Privacy Policy

1. Introduction

First Pass LLC ("First Pass English," "we," "us," or "our") operates the First Pass English platform (firstpassenglish.com), an online English exam practice service. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

We are committed to protecting your privacy and handling your data transparently. We collect only the minimum data necessary to provide our service and give you full control over your information.

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address and password (encrypted) when you create an account
• Profile Information: Optional first name for personalization
• Payment Information: Processed securely by Stripe. We do not store your credit card details
• Support Requests: Information you provide when contacting our support team

2.2 Information Collected Automatically

• Usage Data: Exam progress, scores, study preferences, and learning analytics
• Device Information: Browser type, operating system, and device identifiers
• Log Data: IP address, access times, pages viewed, and referring URLs

2.3 Information We Do NOT Collect

• Date of birth or age
• Physical address
• Phone number
• Social media profiles
• Biometric data

3. How We Use Your Information

We use your information to:

• Provide and maintain our exam practice service
• Track your learning progress and display your scores
• Process payments and manage your subscription
• Send essential service communications (password resets, subscription updates)
• Respond to your support inquiries
• Improve our service based on usage patterns
• Prevent fraud and ensure platform security

We do not: Sell your personal information, use your data for targeted advertising, or share your information with third parties for their marketing purposes.

4. Third-Party Services

We use the following third-party services to operate our platform. These providers process your data only as necessary to provide their services and are bound by data processing agreements:

We do not share your personal information with other third parties except as required by law or as necessary to protect our rights.

5. Data Retention

• Active Accounts: We retain your data for as long as your account is active
• Deleted Accounts: When you delete your account, we remove your personal data within 30 days
• Backups: Backup copies are automatically deleted after 14 days
• Anonymized Data: We may retain anonymized, aggregated data for analytics indefinitely
• Legal Requirements: We may retain certain data longer if required by law (e.g., financial records for tax purposes)

6. Your Rights

You have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Delete your account and all associated data
• Export: Download your data in a portable format
• Objection: Object to certain processing of your data
• Restriction: Request we limit how we use your data
• Withdraw Consent: Where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at privacy@firstpassenglish.com. We will respond within 30 days.

6.1 For Users in the European Economic Area (EEA)

Under the General Data Protection Regulation (GDPR), you have additional rights including the right to lodge a complaint with your local supervisory authority. You may also request information about whether we transfer your data outside the EEA and what safeguards are in place.

6.2 For Users in Japan

Under the Act on the Protection of Personal Information (APPI), you have the right to request disclosure, correction, addition, deletion, cessation of use, or cessation of third-party provision of your personal information.

Purpose of Use (APPI): We use your personal information for the following specific purposes:

• Provision and operation of the First Pass English exam practice service
• User account management and authentication
• Payment processing and subscription management
• Customer support and inquiry response
• Service improvement and development
• Prevention of unauthorized use and fraud

How to Make a Request: Send an email to privacy@firstpassenglish.com with the subject line "APPI Request". We may ask you to verify your identity before processing. We will respond within a reasonable period, and no fee is charged for standard requests.

6.3 For California Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have specific privacy rights:

• Right to Know: Request information about personal data collected, used, disclosed, or sold in the past 12 months
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: We do not sell or share your personal information for cross-context behavioral advertising
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

How to Exercise Your CCPA Rights: Submit a request to privacy@firstpassenglish.com with the subject line "CCPA Request". We will verify your identity and respond within 45 days. You may designate an authorized agent to make requests on your behalf.

7. Cookies and Local Storage

We use cookies and local storage for:

• Authentication: Keeping you signed in to your account
• Preferences: Remembering your language and display settings
• Progress: Saving your exam progress locally for faster loading

We do not use tracking cookies for advertising. You can disable cookies in your browser settings, but this may affect the functionality of our service.

8. International Data Transfers

First Pass LLC is based in the United States. If you are accessing our service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers and service providers are located.

For international transfers, we rely on:

• Data processing agreements with all third-party processors
• Our service providers' compliance certifications and safeguards
• Standard contractual clauses where applicable

9. Data Security

We implement industry-standard security measures to protect your data:

• All data transmitted over HTTPS (TLS encryption)
• Passwords are hashed and never stored in plain text
• Database access restricted and monitored
• Regular security reviews and updates

While we strive to protect your information, no method of transmission over the internet is 100% secure. If you believe your account has been compromised, please contact us immediately.

9.1 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and relevant supervisory authorities within 72 hours of becoming aware of the breach, as required by applicable law.

10. Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal effects or similarly significantly affects you. Exam scoring is automated but does not have legal or significant effects beyond the educational context of our service.

11. Children's Privacy

Our service is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@firstpassenglish.com, and we will delete such information.

For users in the European Economic Area, our service is intended for users aged 16 and older, or with parental consent where permitted by local law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we may also send you an email notification. We encourage you to review this page periodically.

Previous versions of this Privacy Policy are available upon request.

13. Governing Law

This Privacy Policy is governed by the laws of the State of Wyoming, United States. However, this does not affect your statutory rights under GDPR, APPI, CCPA, or other applicable data protection laws in your jurisdiction.

14. Contact Us

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