Privacy Policy

We believe privacy is a right, not a checkbox. This policy explains exactly what we collect, why, and how you can control it.

Effective date: June 1, 2025  ·  Version 1.0
Summary in plain English We collect your name and email to create your account. We process payments through Stripe — we never see or store your card number. We use an AI model (Claude by Anthropic) to score your practice answers; your answers are processed but not used to train AI models. We don't sell your data, ever.

Contents

  1. Who we are
  2. Information we collect
  3. How we use your information
  4. Legal basis for processing
  5. Sharing your information
  6. AI-powered features
  7. Cookies and local storage
  8. Data retention
  9. Your rights
  10. Security
  11. Children's privacy
  12. International transfers
  13. Changes to this policy
  14. Contact us

1Who we are

FrenchPathway ("we", "us", "our") is an online French language exam preparation service operated by FrenchPathway Inc. We help students prepare for the TCF Canada and TEF Canada examinations required for Canadian immigration (Express Entry, work permits).

Data Controller: FrenchPathway Inc., Canada
Privacy contact: support@frenchpathway.ca

We are subject to Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, provincial privacy laws and the General Data Protection Regulation (GDPR) for users in the European Economic Area.

2Information we collect

2.1 Information you provide directly

DataWhen collectedWhy required
First nameAccount sign-upPersonalize your experience
Email addressAccount sign-upAccount creation, receipts, important notices
Practice responses (typed text, voice transcriptions)During module exercisesAI scoring and feedback
Uploaded images (handwritten work)Writing module — optionalAI handwriting recognition and scoring
Feedback messagesIn-app feedback formProduct improvement
Referral codeWhen you share or use a referral linkReferral reward attribution

2.2 Information collected automatically

DataPurpose
IP addressRate limiting AI scoring calls, fraud prevention, security logging
Browser/device typeDebugging and compatibility
Session activity (pages visited, module progress)Service functionality; stored locally in your browser, not on our servers
Payment metadata (Stripe session ID, plan purchased, timestamp)Subscription verification; card details are never transmitted to us

2.3 Information we do NOT collect

3How we use your information

We do not use your personal information for advertising, sell it to third parties, or use it to build profiles for marketing purposes.

4Legal basis for processing

Under PIPEDA and GDPR, we rely on the following legal bases:

Processing activityLegal basis
Account creation and service deliveryContract — necessary to perform our agreement with you
Payment processing and subscription verificationContract
AI-powered practice scoringContract — core feature of the paid service
Security, rate limiting, fraud preventionLegitimate interest
Product analytics (aggregated, anonymized)Legitimate interest
Legal compliance and responding to lawful requestsLegal obligation
Marketing communicationsConsent (opt-in only)

5Sharing your information

We share data only with the following third-party service providers, and only to the extent necessary to operate our service:

ProviderPurposeData sharedLocation
Stripe, Inc.Payment processingEmail, plan selected. Card details go directly to Stripe — never to us.USA (SCCs / adequacy)
Anthropic, PBCAI scoring of practice responsesPractice text/image; no name or emailUSA (SCCs / adequacy)
Hostinger International Ltd.Web hosting and databaseAccount data stored on serversEU/Lithuania
Google FontsFont renderingYour IP address (standard CDN request)USA

We may also disclose information when required by law (court order, regulatory request) or to protect our rights and the safety of our users. We will notify you of such disclosures unless legally prohibited from doing so.

We never sell your data. No advertising networks, data brokers, or marketing companies ever receive your personal information.

6AI-powered features

FrenchPathway uses Claude (by Anthropic) to score your Writing and Speaking practice responses. Here is how it works and what it means for your privacy:

Do not include sensitive personal information (e.g., your passport number, address, financial details) in your practice writing responses.

7Cookies and local storage

FrenchPathway is a lightweight single-page application. We use browser localStorage (not traditional cookies) to store your session state on your own device. This includes:

This data stays on your device and is not transmitted to our servers during normal browsing. It is cleared when you clear your browser data or log out.

Third-party services (Stripe, Google Fonts) may set their own cookies. Stripe sets cookies for fraud prevention and payment session continuity. Google Fonts may log standard CDN request data.

We do not currently use analytics cookies. If we add analytics in the future, we will update this policy and present a consent choice before any tracking begins.

8Data retention

Data typeRetention period
Account information (name, email, plan)Duration of your account + 2 years after deletion
Payment records (Stripe session ID, plan, date)7 years (tax and financial record requirements)
Referral records3 years from the referral event
AI rate-limit logs (IP address)30 days rolling
Security/audit logs90 days
Practice responses submitted for scoringNot retained — processed and discarded immediately
Uploaded handwriting imagesNot retained — discarded after scoring response is returned
Browser localStorage dataUntil you clear browser data or request deletion

9Your rights

Depending on where you are located, you have the following rights regarding your personal information:

RightWhat it means
AccessRequest a copy of the personal information we hold about you
CorrectionAsk us to correct inaccurate or incomplete information
DeletionRequest erasure of your personal information (subject to legal retention requirements)
PortabilityReceive your data in a structured, machine-readable format
ObjectionObject to processing based on legitimate interest
Withdraw consentWithdraw any consent you have given at any time (e.g., marketing emails)
Lodge a complaintFile a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca

To exercise any right, email support@frenchpathway.ca with the subject line "Privacy Request — [Right]". We will respond within 30 days. We may need to verify your identity before processing the request.

10Security

We take the security of your information seriously and implement the following measures:

No method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that creates a real risk of significant harm, we will notify affected users and the Office of the Privacy Commissioner of Canada within 72 hours of becoming aware of the breach, as required under PIPEDA.

11Children's privacy

FrenchPathway is intended for users aged 16 and older. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@frenchpathway.ca and we will delete that information promptly.

12International data transfers

FrenchPathway is operated from Canada. When we share data with service providers in the United States (Stripe, Anthropic), we rely on standard contractual clauses (SCCs) and adequacy decisions where applicable to ensure your data receives equivalent protection to Canadian standards.

Our hosting provider (Hostinger) operates servers within the European Union, which is recognized by Canada as providing adequate protection for personal information.

13Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

Your continued use of FrenchPathway after the effective date constitutes acceptance of the updated policy. If you do not agree with the changes, you may close your account before the effective date.

14Contact us

For any privacy-related questions, requests, or concerns:

Privacy Officer — FrenchPathway Email: support@frenchpathway.ca
Response time: within 30 days
For urgent security issues: include "URGENT" in the subject line

If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Privacy Commissioner of Canada: