CLB Mock Privacy Policy

Effective 2026-11-01 · Version 2026-11-01.3

1. Scope and accountability

This Privacy Policy explains how the individual operator, operating under the Certloom Learning brand ("we," "us," or the "Operator"), handles personal information in connection with the CELPIP Practice Test: AI Score app ("CLB Mock") and its website https://clbmock.web.app. Together, the app and website are referred to as CLB Mock or the "Services". The app's bundle/package identifier is com.clbmock.celpip; AI feedback is provided through our server (the "gateway").

Certloom Learning is a brand used by the Operator and is not represented as a corporation or separate legal entity.

This Privacy Policy does not govern the independent privacy practices of your app marketplace (for example, Apple's App Store), your device operating system, your device's backup service, or third-party websites or services to which we link.

The Operator is accountable for the privacy practices described in this Privacy Policy and is the person in charge of the protection of personal information. Privacy questions and requests may be sent to certloomlearning@gmail.com.

CLB Mock is an unofficial practice service for the English CELPIP-General and CELPIP-General LS tests. It is not affiliated with, endorsed by, or sponsored by Paragon Testing Enterprises, Prometric, or Immigration, Refugees and Citizenship Canada (IRCC). CELPIP is a trademark of its owner. AI scores are estimates for practice, not official CELPIP results.

2. Plain-language summary

• Your practice stays on your phone. The app does not require you to create an account. Practice data, scores, your plan (goal, target CLB and test date), settings and consent records are stored in the app's local storage on your device.
• Your voice is never recorded. Speaking practice turns speech into text on your phone. Audio is never saved or sent, and we never create a voiceprint.
• AI feedback is optional. Only when you ask for an AI score, the text you wrote (or the transcript of what you said) and the task identifier, plus on-device timing metrics for speaking, are sent through our server to Google (Gemini) on Google Cloud's Vertex AI for feedback. We do not keep it. Google does not use it to train its models. Google may keep a request for up to 90 days only if its automated abuse-detection systems flag it.
• No ad tracking in the app. No ads or ad tracking, pixels or session recording in the app. The app sends usage statistics and crash reports (Google Firebase), never with an advertising ID; depending on your app version they start after you allow them or when you accept this Policy, and you can turn them off at any time in Settings (§9A). On our website, Google Analytics counts page views only if you accept it in the cookie banner; there are no ads. We do not sell or rent personal information, and we do not share it for advertising.
• Purchases go through your app marketplace. We check your subscription each time you ask for AI feedback and do not store the proof. We do not receive your full payment-card number from your app marketplace.
• Phone backups: if your phone's iCloud or Google backup is on, it may include the app's local data. You control those backups.
• How the app asks. Depending on your app version, the app either asks you separately before AI feedback, voice practice and usage statistics are first used, or includes them in your acceptance of the Terms of Use and this Privacy Policy on its first screen (§12).
• You are in control. Turn usage statistics off, export your data or delete everything in Settings › Privacy Center. Questions: certloomlearning@gmail.com.

3. Information stored locally in the app

The app stores the following information in local storage on your device, protected by your operating system:

Where this information is stored only locally and is not transmitted to the Operator, we cannot view, retrieve, restore, or provide a server-side copy of it. You can export all of it (Privacy Center › Export my data, a JSON file you share where you choose) or erase it (Delete everything). Delete everything erases all of it except two technical codes kept for abuse prevention: the random free-try code and, on iPhone, the App Attest key identifier (§4). Uninstalling the app removes local application data; the iPhone keychain exception for the free-try code is described in the table above.

Device backups. We allow your operating system's backup service to include the app's local data, so that your progress can move to a new phone (there is no account). If iCloud Backup (iPhone) or Google backup (Android) is turned on, the backup may include: your progress, drafts and settings, and your consent records. These backups are stored in your own Apple or Google account, are governed by Apple's or Google's terms, and are controlled by you. We cannot access them. You can turn backups off in your phone's settings. Deleting data in the app does not delete copies already in an existing backup until your backup service replaces them.

Uninstalling the app, clearing application data, resetting or replacing the device, or loss or corruption of local storage may result in loss of locally stored information that is not in a backup.

4. Information we never collect

• Audio recordings. Speech recognition runs on your device in on-device mode. The audio is processed in memory and discarded. It is never written to storage or sent to us or anyone else.
• We collect no biometric identifiers or information, including voiceprints.
• Your name, email address or phone number through the app.
• Location, contacts, photos, advertising identifiers, device identifiers for tracking, or browsing history through the app. Usage statistics and crash reports are described in §9A; you can turn them off. On the website, page statistics are collected only if you accept Google Analytics (section 9).

5. AI feedback (only when you ask for it)

When: only when you ask for an AI score: when you submit a Writing answer for scoring, or when the recording of a Speaking task you started ends (including the first Speaking task offered during setup). Depending on your app version, the app either first asks for your consent in a pop-up for that feature (with a checkbox and Agree & send), or AI feedback is included in your acceptance of the Terms of Use and this Privacy Policy on the app's first screen (§12). AI feedback is offered only to adults (§19). Providing this information is voluntary. If you do not use AI feedback, nothing is sent and the rest of the app keeps working.

What is sent:

• Writing feedback: the text of your answer, the task identifier and task prompt, and your target CLB if you set one.
• Speaking feedback: the transcript made on your phone, the task identifier and task prompt, your target CLB if you set one, and on-device timing metrics: speaking time in seconds, words per minute, number of pauses and longest pause. Never audio.
• With each request: the time it was sent, a confirmation that you accepted the applicable notice and its version, proof that the request comes from the genuine app (Apple App Attest or Google's app-integrity service on Android), and proof of your subscription from your app marketplace (§7) or, for a free AI score, a random code made on your phone (§7). These proofs are checked by our gateway, then discarded. They are not sent to the AI model. On iPhone, the App Attest proof includes the identifier of a cryptographic key that your phone creates for this app alone; it is not a device or advertising identifier, the app replaces it at least every 30 days, and Delete everything keeps it (abuse prevention, so that deleting cannot renew the free AI scores). On Android, Google's app-integrity service produces the proof and our gateway decodes it with Google.

Who receives it: our gateway, which runs on Google Cloud Run in Montréal, Canada, sends the text, task identifier and, for speaking, the on-device timing metrics to Google's Gemini models on Vertex AI (Google Cloud), using the gateway's own Google Cloud identity. We use Google's global endpoint, so Google may process the request in any Google Cloud location, including the United States. Google acts as our service provider (data processor) under its Cloud Data Processing Addendum.

Why: only to produce feedback on your answer and return it to you.

What is kept:

• By us: nothing. The gateway processes the request in memory and keeps no copy. It never logs the content.
• By Google: Google's terms state that Google will not use customer data to train or fine-tune any AI/ML models without the customer's permission. We turn off Vertex AI's default in-memory data cache (which otherwise keeps inputs and outputs for up to 24 hours to reduce latency). If Google's automated safety classifiers detect suspected misuse, Google may log the prompt, solely to check for violations of its acceptable-use policies, and store it for up to 90 days. We use only Gemini models that are not subject to Google's broader logging for "Advanced AI" models.

Automated feedback: the feedback and the estimated CLB range are produced automatically by an AI model. They are practice estimates, not official scores, and they are not used to make any decision about you. You can ask us how the feedback works at certloomlearning@gmail.com.

Stopping: nothing is sent unless you ask for an AI score, so you can stop at any time by not using AI feedback (in app versions that show a pop-up, you can also turn the feature off in Settings › Privacy Center). Text already sent cannot be recalled, but we keep none of it, and Google keeps it only in the flagged-misuse case above.

6. Voice practice

Your operating system asks for microphone and speech-recognition permissions. Speech recognition runs on your device; audio is never saved or sent. If on-device recognition is unavailable, you can type your answers. We collect no biometric identifiers, including voiceprints. Depending on your app version, the app first asks you to accept a voice-practice release (with your typed name), or voice practice is included in your acceptance of the Terms of Use and this Privacy Policy. The transcript stays on your phone unless it is sent for an AI score (§5).

7. Purchases through app marketplaces

CLB Mock subscriptions are processed by the app store you used (for example, Apple's App Store). The applicable marketplace processes payment and related store-account information under its own terms and privacy practices. We do not receive your full payment-card number from your app marketplace.

When you ask for AI feedback, the app sends the store's proof of your subscription (the marketplace's signed transaction or purchase token). Our gateway checks it, using the applicable marketplace's signature verification or verification service, and then discards it. The gateway uses the proof only to confirm that a subscription of this app is active, whether it is a free trial if one is ever offered, and the subscription's stable identifier for the counter below.

To enforce weekly fair-use limits, the gateway keeps a count of AI requests per subscription per week. It is stored under a scrambled code (a keyed hash of the subscription identifier, the week number and the feature used), never the identifier itself, in Google Cloud Firestore in Montréal. It deletes itself after 8 days, and Google usually removes expired records within a day after that. Without the store's identifier we cannot link it to anyone, and we cannot look it up for a particular person. A per-minute limit works the same way, with a scrambled code held only in the server's memory for about a minute and never written anywhere.

Free AI scores. Without a subscription, the app offers adults 2 AI scores per installation in total across writing and speaking. Instead of a subscription proof, the app sends a random code it created on your phone. The code is not derived from you, your device or your store account. The gateway still checks that the request comes from the genuine app (Apple App Attest or Google's app-integrity service on Android). So that each installation gets no more than 2 free AI scores in total, the gateway keeps a count of free tries in Google Cloud Firestore in Montréal, stored under scrambled codes (keyed hashes of the random code and, on iPhone, of the app's App Attest key identifier), never the codes themselves, and nothing about what you wrote or said. This count does not delete itself: it is kept while the free try is offered and deleted within 30 days after the free-try offer ends. We cannot link it to you. We also keep a monthly total of what free tries cost us, which is not personal information, for about 40 days.

Your app marketplace may independently collect and process information relating to your purchase, device, store account, fraud prevention, taxation and use of their services. Its processing is governed by its privacy policy.

8. Our server, technical data and logs

• Our code never logs the content of requests, your IP address or your device's user agent. It records only technical events: the route, the result code, which check failed, the response time and the amount of AI processing used.
• Our hosting provider's network necessarily sees your IP address to deliver the response. Google Cloud's own request logs for our server can record the IP address and user agent of each request. We configure our project to exclude those request logs and to keep technical logs for 1 day; in any case Google deletes such logs automatically after at most 30 days.
• The Operator administers the Google Cloud project and can see these technical logs, which contain no content or identifiers.

9. Website technical data, cookies and tracking technologies

The website's practice widgets (timers, word counter, quizzes and score calculator) run entirely in your browser and store and send nothing.

Our website consists of static pages hosted on Google Firebase Hosting. It uses no advertising, tracking pixels, session recording, chat widgets, or third-party embeds or fonts, and the only third-party script it can load is Google Analytics 4, and only after you choose "OK" in the cookie banner. Until then, and if you decline or your browser sends Global Privacy Control, nothing from Google Analytics is loaded and no cookie is set.

It stores one strictly necessary record in your browser's localStorage: your cookie-banner choice (banner version, decision, date and time), which you can change with Cookie settings in the footer. This record contains no identifier and never leaves your browser.

Website analytics (only with your consent). If you accept, Google Analytics 4 (Google LLC, as our service provider) receives, for each page you view, the page address and title, the referring page, your browser and device type, screen size and language, an approximate location derived from your IP address, and the random identifiers stored in its _ga and _ga_<ID> cookies. Google states that Google Analytics 4 does not log or store IP addresses. We send no user ID, name, e-mail address or anything you type or choose on the site, we collect page views only, and Google signals, advertising features and ad personalisation are off. We use the aggregated reports to see which pages help people. The cookies expire about 2 months after your last visit and Google Analytics keeps the statistics for 2 months. Withdraw at any time with Cookie settings: Google Analytics stops and its cookies are deleted. App usage statistics are described in §9A.

We do not intercept, record or share your communications with third parties. Like any website host, Google processes your IP address and browser information to deliver pages, detect abuse and protect the service; Google states that Hosting retains IP data for a few months (https://firebase.google.com/support/privacy). We have not enabled Hosting's optional web request logs, so we do not receive that data. Details are in our Cookie & Tracking Technologies Policy (https://clbmock.web.app/cookies/).

Current non-essential provider: Google Analytics 4 (Google LLC), only after you accept.

Global Privacy Control is treated as declining optional cookies: Google Analytics never loads for a browser that sends it.

9A. App usage statistics and crash reports (you can turn them off)

When: depending on your app version:

• Versions that ask separately: only after you tap Allow in the app's "Help improve CLB Mock?" notice, which adults see once (and again if this notice changes materially). If you tap Not now, nothing is sent.
• Versions with one acceptance: after you accept the Terms of Use and this Privacy Policy on the app's first screen, usage statistics and crash reports are on, unless you turn them off. There is no separate notice.

Before you accept, nothing is collected or sent. In every version you can turn Usage statistics and crash reports off at any time in Settings (also in Settings › Privacy Center), and the app works exactly the same. Users the app knows to be under 18 (§19) never send statistics or crash reports.

What is collected: app interactions (events), such as the screens you view; the features you use; starting and finishing a practice set, mock exam or level check, with a score range and a question-count range (never your answers or anything you write or say); reaching a free limit and tapping a Premium-only item; views of the Premium screen, the plan you select, and whether a subscription purchase was started, cancelled, failed or completed (product and period only, never a purchase token or payment details); restoring purchases; choosing your goal and target CLB; and ranges such as how many questions you have answered or how many days you have used the app. Google Analytics for Firebase also records a few automatic events (for example first open, session start and engagement time) and collects a random app instance ID created by Firebase, your device model, operating-system version, app version, and an approximate location (country, region or city) derived from your IP address. We also set these properties: your goal and target CLB, whether you have Premium, your app marketplace and the week you started using the app.

What is not collected: your name, email address, account, answers, text you write or say, purchase tokens, precise location, or advertising identifiers (Apple IDFA or the Android advertising ID). The app does not collect the iOS identifier for vendors (IDFV) or the Android ID for analytics. Advertising storage, ad user data, ad personalization and Google signals are off. We do not link the statistics to your identity.

Why: only to understand which features help learners and what leads people from the free plan to a subscription, so we can improve the app. Not for advertising or profiling, and the statistics are never sold or shared for cross-context behavioural advertising.

Crash reports: under the same setting, Firebase Crashlytics (Google) receives a report when the app crashes: the technical stack trace of the error, your device model, operating-system version, app version, the time of the crash, a random Crashlytics installation ID, and labels for your goal, target CLB and app version. Reports never include your name, account, answers, text you write or say, or audio, and we never set a user ID. Crashes that happen before statistics are on, or after you turn them off, are deleted from your phone without being sent. Development builds never send reports. We use crash reports only to keep the app stable (find and fix crashes); Google is our service provider (data processor), and keeps crash reports for 90 days.

Who receives it: Google LLC (Google Analytics for Firebase and Firebase Crashlytics), as our service provider (data processor) under Google's data processing terms. Google may process the statistics in the United States or in other countries where Google operates (§14).

Offline use: the app works the same without a connection. Statistics and crash reports wait on your phone and are sent when you are back online; nothing waits for them.

Retention: Google Analytics keeps event-level statistics for 2 months, and Crashlytics keeps crash reports for 90 days, then they are deleted. We see only aggregated reports.

Turning them off: switch Usage statistics and crash reports off at any time in Settings or Settings › Privacy Center. Collection stops immediately, and the app deletes from your phone the app instance ID and any statistics or crash reports not yet sent. Delete everything does the same. Switching it back on resumes collection at once. Data already sent is deleted by Google at the end of the retention periods above. Questions: certloomlearning@gmail.com.

10. Voluntary communications

If you contact us voluntarily at certloomlearning@gmail.com, we receive the information you choose to provide, such as your email address, message and attachments. Our mailbox is provided by Google (Gmail). We use that information to respond to you, provide support, diagnose problems, handle privacy requests, maintain appropriate records and comply with applicable law. We keep this correspondence only as long as needed to handle your request, and at most 12 months after it is closed, then delete it. We may keep a short record of privacy requests (date, type of request and our response, without the message content) for as long as the law requires us to be able to show how we handled them.

Do not send unnecessary sensitive personal information in a support request.

11. Purposes for which we process information

We process personal information only to:

• provide AI feedback when you ask for it;
• verify your subscription and enforce fair-use limits;
• protect the Services against fraud, abuse and security incidents (app-integrity checks, rate limits, the spend limit);
• produce usage statistics and crash reports to improve the app and keep it stable, unless you turn them off (§9A);
• respond to support and privacy requests; and
• comply with applicable law and establish, exercise or defend legal rights.

We do not use personal information for advertising, profiling, personalization across services, or model training, and we do not sell it. With your consent, the website uses Google Analytics statistics only to understand which pages are used (section 9), and the app sends usage statistics only to understand which features are used (§9A).

12. Consent and privacy choices

How the app asks depends on your app version:

• Versions that ask separately: accepting the Terms of Use does not give consent to send any data. Each optional feature asks for your consent just before it is first used, with an unticked checkbox: AI writing feedback, AI speaking feedback, and voice practice (with a typed-name release). Usage statistics are asked once, with Allow and Not now (§9A). If a notice changes materially, these versions ask again.
• Versions with one acceptance: the app asks once. On the first screen, Accept & continue accepts the Terms of Use and this Privacy Policy. That acceptance is your consent to the processing described in this Policy: AI feedback, which sends an answer only when you ask for an AI score (§5); voice practice with on-device speech recognition, after your phone's own microphone and speech-recognition permission prompts (§6); and usage statistics and crash reports, which are on unless you turn them off (§9A). There are no further pop-ups, checkboxes or signatures, and a later change to this Policy does not ask you again in the app (§21). You cannot use the app without accepting the Terms of Use and this Privacy Policy.

In every version you can withdraw at any time: turn usage statistics and crash reports off in Settings; do not ask for AI scores (nothing is sent otherwise); turn off the microphone or speech-recognition permission in your phone's settings; or use Delete everything. Withdrawal applies to future processing.

13. Service providers and other recipients

We do not sell or rent personal information, and we do not share it for cross-context behavioural advertising.

We may also disclose information to professional advisers where reasonably necessary; to governmental, regulatory, law-enforcement or judicial authorities where disclosure is legally required or permitted; and to a purchaser, successor or other relevant party in connection with a lawful sale, restructuring or transfer of the business, subject to this Policy. The current list of service providers is at https://clbmock.web.app/subprocessors/.

14. International processing and transfers

Our gateway and counters run in Montréal, Canada. AI feedback requests are processed by Google through its global endpoint, which may use any Google Cloud location, including the United States. Emails you send us are handled through Gmail. App usage statistics and crash reports (unless you turn them off), and website statistics if you accept Google Analytics, are processed by Google, including in the United States. As a result, personal information may be processed in Canada, the United States, and other countries in which we or our providers operate, outside the province, territory or country in which you live. It may be subject to the laws and lawful-access regimes of those jurisdictions, including access by courts, law-enforcement and national-security authorities.

Where applicable law requires an assessment, contractual protection, consent or another measure for an international transfer, we apply the legally required measure.

CLB Mock is available worldwide except in the European Union, the European Economic Area, Switzerland and the United Kingdom. If you use AI feedback, your text leaves your country; usage statistics and crash reports do too unless you turn them off. Your consent (in the feature pop-ups in app versions that show them, or by accepting this Privacy Policy) covers that transfer. International transfers may carry risks because destination countries may not offer the same level of protection as your own country's law. You can avoid AI-content and app-statistics transfers by not using AI feedback and by turning usage statistics off.

Alberta residents: for questions about our policies on service providers outside Canada, contact the Operator at certloomlearning@gmail.com.

15. Retention

16. Security

We use reasonable administrative, technical and organizational measures appropriate to the nature of the information we handle and the Services we provide. These include encryption in transit (TLS), app-integrity checks, strict input limits, no database of users, no AI API key (the gateway uses its Google Cloud identity), the HMAC key held in Google Secret Manager, and a written incident-response plan.

No system, network, device, transmission method or storage technology can be guaranteed to be completely secure, so we cannot guarantee absolute security. Protect your phone with a passcode: the data in §3 is only as safe as your device and your backup account.

If we become aware of a security incident involving personal information that requires notification, reporting, recordkeeping or other action under applicable law, we will take the action required by that law.

17. Access, correction, withdrawal of consent and complaints

Subject to applicable law, you may have rights relating to personal information that we actually hold about you. These include rights to request access, correction or deletion; to withdraw consent; to receive your information in a structured, commonly used technological format; and to raise a privacy complaint. Because the information stored only on your device is not held by the Operator, we cannot provide a server-side copy of information that we do not possess. The Privacy Center lets you view, export and delete it yourself.

To make a privacy request or complaint, email certloomlearning@gmail.com. We answer within 30 days. We may request information reasonably necessary to verify your identity and the request, and never more than we need. Legal exceptions may apply.

• Canada: you have rights under PIPEDA and, in Quebec, under the Act respecting the protection of personal information in the private sector. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca), the Commission d'accès à l'information du Québec (www.cai.gouv.qc.ca) or another applicable provincial privacy regulator.
• United States: depending on your state, you may have the right to know or access, delete and correct personal information; to obtain a portable copy; to opt out of sale, sharing, targeted advertising and profiling (we do none of these); and not to be discriminated against for exercising your rights. We extend these rights to all users, whether or not a given state law applies to us. You may use an authorized agent. If we decline a request, you can appeal by replying to our decision with "Appeal" in the subject line; we will answer within the time your state's law requires and tell you how to contact your state attorney general.
• Other countries: you can exercise the rights your local law gives you (for example under India's DPDP Act, Brazil's LGPD, Nigeria's NDPA or Morocco's Law 09-08) by writing to certloomlearning@gmail.com.

California notice at collection. We collect, only from you and only when you ask for AI feedback, user content (essays and speaking transcripts sent for AI feedback) and commercial information (proof of an active subscription, checked and not kept). We also keep a pseudonymous weekly usage count for 8 days, a pseudonymous free-try count while the free try is offered (§7) and, unless you turn usage statistics off, collect internet or other electronic network activity information (app interactions, an app instance ID, device and app details) and approximate location derived from your IP address, which we disclose to our service provider Google for analytics (§9A). We use them to provide AI feedback and enforce fair-use limits, and we disclose user content to our service provider Google for that purpose. We do not sell or share personal information, and we do not use or disclose sensitive personal information for purposes that require a right to limit. Retention periods are in §15.

Consumer health data. We do not ask for, and do not intend to collect, consumer health data as defined by Washington's My Health My Data Act, Connecticut's Data Privacy Act or similar laws, and we do not record voice. Please do not include health information in your answers. If you do, it is handled like any other text you send for feedback (§5) and we do not keep it.

18. EEA, UK and Switzerland

CLB Mock is not offered in the European Union, the European Economic Area, Switzerland or the United Kingdom. Nothing in this Policy limits privacy rights that apply under mandatory law. For privacy questions or requests, contact certloomlearning@gmail.com. Website analytics is optional and operates only with consent as described in §9.

19. Children and minors

CLB Mock is intended for adults preparing for the English CELPIP-General and CELPIP-General LS tests. Depending on your app version, a neutral age screen during setup asks for your birth year, or the app treats you as an adult when you accept the Terms of Use and this Privacy Policy; in versions with one acceptance you can enter your birth year at any time in Settings › Privacy Center (Age). Only the result (18 or older, or not) is stored, never the year. For a user the app knows to be under 18, AI feedback and voice practice are hidden and no usage statistics or crash reports are sent, so no information leaves their device. If you are under 18, please enter your birth year in the Privacy Center. If applicable law requires parental or guardian authorization for a particular user's use of the Services, the user should use the Services only with the required authorization. We do not knowingly collect personal information from children. If you believe a child has sent us information, contact certloomlearning@gmail.com and we will delete it.

20. Third-party services

The Services rely on or link to services supplied by Apple, Google, government websites and test administrators. Those third parties may independently collect and process information under their own terms and privacy policies. We are not responsible for their independent privacy practices.

21. Changes to this Privacy Policy

We may update this Privacy Policy when the Services, technologies, providers, legal requirements or our privacy practices change. The effective date and version will be updated when the Policy changes, and the current Policy is always at https://clbmock.web.app/privacy/. App versions with one acceptance do not ask you again in the app when the Policy changes (app versions that ask separately for each feature ask again before that feature sends anything after a material change). We will mention material changes in the app's store release notes, and where applicable law requires additional notice or consent, we will provide it.

22. Contact

Privacy questions, requests, complaints and other privacy-related communications may be sent to:

CLB Mock Operated under the Certloom Learning brand Person in charge of the protection of personal information: the Operator Email: certloomlearning@gmail.com

Do not send unnecessary sensitive personal information in an email request.