Legal Document

Privacy Policy

Last updated: 16 June 2025Effective: 16 June 2025Bradnova Technologies Ltd

Bradnova Technologies Ltd ('we', 'our', or 'us') operates the NovaEnglish platform. This Privacy Policy explains what personal data we collect when you use NovaEnglish, why we collect it, how we use it, and your rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws including Brazil's LGPD.

Data Controller

The data controller responsible for your personal information is:

Bradnova Technologies Ltd

Email: privacy@novaenglish.app

Platform: novaenglish.app

If you have any questions about this Policy or wish to exercise your rights, please contact us at the email above.

Data We Collect

We collect the following categories of personal data:

Account Information: Your email address, full name (optional), native language, and learning goal — provided during sign-up or onboarding.

Assessment Data: CEFR level results, section scores (grammar, vocabulary, reading, writing), question responses, and writing submissions.

Technical Data: IP address (hashed for consent records), browser type, device type, and session timestamps.

Consent Records: Records of your cookie and data processing consent choices, including the date and version of the policy you agreed to.

AI-Generated Content: Personalised feedback generated by our AI evaluation engine based on your assessment responses.

We do not collect or process any special categories of data (e.g. health, biometric, or political data).

Legal Basis for Processing

We process your personal data under the following GDPR legal bases:

Contract (Art. 6(1)(b))To provide the NovaEnglish assessment service and your account.

Consent (Art. 6(1)(a))For optional analytics and personalisation cookies. You may withdraw consent at any time.

Legitimate Interest (Art. 6(1)(f))To improve our platform, prevent fraud, and ensure technical security.

Legal Obligation (Art. 6(1)(c))To maintain consent audit trails as required by GDPR Art. 7.

How We Use Your Data

→Deliver your CEFR assessment results and personalised AI feedback
→Show your progress history across multiple assessments
→Generate and download PDF reports of your results
→Send transactional emails (account verification, password reset)
→Improve the accuracy and quality of our adaptive assessment engine
→Maintain security, prevent fraud, and comply with legal obligations

Data Retention

Profile & account dataWhile account is active + 30 days after deletion

Assessment sessions & scores2 years, then anonymised

Question responses2 years, then deleted

Writing responses1 year, then deleted

Consent recordsPermanently retained for legal audit trail

Technical logs90 days

Your Rights

Under GDPR (and LGPD for Brazilian residents), you have the following rights:

Access (Art. 15)Request a copy of all personal data we hold about you.

Rectification (Art. 16)Correct inaccurate or incomplete data.

Erasure (Art. 17)Request deletion of your data ('right to be forgotten').

Portability (Art. 20)Export your data in a structured, machine-readable format (JSON).

Restriction (Art. 18)Request we stop processing your data while a complaint is resolved.

Object (Art. 21)Object to processing based on legitimate interests.

Withdraw ConsentWithdraw any consent at any time via your Privacy Center.

To exercise any of these rights, visit your Privacy Center (requires sign-in) or email privacy@novaenglish.app. We will respond within 30 days.

Cookies

We use cookies and similar technologies to operate our platform. For full details, please read our Cookie Policy. You can manage your cookie preferences at any time via the cookie banner or your Privacy Center.

Security

We implement technical and organisational measures to protect your data, including TLS encryption in transit, AES-256 encryption at rest (via Supabase), Row Level Security policies, hashed IP addresses, and access controls limiting data access to authorised personnel only. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security but we continuously review and improve our practices.

Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify registered users by email and update the “Last updated” date at the top. Continued use of NovaEnglish after changes become effective constitutes acceptance of the updated Policy.