We believe privacy is a right, not a checkbox. This policy explains exactly what we collect, why, and how you can control it.
FrenchPathway ("we", "us", "our") is an online French language exam preparation service operated by FrenchPathway Inc. We help students prepare for the TCF Canada and TEF Canada examinations required for Canadian immigration (Express Entry, work permits).
Data Controller: FrenchPathway Inc., Canada
Privacy contact: support@frenchpathway.ca
We are subject to Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, provincial privacy laws and the General Data Protection Regulation (GDPR) for users in the European Economic Area.
| Data | When collected | Why required |
|---|---|---|
| First name | Account sign-up | Personalize your experience |
| Email address | Account sign-up | Account creation, receipts, important notices |
| Practice responses (typed text, voice transcriptions) | During module exercises | AI scoring and feedback |
| Uploaded images (handwritten work) | Writing module — optional | AI handwriting recognition and scoring |
| Feedback messages | In-app feedback form | Product improvement |
| Referral code | When you share or use a referral link | Referral reward attribution |
| Data | Purpose |
|---|---|
| IP address | Rate limiting AI scoring calls, fraud prevention, security logging |
| Browser/device type | Debugging and compatibility |
| Session activity (pages visited, module progress) | Service functionality; stored locally in your browser, not on our servers |
| Payment metadata (Stripe session ID, plan purchased, timestamp) | Subscription verification; card details are never transmitted to us |
Under PIPEDA and GDPR, we rely on the following legal bases:
| Processing activity | Legal basis |
|---|---|
| Account creation and service delivery | Contract — necessary to perform our agreement with you |
| Payment processing and subscription verification | Contract |
| AI-powered practice scoring | Contract — core feature of the paid service |
| Security, rate limiting, fraud prevention | Legitimate interest |
| Product analytics (aggregated, anonymized) | Legitimate interest |
| Legal compliance and responding to lawful requests | Legal obligation |
| Marketing communications | Consent (opt-in only) |
We share data only with the following third-party service providers, and only to the extent necessary to operate our service:
| Provider | Purpose | Data shared | Location |
|---|---|---|---|
| Stripe, Inc. | Payment processing | Email, plan selected. Card details go directly to Stripe — never to us. | USA (SCCs / adequacy) |
| Anthropic, PBC | AI scoring of practice responses | Practice text/image; no name or email | USA (SCCs / adequacy) |
| Hostinger International Ltd. | Web hosting and database | Account data stored on servers | EU/Lithuania |
| Google Fonts | Font rendering | Your IP address (standard CDN request) | USA |
We may also disclose information when required by law (court order, regulatory request) or to protect our rights and the safety of our users. We will notify you of such disclosures unless legally prohibited from doing so.
FrenchPathway uses Claude (by Anthropic) to score your Writing and Speaking practice responses. Here is how it works and what it means for your privacy:
FrenchPathway is a lightweight single-page application. We use browser localStorage (not traditional cookies) to store your session state on your own device. This includes:
This data stays on your device and is not transmitted to our servers during normal browsing. It is cleared when you clear your browser data or log out.
Third-party services (Stripe, Google Fonts) may set their own cookies. Stripe sets cookies for fraud prevention and payment session continuity. Google Fonts may log standard CDN request data.
We do not currently use analytics cookies. If we add analytics in the future, we will update this policy and present a consent choice before any tracking begins.
| Data type | Retention period |
|---|---|
| Account information (name, email, plan) | Duration of your account + 2 years after deletion |
| Payment records (Stripe session ID, plan, date) | 7 years (tax and financial record requirements) |
| Referral records | 3 years from the referral event |
| AI rate-limit logs (IP address) | 30 days rolling |
| Security/audit logs | 90 days |
| Practice responses submitted for scoring | Not retained — processed and discarded immediately |
| Uploaded handwriting images | Not retained — discarded after scoring response is returned |
| Browser localStorage data | Until you clear browser data or request deletion |
Depending on where you are located, you have the following rights regarding your personal information:
| Right | What it means |
|---|---|
| Access | Request a copy of the personal information we hold about you |
| Correction | Ask us to correct inaccurate or incomplete information |
| Deletion | Request erasure of your personal information (subject to legal retention requirements) |
| Portability | Receive your data in a structured, machine-readable format |
| Objection | Object to processing based on legitimate interest |
| Withdraw consent | Withdraw any consent you have given at any time (e.g., marketing emails) |
| Lodge a complaint | File a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca |
To exercise any right, email support@frenchpathway.ca with the subject line "Privacy Request — [Right]". We will respond within 30 days. We may need to verify your identity before processing the request.
We take the security of your information seriously and implement the following measures:
No method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that creates a real risk of significant harm, we will notify affected users and the Office of the Privacy Commissioner of Canada within 72 hours of becoming aware of the breach, as required under PIPEDA.
FrenchPathway is intended for users aged 16 and older. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@frenchpathway.ca and we will delete that information promptly.
FrenchPathway is operated from Canada. When we share data with service providers in the United States (Stripe, Anthropic), we rely on standard contractual clauses (SCCs) and adequacy decisions where applicable to ensure your data receives equivalent protection to Canadian standards.
Our hosting provider (Hostinger) operates servers within the European Union, which is recognized by Canada as providing adequate protection for personal information.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:
Your continued use of FrenchPathway after the effective date constitutes acceptance of the updated policy. If you do not agree with the changes, you may close your account before the effective date.
For any privacy-related questions, requests, or concerns:
If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Privacy Commissioner of Canada: