Privacy Policy

1. Introduction

Osborne Education And Migration Pvt Ltd ("we", "us", "our") operates ClearMyPTE. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform. By using our services, you consent to the practices described in this policy.

2. Information We Collect

Personal Information

• Name, email address, phone number, and username during account registration.
• Payment information (processed securely by Razorpay — we do not store card details).
• Profile photo if you choose to upload one.
• Institute affiliation details for institute-managed accounts.

Usage Data

• Practice session data including answers, scores, and time spent.
• Mock exam results and performance analytics.
• Audio recordings submitted for speaking practice (processed for scoring, then retained for your review).
• Browser type, IP address, device information, and access timestamps.
• Marketing attribution data (UTM parameters) that identify which advertisement or link brought you to our platform.

Communication Data

• WhatsApp messages exchanged through our support channel.
• Email correspondence with our support team.
• In-app notifications and their interaction data.

3. How We Use Your Information

• To provide and maintain our PTE preparation services.
• To process your AI-based scoring and generate personalized feedback.
• To track your progress and provide performance analytics.
• To process payments and manage subscriptions.
• To send important notifications about your account, subscription, and platform updates.
• To provide customer support via email and WhatsApp.
• To improve our AI scoring algorithms and platform features.
• To detect and prevent fraud or abuse of our services.

4. Data Sharing

We do not sell your personal data. We may share information with:

• Institute Administrators: If you are registered through an institute, your practice data and progress may be visible to your institute administrators.
• Payment Processors: Razorpay processes payments on our behalf under their own privacy policies.
• AI Service Providers: Your practice responses may be processed by third-party AI services (e.g., OpenAI) for scoring. This data is anonymized where possible.
• Communication Platforms: We use Chatwoot for customer support chat and Meta WhatsApp Business API for messaging.
• Analytics Providers: Google Analytics collects anonymized usage data to help us understand how our platform is used and improve our services.
• Advertising Partners: Meta (Facebook) Pixel collects conversion data to measure the effectiveness of our advertising campaigns. This data is subject to your cookie consent preference.
• Legal Requirements: We may disclose information if required by law or to protect our rights.

5. Data Security

We implement industry-standard security measures including encrypted data transmission (HTTPS/TLS), secure server infrastructure, access controls, and regular security audits. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. Practice data and scores are retained to maintain your progress history. You may request deletion of your account and associated data by contacting our support team. Some data may be retained for legal or legitimate business purposes after account deletion.

7. Cookies and Tracking

We use cookies and similar technologies to operate our platform, analyse usage, and deliver relevant advertising. When you first visit our website, a consent banner allows you to accept or reject non-essential cookies.

Types of Cookies We Use

• Essential (always active): Login session tokens and local storage for your preferences, test type selection, and cookie consent choice. These are necessary for the platform to function.
• Analytics (with consent): Google Analytics 4 (GA4) collects anonymized data about page visits, feature usage, and platform performance. This helps us improve our services.
• Advertising (with consent): Meta (Facebook) Pixel tracks conversion events such as signups and payments to measure the effectiveness of our advertising campaigns.

Marketing Attribution

When you arrive via an advertisement or promotional link, we capture standard UTM parameters (source, medium, campaign, content, term) and store them in your browser's local storage. If you create an account, these parameters are saved to your user record to help us understand which channels bring students to our platform. This data is never sold to third parties.

Managing Your Preferences

You can change your cookie preferences at any time by clearing your browser's local storage or site data, which will cause the consent banner to reappear on your next visit. If you reject non-essential cookies, analytics and advertising tracking will not be activated. You may also use your browser's built-in cookie settings to block or delete cookies.

8. Your Rights

You have the right to:

• Access and receive a copy of your personal data.
• Correct inaccurate personal information.
• Request deletion of your account and personal data.
• Opt out of non-essential communications (marketing messages, promotional WhatsApp campaigns).
• Lodge a complaint with a data protection authority if applicable.

9. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the updated policy on this page and updating the "Last updated" date. We encourage you to review this page periodically.

11. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: