Privacy
Policy

This Privacy Policy explains how BlackNerd Studio Limited collects, uses, and protects your personal data when you use Prepwise, our AI-powered IELTS Speaking practice application. It applies to the Prepwise app on all platforms on which it is available.

BlackNerd Studio Limited is the data controller for Prepwise. For data practices relating to our website and company more broadly, see our Company Privacy Policy.

1. Who We Are

BlackNerd Studio Limited is the data controller responsible for your personal data.

• Company: BlackNerd Studio Limited
• Registered address: 20 Reginald Road, London, E7 9HS, United Kingdom
• Registration: Registered in England & Wales
• Contact: hello@blacknerd.studio

2. Data We Collect

Depending on how you use Prepwise, we may collect the following categories of personal data:

Account & Identity Data

• Name and email address (when you create an account)
• Authentication credentials (stored securely and never in plaintext)
• Account preferences and settings

Voice & Audio Data

• Audio of your spoken responses, captured only while you are actively practising with our AI voice agent
• A transcript of your responses, used to generate your feedback and band scores
• We do not store your audio recordings — they are used to produce your transcript and feedback, then discarded (see Section 5)

Practice & Usage Data

• Practice session results, band scores, and feedback history
• In-app activity (features used, session duration)
• Anonymised session recordings of your in-app screen interactions (via our analytics provider), with text you type masked and sensitive screens such as the live speaking room excluded from recording
• Crash reports and error logs

Device & Technical Data

• Device type, operating system, and app version
• IP address and approximate location (country/region level)
• A device push-notification token, if you enable notifications, so we can send you reminders and updates such as when your feedback is ready

Communications Data

• Messages you send us (e.g. support requests or feedback)

3. How We Use Your Data

We use your personal data to:

• Provide the service: process your speaking sessions, generate AI feedback, and display your results and progress
• Manage your account: create and secure your account, authenticate you, and enable personalised features
• Improve Prepwise: analyse usage and fix bugs, using anonymised or aggregated data where possible
• Provide support: respond to your questions and resolve issues
• Send notifications: if you opt in, send reminders and updates such as when your feedback is ready; you can turn these off at any time in the app or your device settings
• Process purchases: manage in-app purchases and subscriptions through the relevant app store
• Keep the service safe: detect fraud, abuse, or unauthorised access
• Meet legal obligations: comply with applicable laws

4. Legal Bases for Processing (UK & EU GDPR)

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

• Performance of a contract: to provide the Prepwise service you have signed up for
• Consent: to capture and process your voice for scoring and feedback; you can withdraw consent at any time by stopping use and deleting your account
• Legitimate interests: to improve our product, maintain security, and communicate service-related updates
• Legal obligation: where we are required to process data by law

5. Voice Recordings & AI Processing

Prepwise uses third-party voice AI agents (provided by Vapi and ElevenLabs) to run your practice conversation. When your session ends, your audio recording and a transcript of the session are delivered to our backend, where we use AI models to generate your feedback and band scores.

We do not retain your audio recordings: once your feedback has been generated, the recording is discarded. We keep your transcript and feedback so you can review your results and track progress, and so we can regenerate your feedback if and when we improve our scoring models.

We do not use your voice for biometric identification, voiceprinting, or advertising. Your voice and transcript data are processed by our sub-processors strictly on our behalf and under contract (see Section 6), and are deleted when you delete your account (see Section 11).

6. How We Share Your Data

We do not sell your personal data. We share data only with service providers (sub-processors) who process it on our behalf, under data processing agreements, in the following categories:

• Voice AI agents (Vapi, ElevenLabs): to run your real-time speaking conversation and process your audio and transcript
• AI model providers (OpenAI, Anthropic, Google): to generate your written feedback and band-score assessments from your transcript
• Cloud infrastructure providers: for hosting, storage, and databases
• Analytics & session replay (PostHog): to understand how the app is used so we can improve it, including anonymised session replays — recordings of your in-app screen interactions, with typed text masked and sensitive screens excluded
• App stores (Apple, Google): to process payments and subscriptions; we never receive or store your card details

We may also disclose data where required by law, or to protect our rights, users, or the public. A current list of our sub-processors is available on request at hello@blacknerd.studio.

7. International Transfers

Your data is primarily stored and processed in the United Kingdom and European Economic Area. Where data is transferred outside these regions (for example, to AI sub-processors), we put appropriate safeguards in place — such as UK International Data Transfer Agreements, EU Standard Contractual Clauses, or transfers to countries with an adequacy decision.

8. Data Retention

We keep personal data only as long as necessary:

• Audio recordings: not retained — discarded once your feedback has been generated
• Transcripts & feedback (results, band scores): kept while your account is active so you can review your history, track progress, and have your feedback regenerated when our scoring models improve
• Account data: kept while your account is active
• Communications: kept for up to 3 years for support and legal record-keeping

When you delete your account, your data is deleted immediately (see Section 11), apart from the limited communications records above and anything we are required to keep by law.

9. Your Rights

Where the UK GDPR or EU GDPR applies, you have the right to: access your data; correct inaccurate data; request erasure; restrict or object to processing; data portability; and withdraw consent at any time.

To exercise any of these rights, contact hello@blacknerd.studio. We will respond within one month. If you are in the UK, you also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk. If you are in the EEA, you may complain to your local supervisory authority.

10. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect and how we use it; to request deletion or correction of your information; to opt out of the “sale” or “sharing” of personal information; and to limit the use of sensitive personal information. We will not discriminate against you for exercising these rights.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. To make a request, contact hello@blacknerd.studio.

11. How to Delete Your Account and Data

You can permanently delete your account at any time from within the app, in Settings → Account → Delete Account. When you do, we immediately and permanently delete your personal data from our systems — including your transcripts, feedback, results, and account details.

We also delete the personal data held about you by our sub-processors (such as Vapi and ElevenLabs). Some third-party deletions complete shortly afterwards rather than instantly — for example, analytics data held in PostHog is removed through its data-deletion process. Aggregated or anonymised data that no longer identifies you may be retained.

If you need help, email support@blacknerd.studio and we will action your request.

12. Children’s Privacy

Prepwise is intended for users aged 16 and over. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with their data, please contact us and we will delete it promptly.

13. Security

We use appropriate technical and organisational measures to protect your data, including encryption of data in transit and access controls. No method of transmission or storage is completely secure, but we work to protect your information and to address any incidents promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will revise the “Last updated” date above and, for significant changes, notify you in the app or by email.

15. Contact Us

If you have any questions about this policy or your data:

• Privacy & data requests: hello@blacknerd.studio
• Support: support@blacknerd.studio
• Post: BlackNerd Studio Limited, 20 Reginald Road, London, E7 9HS, United Kingdom