• Restrict processing in certain circumstances
• Object to processing based on legitimate interests
• Data portability — receive your data in a structured, machine-readable format

How to exercise your rights:

• Account deletion is available directly in the app
• For all other data requests, email support@linguo.me
• We will respond within 30 days of receiving your request

You also have the right to lodge a complaint with a supervisory authority in your country of residence.

12. Children

• The minimum age to use BandForge is 13 years old, aligned with OpenAI’s age requirements.
• Users under 16 in the EU/UK require parental or guardian consent to use the Service.
• If we learn that we have collected data from a child below the applicable age without proper consent, we will delete it promptly.

13. Security

We take reasonable measures to protect your data, including:

• Encryption in transit (TLS/HTTPS) and at rest
• Access controls and least-privilege principles
• Regular security reviews

No system is 100% secure. If you become aware of a security vulnerability, please report it to support@linguo.me.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available at /privacy. If we make material changes, we will notify you via email or a prominent notice on the Service.

15. Contact

For any questions about this Privacy Policy or your personal data:

• Email: support@linguo.me

Last updated: 2026-02-12