1. Who is responsible for your data
Excelia Sdn Bhd (registration 202401038326), a company registered in Malaysia, is the data controller for IELTS-X. Malaysia's Personal Data Protection Act 2010 (PDPA) applies to how we handle your personal data.
Contact: [email protected].
2. What we hold
Your account
- Your email address is stored as a one-way hash, not as an address. When you sign in we hash what you type and compare the hashes. That is enough to recognise you and not enough to read your address back out of your account.
- Three honest exceptions, because "we never hold your address" would be too
strong:
- while a sign-in code is live, the row holding that code carries the address we sent it to. The code expires after ten minutes, and the address is erased from the row as soon as the code is used or expires.
- your own browser keeps the address in a cookie while you are signed in, so the app can show it to you. Signing out clears it.
- if you redeem a voucher code, the record of that code keeps your address,
so that we can settle with the partner who sold it and help you with it.
IELTS-X staff can see the address. The partner sees only a masked form,
such as
z***@qq.com.
- We also keep the part of your address before the
@as a display name. - A note of the hashing: it is a plain SHA-256. It cannot be reversed, but somebody who both obtained our database and already had a list of candidate addresses could test them against it. It protects your address from being read; it is not a secret-keeping measure.
- When you created the account, and which version of these documents you accepted, and when.
Your devices
- For each device you sign in from we store a coarse label ("Chrome · macOS") and an irreversible fingerprint. The fingerprint is a keyed hash of three things: your browser family, your operating system family, and the network block your connection came from — not your full address, which is truncated before it is hashed.
- We do not store your IP address, and we do not store your location.
- This is not biometric data and it is not a device identifier we can look up anywhere else. It exists only to notice one account being used from many different places, which is what enforces the one-account-one-person rule.
Your work
- Your answers to practice questions, your scores and your attempt history.
- Essays you submit for grading, and the band estimates and feedback produced for them.
- Your conversations with the AI tutor, including the transcript of a spoken Live session.
- Your notes and your saved vocabulary, including the sentence you first met a word in, and your review history for it.
- AI memory: short notes the tutor keeps about what you are working on — your weak areas, your target band — so it does not start from nothing each time. These are stored as vectors in our own database, keyed to your account. This applies to the spoken Live tutor only, and only when the memory feature is switched on; text chat does not write to it.
Your account activity
- Credits granted and spent, and what each was spent on.
- Records of payments: what you paid, when, what it bought, and the identifiers our payment provider uses for you and for the payment. We never see or store your card number.
3. What we do not do
- No face recognition. Signing in to a consumer account is an email and a code; there is no camera step at any point. (Face verification exists in our separate product for training centres, where a centre switches it on for its own enrolled students. It is not used here.)
- No advertising, and no selling or renting your data to anyone.
- No profiling to make decisions about you beyond showing you your own study progress.
4. Why we hold it, and on what basis
| Why | What it covers |
|---|---|
| To provide the service you asked for | your account, your work, your credits |
| To take payment and keep accounts | payment, credit and voucher code records |
| Our legitimate interest in preventing account sharing and abuse | devices, rate limits |
| Your consent | the AI memory, and these documents themselves |
| To meet a legal obligation | tax and accounting records |
You can withdraw consent to the AI memory by deleting your account; we will offer a narrower control if you ask for one.
5. Who else processes your data
We use other companies to run the service. Each one receives only what its job needs.
| Who | What they do for you |
|---|---|
| Hetzner (Singapore) | runs the servers the application and database sit on |
| Tencent Cloud COS (Singapore) | stores files — your notes, generated images, practice audio — and holds the nightly database backup |
| Cloudflare | carries traffic between your browser and our servers and protects against attack. As it terminates the secure connection, it necessarily sees your IP address |
| DeepSeek | the text AI tutor |
| OpenAI | the spoken Live tutor, its speech-to-text, and vocabulary pronunciation |
| OpenRouter | routes our other AI requests — translation, sentence-structure help, writing grading, image generation and dictionary entries — on to the model that serves them, which may be run by OpenAI or Google |
| Resend | sends your sign-in code by email |
| Sentry | receives error reports from our servers, on a sample of traffic, when something breaks |
| Stripe | takes your payment and keeps your card on file for the subscription. You enter your card on a page Stripe hosts, so your card number never reaches us — we hold only Stripe's identifiers for you and for each payment |
The partner who sold you a voucher code does not process your data for us,
but it can see that the code was redeemed, when, and a masked form of your
address, such as z***@qq.com. It is not told anything else about you.
Your card details are handled by Stripe and never by us. We cannot see, store or recover your card number, and nothing in this service can charge your card except the subscription you started.
What goes to the AI tutor is more than your message. So that it can help with the question in front of you, the tutor can also read your recent answers and scores, the weak areas those imply, and your saved notes. All of that is sent to the AI provider as part of answering you.
Do not put anything in a tutor conversation, a note or an essay that you would not want processed by a third party.
6. Where your data is
Our servers and file storage are in Singapore. The AI providers, the email provider, the error-reporting provider and the payment provider process data outside Malaysia, including in the United States and, for DeepSeek, in China. By using the service you agree to your data being transferred and processed in those places so that we can provide it to you.
7. How long we keep it
We keep your account and your work for as long as your account exists.
Nothing expires on its own. Your essays, answers, notes, vocabulary and tutor conversations are kept until you delete them or delete your account. We do not currently run an automatic deletion schedule for inactive accounts; if we introduce one we will tell you first.
Sign-in codes expire after ten minutes, and the address on them is erased at that point. Error reports are kept by Sentry under its own retention period.
Voucher code records are kept as financial records after your account is deleted, with your address masked.
Backups. We take a nightly backup of the whole database and keep it for 30 days. A backup is a snapshot, so for up to 30 days after you delete your account your data still exists inside backups taken before the deletion. Those backups are not used to serve the product and expire on their own.
8. Your rights
Under the PDPA you can ask to see your data, correct it, limit how we use it, and withdraw consent. Two of those you can do yourself, immediately, from Settings → Account:
- Export my data — downloads a file containing everything stored against your account, generated at the moment you ask.
- Delete my account — deletes it, at once and permanently.
To correct something, or for anything else, write to [email protected]. If you are not satisfied with our answer you can complain to the Personal Data Protection Commissioner of Malaysia.
9. What deletion deletes, and what it keeps
Deleting your account removes: your account, your practice answers and scores, your mock attempts, your essays and their grades, your notes — including the note files themselves and any images generated for them — your vocabulary, your tutor conversations, your device list, your unused sign-in codes, and the AI tutor's memory of you.
Your subscription is cancelled at the same time, so no further payment is taken. It takes effect immediately. The one lag is backups, described in section 7.
It keeps a small number of records, and only these:
- Payment and credit records — what you paid, what it bought, which plan you were on, and what the credits were spent on. These are financial records: we are required to keep them for accounting and tax, and they are the only answer we have if a payment is disputed after the account is gone.
- Voucher code records — the code, its dates, what it granted, your former
account identifier and a masked form of your address, such as
z***@qq.com. We need these to settle with the partner who sold the code. Your full address is removed from them when you delete your account. - Your consent record — which version of these documents you accepted and when. This is the evidence that we were permitted to hold your data in the first place, so deleting it would defeat its purpose.
- Usage cost records, with your account identifier removed — we keep what the AI usage cost us; the link to you is erased.
- A deletion record — your former account identifier, a hash of your address, and the date. This is what lets us confirm your account was deleted without keeping the account.
Your account page shows this same list, read from the server, so what you are told matches what the software does.
10. Security
Traffic is encrypted in transit. Your account holds your email as a hash rather than as an address, and device fingerprints are one-way. Access to production systems is limited to the people who operate them.
No service can promise it will never be breached. If a breach affects your data, we will tell you.
11. Changes
If we change this notice in a way that matters, we will ask you to accept the new version the next time you sign in, and record which version you accepted.