Lumi TOEFL Privacy Policy
Lumi TOEFL ("we", "our", or "us") provides TOEFL-style writing, reading, listening, and speaking practice, AI feedback, progress tracking, Lumids, rewarded ads, and related services.
Information We Collect
We may collect account information such as Firebase user ID, email address, display name, optional username, optional profile photo, account role, account creation time, and account deletion status. Passwords are handled by Firebase Authentication; we do not store raw passwords.
When you use practice and grading features, we may collect writing answers, question type, word count, time spent writing, submission status, AI grading results, feedback, corrected sentences, vocabulary suggestions, grading errors, and model metadata.
When you use Speaking practice, we use your microphone when you start a microphone check or record an answer. Microphone checks are processed on your device. When you submit a speaking attempt, we collect the answer recordings, question type, recording duration, AI transcripts, scores, feedback, and grading metadata. Recordings are stored in Firebase Storage and can be played back by you and by our staff for quality review.
For Lumids, rewards, and purchases, we may collect wallet balances, unlocked question IDs, rewarded ad completion events, package IDs, purchase amounts, payment status, purchase timestamps, and transaction identifiers from Apple App Store, Google Play, or Stripe, depending on the platform.
We may also collect leaderboard settings, progress statistics, inbox/admin note data, usage events, crash reports, performance data, Remote Config fetch data, audit logs, and local preference data.
Account details, profile photos, practice submissions, speaking recordings, progress, rewards, and purchase records are associated with your account. We also provide your Firebase user ID to Google Analytics and Firebase Crashlytics to analyze usage and diagnose errors. These records are linked to your account rather than treated as anonymous.
AI Processing
When you request AI grading, your written answers or speaking recordings and related question context are sent to Google through Firebase Cloud Functions and Google Cloud Vertex AI or Firebase AI Logic. Google Gemini models process this content to produce transcripts, scores, corrections, and feedback. The related question context may include reading passages, task instructions, or listening transcripts. Your submissions and results are stored with your account so you can review them. We do not send your practice answers or speaking recordings to advertising partners for advertising.
Advertising: Appodeal and Kakao AdFit
The iOS and Android apps use Appodeal mediation for banners and optional rewarded video ads. Website banners use Kakao AdFit. See Appodeal’s privacy policy and Appodeal’s data-disclosure guidance.
Appodeal, its consent-management and mediation services (including Bidon and BidMachine), and participating advertising networks may collect or receive advertising and device identifiers, IP address and approximate location, device model and operating system, language and network information, ad impressions and clicks, video completion events, app interactions, and performance or diagnostic information. Collection and use depend on the network serving the ad, your region, device settings, and consent choices. The app does not request precise GPS location permission.
Integrated advertising partners include AppLovin, Meta Audience Network, Unity Ads, Liftoff/Vungle, Mintegral, Yandex, and other networks available through the configured mediation adapters. Partners use advertising data to deliver and measure ads, manage ad auctions, prevent fraud, and improve their services. Where permitted by your consent and platform settings, advertising identifiers and related ad activity may be combined with information from other companies’ apps and websites for personalized advertising and advertising measurement.
On iOS, the app requests App Tracking Transparency permission before initializing advertising when a tracking choice has not yet been made. Appodeal’s consent manager also manages mobile advertising consent where required. We do not initialize or request mobile ads for users who select an age under 18 or whose age eligibility is unknown.
For rewarded ads, we send Appodeal a temporary, single-use reward-session identifier. Our server can associate that identifier with your account to credit Lumids after verifying Appodeal’s encrypted completion callback and transaction identifier. It is not your email address or a permanent account ID. We do not send Appodeal your name, email address, practice answers, or speaking recordings for advertising.
Other Service Providers and Information Shared
- Google Firebase and Google Cloud: account identifiers and sign-in details, profile information, submitted text and audio, practice results, wallet and purchase records, and operational data for authentication, storage, hosting, grading, security, and support.
- Google Analytics and Firebase Crashlytics/Performance Monitoring: user or installation identifiers, usage events, device information, crash reports, performance metrics, and diagnostic information for usage analysis and reliability. Analytics and crash reports can be associated with your Firebase user ID.
- Apple, Google, and Kakao sign-in: authentication information exchanged with the sign-in provider you choose. We receive the account information that provider makes available, such as an identifier, name, email address, or profile image.
- Apple App Store and Google Play: in-app purchases on their respective mobile platforms. We receive purchase and transaction information to validate purchases and deliver Lumids; we do not receive your full payment card or bank account details.
- Stripe: website payment processing. Stripe handles payment details, and we receive checkout, payment-status, customer, and transaction identifiers needed to fulfill purchases and maintain records.
- Kakao AdFit: website advertising, including browser/device information and advertising interactions according to its policies and applicable settings.
Google explains how it uses data from sites and apps that use its services at policies.google.com/technologies/partner-sites.
How We Use Information
We use information to create and manage accounts, authenticate users, provide writing practice and feedback, process AI and human grading, maintain progress history, award Lumids, unlock content, process purchases, operate rewarded ad features, display leaderboards, send support messages, improve reliability, prevent abuse, administer roles, comply with law, and enforce our rights.
Account Deletion and Retention
You may request account deletion in the app. Accounts are scheduled for a 30-day recovery period. After that period, direct account identifiers may be deleted or de-identified, but writing submissions and grading records may be retained in de-identified or disassociated form for product improvement, quality control, analytics, abuse prevention, records, and service operations. Speaking attempts and voice recordings are deleted when account deletion is completed.
Your Choices
You may choose whether to use Apple, Google, or Kakao sign-in, request AI grading, watch rewarded ads, appear on leaderboards, or request account deletion. You can review microphone permission in your device settings. On iOS, you can manage tracking permission in Settings > Privacy & Security > Tracking. Where advertising privacy options are available for your region, open Profile > Ad privacy choices in Lumi TOEFL to reopen Appodeal’s consent form. The age range used for advertising eligibility is stored only on the device.
To request access to, correction of, or deletion of your information, use the account settings in the app where available or contact [email protected]. Account deletion and retention are described above.
Children's Privacy
This release is intended for users age 16 and older. Users who select an age under 16 cannot continue into the iOS or Android app, and mobile ads are disabled for every user under 18. If you believe a child has provided personal information in violation of applicable law, contact us so we can review the situation.
International Processing
Your information may be processed and stored in countries other than your own, depending on where our service providers and infrastructure operate.
Contact
For privacy requests or questions, contact [email protected].
TOEFL is a registered trademark of ETS. This product is not endorsed or approved by ETS.