Privacy Policy
How TOEFLScorer handles accounts, practice answers, recordings, and payments
Version 1.0 · Effective and last updated: October 17, 2026.
1. Data controller and contact
Enzo, the individual operator of TOEFLScorer at https://toeflscorer.com, is responsible for the personal information we process to provide this Service. For privacy requests, support, or security reports, contact support@toeflscorer.com or our contact page. We have not appointed a dedicated data protection officer; the operator handles privacy requests.
This policy covers our practice service, accounts, payment records, and communications. Waffo Pancake and other providers may also process information under their own policies where they act independently. Our Terms of Service explain purchases and acceptable use.
2. Information we collect
- Account information: name, email address, verification status, authentication records, and password hashes for password-based accounts. Google sign-in supplies the basic profile and email you authorize; we do not receive your Google password.
- Practice information: selected tests, answers, essays, audio recordings you submit, transcripts or pronunciation results returned by the speech engine, scores, feedback, progress, timestamps, and usage allowances.
- Browser and request information: anonymous browser identifiers, session information, IP address, user agent, requested URLs, and diagnostic or security events needed to operate and protect the Service.
- Payment information: billing email, customer and transaction references, plan, amount, currency, payment status, subscription periods, cancellation status, and refund status received from Waffo Pancake. Complete payment-card details are handled by Waffo Pancake and do not pass through or remain on our servers.
- Communications: messages you send through support or contact forms, plus your email and signup source if you join the paid-plan availability waitlist.
We do not require your official test results, government identity documents, precise location, or sensitive personal details in practice answers. Avoid including unnecessary information about yourself or others.
3. Purposes and legal bases
Where applicable data protection law requires a legal basis, we rely on the following:
| Purpose | Legal basis |
|---|---|
| Accounts, practice delivery, evaluation, feedback, and purchased access | Performance of a contract or steps you request before entering one |
| Billing, receipts, refunds, and transaction administration | Performance of a contract; legal obligations for required records |
| Security, abuse prevention, usage limits, diagnostics, and service reliability | Legitimate interests in operating a secure and reliable service |
| Answering support requests and sending necessary service notices | Contract performance or legitimate interests |
| Required tax, accounting, and legal responses | Legal obligations |
| Waitlist availability messages and any optional marketing | Your consent |
Microphone access requires your browser permission and is used when you choose a speaking activity. You can revoke permission in browser settings; speaking recording will then be unavailable. Browser permission does not authorize unrelated uses of recordings.
4. Recordings, answers, and AI evaluation
Recordings are used to evaluate speaking and, where saved, let you replay your responses privately. Speaking audio is transmitted to the Zhiyan speech evaluation engine: some activities stream directly from your browser using a short-lived authorization issued by our server, while others are sent through our server for evaluation. Written responses are sent to Speko Router and the AI model provider selected for evaluation. We send the response and task context needed for feedback, not your payment-card information.
We do not use your answers or recordings to train AI models. Processing by evaluation providers is also subject to their applicable service and data-processing terms; this statement does not promise a provider retention or training arrangement beyond what we have actually agreed with it.
The homepage sentence demo sends audio for immediate evaluation without saving a replay recording on our service. Replay recordings from full tests, section practice, and individual speaking drills are stored privately with a 30-day retention limit. Local copies can remain in your browser until you clear site storage. Deleting a server copy does not clear your device.
Practice history includes answers, scores, and feedback. Share links expose score summaries to anyone who has the link, but never detailed answers or recordings. Do not share a link if you want its summary to remain private.
5. Cookies, local storage, and analytics
We use essential authentication cookies to keep you signed in and browser storage to remember preferences, restore practice progress, store local answers or recordings, and associate anonymous activity with scoring allowances. These functions are not advertising profiles. You can remove cookies and site storage through browser settings; this may sign you out and prevent recovery of anonymous practice.
The current release has no configured Google Analytics, Microsoft Clarity, Plausible, or Umami tracking integration and does not use advertising or retargeting pixels. Infrastructure request logs and internal operational events are used for service delivery and security. Before enabling optional analytics or marketing tracking, we will update this policy to identify the tool, link its policy, and provide any consent choices required by law. There is currently no separate cookie preference center.
6. Sharing and service providers
We do not sell your personal information or share it for cross-context behavioral advertising. We disclose information only as needed for the following purposes:
- Cloudflare: hosting, CDN, database, private recording storage, queues, email delivery, and security infrastructure. See Cloudflare's Privacy Policy.
- Waffo Pancake: merchant of record, hosted checkout, payment processing, tax handling, receipts, refunds, and customer billing portal. Its PCI-DSS-compliant payment infrastructure handles card data exclusively; we retain only the transaction information described above. Its privacy information is available through Waffo and the hosted checkout.
- Zhiyan speech evaluation engine: audio and task information needed for speaking evaluation and pronunciation feedback.
- Speko Router and the selected third-party AI model provider: written answers and task context needed for writing feedback. The routing service is available at Speko Router.
- Google, if you choose Google sign-in: authentication information under Google's Privacy Policy.
- Our support email service: messages and contact details necessary to receive and answer your requests.
We may also disclose information when legally required, to protect legal rights or security, or with your specific consent. If the Service is transferred or acquired, we will require continued protection and notify you of material changes. We do not publish your private answers or recordings as marketing material.
7. Retention and deletion
The following are our retention limits for records we control. Routine cleanup may be manual; we do not represent that every category has an automatic deletion job.
| Data | Retention and disposal |
|---|---|
| Account information, saved answers, scores, and feedback | While the account or history is maintained; delete or anonymize within 30 days of a verified deletion request, except required legal records |
| Anonymous server-side practice and usage records | Up to 12 months from the activity, then delete or anonymize |
| Saved full-test, section-practice, and speaking-drill recordings | Up to 30 days from upload, then delete; earlier verified deletion requests are handled within 30 days |
| Local browser answers and recordings | Until you clear the site's browser storage; controlled by your device |
| Paid transaction and refund records | Up to 7 years where needed for accounting, tax, fraud prevention, or payment disputes; longer only where legally required |
| Unpaid or failed checkout records | Up to 90 days, then delete or anonymize unless needed for an active dispute or security investigation |
| Support and privacy-request correspondence | Up to 24 months after resolution, unless needed for an active legal claim |
| Paid-plan waitlist entries | Until withdrawal or up to 90 days after the availability notice, whichever comes first |
| Application security and diagnostic records we retain | Up to 90 days, unless required for an ongoing incident or legal claim |
Canceling renewal does not delete a free account or its history. You may request deletion separately. Providers acting independently, including the payment merchant of record, may retain their own legally required records. Infrastructure logs held by providers follow their documented retention periods. Where legal retention prevents deletion, we restrict use to the purpose that requires retention.
8. Security and incident response
We use HTTPS, password hashing for password accounts, access checks for private results and recordings, and server-side handling of payment and evaluation credentials. Access to operational data is limited to service administration and support. No system is completely secure; do not share credentials or send card details in support messages.
If a personal-data breach occurs, we will investigate, take remedial action, and notify the relevant authority and affected users as required by applicable law. Where the GDPR's supervisory-authority notification rule applies, that includes notification without undue delay and, where feasible, within 72 hours of becoming aware, unless the applicable exception applies. User notification follows the applicable risk and legal requirements.
9. Your rights
Depending on applicable law, you may request information about processing, access, correction, deletion, restriction, a portable copy, or object to processing based on legitimate interests. You may withdraw consent for consent-based processing at any time without affecting earlier lawful processing. You may complain to your local data protection authority and will not be discriminated against for exercising applicable privacy rights.
Send requests to support@toeflscorer.com. We respond within 30 days or the period required by applicable law, and explain any lawful extension. We may verify identity before disclosing or deleting information. Account deletion is available in account settings; contact us for history-only deletion or help removing related recordings. Cancel active subscriptions separately before deleting an account, or ask us to assist with both.
10. Communications and withdrawal
If you join the paid-plan waitlist, we use your email to notify you about availability. You may withdraw at any time by emailing support@toeflscorer.com with a request to remove your waitlist entry. We do not automatically enroll registered users in a marketing newsletter. Withdrawing from optional messages does not stop necessary account verification, password reset, security, billing, or policy notices.
11. International processing
Cloudflare's global infrastructure and payment, email, and evaluation providers may process information outside your country. The location can depend on the provider and request routing. We use applicable contractual protections and lawful transfer mechanisms where required, including standard contractual clauses where applicable. We do not promise storage exclusively in one country or claim a certification we have not obtained. Contact us for information about safeguards applicable to your data.
12. Children
The Service is not directed to children under 13, or below a higher minimum age required by local law. Users below legal adulthood need a parent or guardian's permission; purchases must be made by an adult aged at least 18. We do not knowingly collect personal information from children below the applicable minimum age. If you believe a child has provided such information, contact us so we can investigate and delete it.
13. Policy changes
We publish the version, effective date, and last-updated date on this page. We give at least 15 days' notice of material changes through the site or your account email, except where law or urgent security needs require earlier action. When a new use requires consent, we will seek it before that use. English and Chinese versions describe the same practices.
14. Contact
Data controller: Enzo (individual operator of TOEFLScorer).
Privacy, support, and security: support@toeflscorer.com. You may also use our contact page. For a request about practice records, include your account email or available attempt reference; never send passwords or complete card details.