{ "privacy": { "seo": { "title": "Privacy Policy | CEFR Hub AI", "description": "Learn how CEFR Hub AI protects your personal data in compliance with GDPR, PIPEDA, Quebec's Law 25 and FERPA." }, "title": "Privacy Policy", "lastUpdated": "Last updated:", "sections": { "intro": { "title": "Introduction", "content": "CEFR Hub AI (\"we\", \"our\", \"us\") is committed to protecting your privacy. This policy explains how we collect, use, and protect your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector (Law 25), the General Data Protection Regulation (GDPR), and the Family Educational Rights and Privacy Act (FERPA) where applicable." }, "dataCollected": { "title": "1. Data We Collect", "intro": "We collect and process the following personal data:", "items": { "account": "Account Information: Email address, name (optional), password (encrypted)", "results": "Evaluation Results: Assigned CEFR levels, detailed analyses, personalized recommendations", "metadata": "Metadata: Evaluation title, evaluated language, evaluation type (oral/written), timestamp", "technical": "Technical Data: IP address, browser type, device information" }, "notStored": { "title": "Data NOT Stored", "content": "Audio files submitted for oral evaluation and texts submitted for written evaluation are NOT stored on our servers. They are analyzed in real-time by our AI system and immediately deleted. Only results and analyses are retained." } }, "dataUse": { "title": "2. How We Use Your Data", "intro": "Your data is used to:", "items": [ "Provide CEFR language evaluation services", "Generate personalized learning recommendations", "Enable progress tracking", "Improve our service quality", "Send service updates (with your consent)", "Ensure platform security" ] }, "legalBasis": { "title": "3. Legal Basis for Processing", "intro": "We process your data on the following legal bases:", "items": [ "Consent: For sending audio/text evaluations to our AI system", "Contract Performance: To provide the evaluation services you requested", "Legitimate Interest: To improve our services and ensure security", "Legal Obligation: To comply with applicable laws" ], "law25": { "title": "Quebec's Law 25 (Act respecting the protection of personal information in the private sector)", "content": "CEFRhub Technologies Inc., a federally incorporated Canadian company, is committed to protecting the personal data of all its users in compliance with the strictest applicable data protection laws, including Quebec's Law 25 (fully in effect since September 2024). This includes:", "items": [ "Transparency regarding automated decisions: our AI-powered evaluations are clearly identified as automated processing, and you may request information about how the decision was made", "Privacy by default: only strictly necessary personal data is collected, and privacy settings are set to their most protective level by default", "PIA completed: CEFRhub has conducted a Privacy Impact Assessment (PIA / EFVP) in compliance with Quebec's Law 25 prior to deploying its AI analysis system. This document is available upon request for institutional clients.", "A privacy officer has been designated to oversee compliance" ] }, "ferpa": { "title": "FERPA (Family Educational Rights and Privacy Act)", "content": "When CEFR Hub AI is used by educational institutions in the United States, we comply with FERPA requirements:", "items": [ "We act as a 'school official' with a legitimate educational interest when processing student records on behalf of an institution", "Assessment results and language proficiency data are treated as educational records", "We do not disclose personally identifiable student information without proper consent or authorization", "Parents and eligible students retain the right to access and request amendment of educational records" ] } }, "storage": { "title": "4. Data Storage and Security", "intro": "All data is stored on secure servers located in Canada with enterprise-grade security:", "items": [ "Data encryption in transit (HTTPS/TLS)", "Data encryption at rest", "Access controls and enhanced authentication", "Continuous security monitoring", "Regular backups for disaster recovery" ] }, "thirdParty": { "title": "5. Data Sharing and Sub-processors", "intro": "Your data is never sold to third parties. It is processed only by the following sub-processors, each bound by a Data Processing Agreement (DPA). Data at rest is hosted in Canada (Montréal, region northamerica-northeast1). Some sub-processors (Google Gemini API, Sentry, SendGrid, Stripe) are established in the United States; these transfers are governed by Standard Contractual Clauses (SCCs, Module 2) in accordance with GDPR Art. 46 and Law 25 Art. 17.", "items": [ "Google LLC — Firebase (servers in Canada): Hosting, database, and authentication. Certifications: ISO 27001, SOC 2 Type II. Firebase Privacy Policy.", "Google Cloud - Gemini API: AI linguistic analysis of your submitted content. Data transmitted: linguistic content only (text or audio) — no identifying data (name, email) is transmitted. Retention: 0 days. Your content is never used to train AI models. Google Cloud DPA.", "Stripe Inc.: Secure payment processing. Certifications: PCI DSS Level 1, SOC 2 Type II. Stripe Privacy Policy.", "Sentry (Functional Software Inc.): Error and performance monitoring. Personal data is masked before transmission. Sentry Privacy Policy.", "Twilio SendGrid: Transactional email delivery (account confirmation, notifications). Twilio Privacy Policy." ] }, "rights": { "title": "6. Your Rights (GDPR, PIPEDA, Law 25 & FERPA)", "intro": "Depending on your jurisdiction and applicable legislation, you have the right to:", "items": [ "Access: Request a copy of your personal data (GDPR, PIPEDA, Law 25, FERPA)", "Rectification: Correct inaccurate data (GDPR, PIPEDA, Law 25, FERPA)", "Erasure: Request deletion of your data — \"right to be forgotten\" (GDPR, Law 25)", "Portability: Export your data in a readable format (GDPR, Law 25)", "Objection: Refuse processing for marketing purposes (GDPR, PIPEDA)", "Withdrawal: Withdraw your consent at any time (GDPR, PIPEDA, Law 25)", "Automated Decisions: Request information about and contest decisions made solely through automated processing (GDPR, Law 25)", "De-identification: Request that your personal information be de-identified (Law 25)" ], "contact": "To exercise these rights, contact us at:" }, "retention": { "title": "7. Data Retention", "intro": "We retain your data as long as your account is active.", "afterDeletion": "After account deletion:", "items": [ "Personal data is deleted within 30 days", "Anonymized analytics data may be retained for statistical purposes", "Legal obligations may require retention of certain records" ] }, "cookies": { "title": "8. Cookies and Tracking", "content": "We use essential cookies for authentication and site functionality. Analytics cookies are optional and require your consent. You can manage your preferences through our cookie consent banner." }, "children": { "title": "9. Protection of Minors", "content": "Our services are not intended for persons under 13 years of age. We do not knowingly collect personal data from children under 13. Under GDPR (Article 8), parental consent is required for users under 16 in the European Union. Under PIPEDA, children under 13 generally cannot provide meaningful consent. Under FERPA, when our services are used by educational institutions, parents retain rights over their child's educational records until the student reaches 18 years of age or attends a postsecondary institution. If you are a parent or guardian and believe your child has provided us with personal data, please contact us." }, "changes": { "title": "10. Changes to This Policy", "content": "We may update this privacy policy periodically. Material changes will be notified via email or platform notifications." }, "contact": { "title": "11. Contact Us", "intro": "For any questions about privacy or data protection:", "email": "Email:", "dpo": "Data Protection Officer:" } } }, "terms": { "seo": { "title": "Terms of Service | CEFR Hub AI", "description": "Read the terms and conditions for using CEFR Hub AI, your AI-powered CEFR language assessment platform. Compliant with PIPEDA, Law 25, GDPR and FERPA." }, "title": "Terms of Service", "lastUpdated": "Last updated:", "sections": { "acceptance": { "title": "1. Acceptance of Terms", "content": "By accessing and using CEFR Hub AI (\"the Service\"), you agree to be bound by these Terms of Service. These terms are governed by the laws of Canada and the Province of Quebec, and comply with applicable privacy legislation including PIPEDA, Quebec's Law 25, GDPR, and FERPA where applicable. If you do not agree to these terms, please do not use the Service." }, "description": { "title": "2. Service Description", "intro": "CEFR Hub AI provides AI-powered language evaluation services based on the Common European Framework of Reference for Languages (CEFR):", "items": [ "Written text evaluation", "Oral expression evaluation (audio recordings)", "Personalized learning recommendations", "Progress tracking and comparison tools", "PDF export and analytical reports" ], "disclaimer": "Important Disclaimer: Evaluations are generated by artificial intelligence and have consultative value only. They do not constitute official CEFR level certification. For recognized certification, please consult an accredited organization.", "dataProcessing": { "title": "Data Processing Consent", "content": "By using our evaluation services, you expressly agree that:", "items": [ "Your audio files (oral evaluation) or texts (written evaluation) will be sent to our AI system for analysis", "These files will be automatically deleted from our servers immediately after analysis", "Only the generated analysis and results will be retained in accordance with these Terms" ] }, "automatedDecisions": { "title": "Automated Decision-Making", "content": "In accordance with GDPR (Article 22) and Quebec's Law 25, we inform you that:", "items": [ "CEFR level assessments are generated through automated processing by our AI system", "These assessments are consultative and do not produce binding legal effects", "You have the right to request information about how the automated assessment was made", "When used by educational institutions, assessment results should be reviewed by a qualified educator before making placement or certification decisions" ] } }, "accounts": { "title": "3. User Accounts", "intro": "To use the Service, you must create an account and provide accurate information:", "items": [ "You must be at least 13 years old to create an account", "You are responsible for maintaining account security", "You must not share your login credentials", "You are responsible for all activities under your account", "You must notify us immediately of any unauthorized access" ] }, "subscriptions": { "title": "4. Subscriptions and Payments", "intro": "CEFRhub offers free and paid subscription plans for individuals and organizations.", "plans": [ "Freemium (Free): 1 evaluation / 30 days, basic analysis, no PDF export or history", "Professional ($49/month or $39/month annually): 50 evaluations/month, 10 comparisons, PDF export, full history, priority support", "Power ($89/month or $71/month annually): 200 evaluations/month, 50 comparisons, PDF/Excel export, advanced analytics, 24/7 support", "Expert ($179/month or $143/month annually): Unlimited evaluations*, unlimited comparisons*, all premium features, dedicated account manager" ], "organizationPlans": "Organization Plans:", "organizationPlansList": [ "Team ($169/month or $135/month annually): Up to 10 members, 500 evaluations/month, logo customization", "Business ($499/month or $399/month annually): Up to 50 members, 2,000 evaluations/month, custom departments", "Enterprise (Contact us): Unlimited members, custom volume, SSO, guaranteed SLA" ], "billingTitle": "Billing Terms:", "billingItems": [ "Subscriptions are billed monthly or annually based on your selection (save 20% with annual billing)", "All payments are processed securely via Stripe (PCI DSS Level 1 certified)", "Subscriptions automatically renew at the end of each billing cycle unless cancelled before the renewal date", "You authorize CEFRhub to charge your designated payment method for all applicable fees", "All prices are in USD. Applicable taxes may be added based on your jurisdiction", "We reserve the right to modify pricing with 30 days' advance notice to existing subscribers. Price changes do not affect the current billing cycle" ], "cancellationTitle": "Cancellation:", "cancellationItems": [ "You may cancel your subscription at any time from Profile > Subscription", "Cancellation takes effect at the end of the current billing period — you retain full access until then", "No cancellation fees apply", "Your evaluation data remains accessible for 90 days after cancellation for export purposes", "After 90 days, data is permanently deleted unless you reactivate your account" ], "upgradeDowngradeTitle": "Plan Changes (Upgrades & Downgrades):", "upgradeDowngradeItems": [ "Plan changes take effect immediately upon confirmation", "Upgrades: You are charged a prorated amount for the remainder of the current billing cycle", "Downgrades: Unused credit is applied to your next billing cycle", "Enterprise plan changes require contacting our sales team" ], "refundTitle": "Refund Policy:", "refundItems": [ "7-day money-back guarantee on all paid plans for new subscribers", "Full refund if 5 or fewer evaluations have been used within the 7-day period", "Beyond 5 evaluations within the 7-day period, a partial refund may apply minus API usage costs", "After the 7-day period, no refunds are issued (SaaS industry standard)", "Annual subscriptions: unused months are not refunded after the 7-day period", "To request a refund, contact support@cefrhub.ai within 7 days of purchase" ], "paymentFailureTitle": "Payment Failure:", "paymentFailureItems": [ "If a payment fails, we will notify you by email and retry the charge within 3 business days", "If payment continues to fail after 3 attempts, your account may be downgraded to Freemium", "You will retain read-only access to your data for 30 days to export your evaluations", "No data is deleted without prior email notification" ], "quotaTitle": "Usage Quotas:", "quotaItems": [ "Monthly quotas reset on the anniversary of your subscription start date (not the 1st of the month)", "You receive alerts at 80% and 100% of your quota usage", "Once your quota is reached, you must wait for the next cycle or upgrade your plan — no overage charges apply", "Unused quota does not roll over to the next billing cycle" ], "fairUse": { "title": "Fair Use Policy", "content": "Plans marked as \"Unlimited\" (Expert individual plan and Enterprise organization plan) are subject to our Fair Use Policy. Daily limits apply to ensure consistent service quality: Expert plan — 50 AI analyses (evaluations or comparisons combined) per day; Enterprise plan — 200 AI analyses (evaluations or comparisons combined) per day. These limits cover the needs of the vast majority of professionals. If your usage regularly exceeds these limits, contact us for a custom arrangement. We reserve the right to temporarily restrict access if usage patterns suggest automated or abusive behavior." } }, "acceptableUse": { "title": "5. Acceptable Use Policy", "intro": "You agree NOT to:", "items": [ "Use the Service for any illegal or unauthorized purpose", "Attempt to gain unauthorized access to the Service", "Interfere with or disrupt the Service or servers", "Upload malicious code, viruses, or harmful content", "Scrape, mine, or automate access to the Service", "Share evaluation codes in a way that violates privacy", "Impersonate another person or entity", "Violate any applicable laws or regulations" ] }, "intellectualProperty": { "title": "6. Intellectual Property", "ourContent": { "title": "Our Content:", "intro": "CEFR Hub AI owns all rights to the Service, including:", "items": [ "Software, algorithms, and AI models", "User interface, design, and branding", "All logos, trademarks, and service marks" ] }, "yourContent": { "title": "Your Content:", "content": "You retain ownership of texts and audio you submit. By using the Service, you grant us a limited license to process your content for evaluation purposes. This content is not stored after analysis." } }, "disclaimer": { "title": "7. Disclaimer of Warranties", "intro": "THE SERVICE IS PROVIDED \"AS IS\" WITHOUT WARRANTIES OF ANY KIND:", "items": [ "We do not guarantee 100% accuracy of AI evaluations", "CEFR levels are indicative and do not replace official certifications", "We do not guarantee uninterrupted or error-free service", "We are not responsible for third-party service failures" ] }, "liability": { "title": "8. Limitation of Liability", "intro": "TO THE MAXIMUM EXTENT PERMITTED BY LAW, CEFR HUB AI SHALL NOT BE LIABLE FOR:", "items": [ "Any indirect, incidental, or consequential damages", "Loss of data, profits, or business opportunities", "Damages resulting from use or inability to use the Service", "Any damages exceeding the amount you paid in the last 12 months" ] }, "termination": { "title": "9. Termination", "intro": "We reserve the right to suspend or terminate your account if you:", "items": [ "Violate these Terms of Service", "Engage in fraudulent or illegal activities", "Abuse the Service or other users", "Fail to pay subscription fees" ], "effect": "Upon termination, your access to the Service will cease immediately. You may request data export before termination." }, "changes": { "title": "10. Changes to Terms", "intro": "We may update these Terms of Service periodically. Material changes will be communicated via:", "items": [ "Email notification to registered users", "In-app notifications", "Updated \"Last Modified\" date on this page" ], "continued": "Continued use of the Service after changes constitutes acceptance of the new terms." }, "governing": { "title": "11. Governing Law", "content": "These Terms shall be governed by and construed in accordance with the laws of Canada and the Province of Quebec, without regard to conflict of law provisions." }, "contact": { "title": "12. Contact", "intro": "For questions about these Terms:", "email": "Email:", "support": "Support:" } } } }