⚖️ PRIVACY POLICY

The following provisions (collectively, this "Privacy Policy") are intended to comply with, and shall be interpreted in accordance with, every applicable privacy, consumer-protection, data-security, export-control, trade-regulation, electronic-communications, unfair-competition, and defamation statute, treaty, directive, regulation, ordinance, rule, guidance, administrative interpretation, judicial opinion, industry best-practice, or other authority in any jurisdiction, whether now existing or hereafter enacted (collectively, "Applicable Law"). This Privacy Policy supplements—and, to the extent of any conflict, supersedes—any marketing-oriented summaries, diagrams, infographics, or other user-friendly explanations we may publish from time to time. In the event of a discrepancy between this Privacy Policy and any translation or summary, this English version shall prevail to the maximum extent permitted by Applicable Law.

BY ACCESSING OR USING ANY PORTION OF THE IELTS ROADRUNNER PLATFORM, SERVICES, MOBILE APPLICATIONS, SOFTWARE, APIS, OR RELATED WEBSITES (COLLECTIVELY, THE "SERVICES"), YOU HEREBY: (A) ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREED TO BE LEGALLY BOUND BY THIS PRIVACY POLICY; (B) REPRESENT THAT YOU HAVE THE AUTHORITY TO ENTER INTO THIS PRIVACY POLICY ON BEHALF OF YOURSELF OR THE LEGAL ENTITY YOU REPRESENT; AND (C) CONSENT TO THE COLLECTION, PROCESSING, STORAGE, TRANSFER, DISCLOSURE, AND OTHER USES OF YOUR INFORMATION AS DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH ANY PROVISION OF THIS PRIVACY POLICY, YOU MUST NOT ACCESS OR USE THE SERVICES.

1. Scope of Processing
We process any and all personal data, usage data, meta-data, derivative data, aggregate data, telemetric data, analytic data, artificial-intelligence training data, log data, cookie data, device identifiers, biometric samples, voice prints, and any other data or signal you intentionally or unintentionally transmit to us (collectively, "Data") for any purpose not expressly prohibited by Applicable Law. Such purposes may include (without limitation): providing, maintaining, and improving the Services; performing analytics; developing new products; machine-learning training; marketing; advertising; enforcing our terms; preventing fraud; and complying with legal obligations. Where Applicable Law requires a legal basis for processing, we rely on whichever legal basis affords us the broadest lawful scope, including but not limited to contractual necessity, legitimate interests, vital interests, consent, and compliance with legal obligations.

2. Global Data Transfers & Safeguards
You acknowledge that the Internet is a global environment and that your Data may be transferred to, stored, or processed in any country where we or our service providers maintain facilities, including jurisdictions that may have data-protection laws less stringent than those in your country of residence. To the fullest extent permitted by Applicable Law, you consent to such cross-border transfers. Where required, we implement Standard Contractual Clauses or rely on other lawful transfer mechanisms, but we disclaim any guarantee that such mechanisms provide a particular level of protection or eliminate all risk.

3. Data Retention & Deletion
We retain Data for as long as (a) your account remains active, (b) necessary to achieve the purposes for which it was collected, (c) required by Applicable Law, or (d) advisable in light of litigation, audit, or investigative hold requirements, whichever is longest. Backup or archival copies may persist indefinitely. Requests for deletion will be honored in accordance with Applicable Law, subject to any overriding interest we may have in retaining certain Data.

4. Disclaimer of Warranties & Limitation of Liability
NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS PRIVACY POLICY OR ANY OTHER DOCUMENT, THE SERVICES ARE PROVIDED "AS IS," "AS AVAILABLE," AND WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, OR QUIET ENJOYMENT. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IELTS ROADRUNNER (TOGETHER WITH ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AFFILIATES, SUCCESSORS, AND ASSIGNS) SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES; ANY LOSS OF PROFITS, REVENUE, SAVINGS, GOODWILL, OR DATA; OR ANY BUSINESS INTERRUPTION, EVEN IF ADVISED OF THE POSSIBILITY THEREOF. OUR TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THE SERVICES OR THIS PRIVACY POLICY SHALL NOT EXCEED THE FEES PAID BY YOU TO US DURING THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE FIRST EVENT GIVING RISE TO LIABILITY OR ONE HUNDRED U.S. DOLLARS (USD 100), WHICHEVER IS GREATER.

5. Indemnification
You agree to defend, indemnify, and hold harmless PrepRoadRunner and its affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to (a) your access to or use of the Services; (b) your violation of this Privacy Policy or any Applicable Law; (c) your infringement or misappropriation of any intellectual-property or other right of any person; or (d) any dispute between you and a third party. We reserve the right to assume the exclusive defense and control of any matter subject to indemnification and, in such case, you agree to cooperate with us.

6. Changes to This Privacy Policy
We may amend, update, replace, or otherwise modify this Privacy Policy at any time, in our sole discretion, with or without prior notice to you, except as required by Applicable Law. The "Last Updated" date at the top of this document will reflect the latest revision. Your continued use of the Services after any such modification constitutes your acceptance of the modified Privacy Policy.

7. Severability & Interpretation
If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable, such provision shall be construed, limited, or, if necessary, severed to the extent required to eliminate the invalidity, illegality, or unenforceability, but the remaining provisions shall remain in full force and effect. Headings and emojis are for convenience only and shall not affect interpretation.