1. Information We Collect

The information we collect depends on the services you use.

Account and contact information

We may collect:

• Your name;
• Email address;
• Telephone number;
• Country, province or general location;
• Account login information;
• Organization, school or employer;
• Parent or guardian information where applicable; and
• Information you provide when contacting us.

Purchase and transaction information

When you make a purchase, we may receive:

• The product or service purchased;
• Transaction date and amount;
• Currency and applicable taxes;
• Payment status;
• Billing name and address;
• Discount, affiliate or referral information; and
• Limited payment-related information supplied by the payment processor.

Payments may be processed through Payhip and the payment provider presented at checkout. We generally do not receive or store your complete payment-card number.

Learning and account activity

We may collect information about how you use our learning services, including:

• Courses, lessons and activities accessed;
• Quiz, test and assessment responses;
• Completion status and learning progress;
• Scores and internally generated level estimates;
• Certificates of completion;
• Download history;
• Membership activity;
• Tool usage;
• Language-learning preferences; and
• Technical or support issues.

AI, speaking, writing and assessment information

When you use an AI-assisted or interactive feature, we may process:

• Written answers, prompts and documents;
• Audio or voice recordings;
• Speech transcriptions;
• Pronunciation attempts;
• Reading and listening responses;
• Images or files voluntarily submitted;
• AI-generated feedback; and
• Assessment results.

Voice information is used to provide speaking, pronunciation or interactive learning functions. It is not intended to be used for identity verification or biometric identification.

Do not submit government identification numbers, financial account information, medical information or other highly sensitive personal information through our AI tools.

VR and facilitated-program information

For virtual reality sessions, workshops and community programs, we may collect:

• Participant name and age range;
• Registration and attendance information;
• Emergency or accessibility information voluntarily provided to the facilitator;
• Activity completion and engagement observations;
• Session feedback;
• Photos, video or testimonials where separate permission has been obtained; and
• Reports prepared for the participant or participating organization.

Website and technical information

We may automatically collect:

• Internet Protocol address;
• Browser and device type;
• Operating system;
• Referring webpage;
• Pages viewed;
• Approximate location derived from an IP address;
• Login and access timestamps;
• Cookie identifiers; and
• Error, security and performance information.

2. How We Collect Information

We collect personal information:

• Directly from you;
• From a parent or guardian;
• Through our website, applications and learning tools;
• Through Payhip and other service providers;
• From an organization that purchases or administers access for you;
• Through registration, inquiry or assessment forms;
• During facilitated programs or events; and
• Through cookies and similar technologies.

3. How We Use Information

We may use personal information to:

• Create and manage accounts;
• Process purchases, instalments, subscriptions and refunds;
• Deliver courses, software, memberships and digital products;
• Generate learning feedback, assessments and progress reports;
• Operate AI-assisted, speaking, writing, reading and listening features;
• Administer VR sessions and organizational programs;
• Provide technical and customer support;
• Verify licences and prevent account sharing or unauthorized access;
• Send transaction, account and service messages;
• Send marketing communications where permitted;
• Improve our courses, tools, website and services;
• Measure usage, performance and engagement;
• Protect our systems and users;
• Investigate suspected fraud, abuse or policy violations;
• Maintain business, accounting and legal records; and
• Meet legal and regulatory requirements.

We may use aggregated or de-identified information for analytics, research, product development and business planning where that information does not reasonably identify an individual.

4. Institutional and Organization-Sponsored Accounts

Your access may be purchased, administered or sponsored by a tutoring centre, school, daycare, out-of-school-care provider, employer, senior organization or other partner.

In those circumstances, the organization may receive information reasonably connected to its program, including:

• Enrollment or attendance;
• Course and activity completion;
• Assessment or quiz results;
• Progress summaries;
• Certificates;
• Engagement reports; and
• Account or licence status.

The participating organization is responsible for obtaining any consent it requires from learners, parents, guardians, employees or participants before providing their information to us.

An organization may have its own privacy policy in addition to this Privacy Policy.

5. Service Providers and Disclosure of Information

We may share personal information with service providers that help us operate our business, including providers of:

• Website and course hosting;
• Ecommerce and payment processing;
• Cloud storage and databases;
• Email delivery;
• Analytics;
• Customer support;
• Artificial intelligence and speech processing;
• Video, media and content delivery;
• Software licensing and authentication;
• Cybersecurity; and
• Professional accounting, legal or technical services.

These providers may access information only as reasonably necessary to perform services for us, subject to their agreements and legal obligations.

We may also disclose information:

• With your consent;
• To a parent, guardian or sponsoring organization where authorized;
• To investigate fraud, security incidents or prohibited activity;
• To comply with a court order, legal process or lawful government request;
• To protect the rights, safety or property of our users, the public or Simple French With Hems Inc.; or
• In connection with a merger, financing, restructuring, sale or transfer of all or part of the business.

We do not sell personal information to data brokers.

6. Third-Party AI Services

Some learning tools may rely on third-party artificial intelligence, speech recognition, transcription or cloud-processing providers.

Information submitted through these tools may be sent to and processed by those providers to generate the requested response or feedback. Their processing may occur outside Canada.

AI-generated responses may be inaccurate, incomplete or inappropriate. Users should not rely on AI feedback as an official examination result, professional evaluation or immigration determination.

7. Cookies and Similar Technologies

We and our service providers may use cookies and similar technologies to:

• Keep you signed in;
• Remember preferences;
• Operate shopping-cart and checkout functions;
• Protect accounts;
• Understand website traffic;
• Measure performance; and
• Improve our services.

Some cookies are necessary for the website to function. You may block or delete cookies through your browser settings, but doing so may prevent certain features from working correctly.

8. Marketing Communications

We may send promotional emails when you have provided consent or when otherwise permitted by law.

Marketing messages will include an unsubscribe method. You may unsubscribe at any time. Unsubscribing from promotional messages will not prevent us from sending receipts, account notices, security messages or other communications required to provide a service you requested.

9. Children and Minors

Children may participate in certain Simple French with Hems programs, but they should not independently purchase products or create paid accounts unless permitted by applicable law.

A parent, legal guardian or authorized organization must approve or administer a minor’s participation where appropriate.

We do not knowingly request unnecessary sensitive information from children. Parents or guardians may contact us regarding a child’s personal information.

10. International and Cross-Border Processing

Our business is based in Alberta, Canada. Some service providers may store or process information in other provinces or countries.

Personal information processed outside Alberta or Canada may be subject to the laws of the jurisdiction where it is processed and may be accessible to courts, law enforcement or government authorities in that jurisdiction.

11. Retention

We retain personal information only for as long as reasonably necessary to:

• Provide the relevant service;
• Maintain account and purchase records;
• Complete contractual obligations;
• Resolve disputes;
• Enforce our agreements;
• Prevent fraud;
• Meet tax, accounting and legal requirements; and
• Maintain legitimate business records.

Different categories of information may be retained for different periods. Information that is no longer required will be deleted, anonymized or securely disposed of, subject to technical and legal limitations.

12. Security

We use reasonable administrative, technical and organizational safeguards intended to protect personal information against loss, theft, unauthorized access, disclosure, alteration and misuse.

No internet transmission, cloud platform or storage system can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your password and notifying us promptly if you suspect unauthorized account access.

Where required by law, we will investigate privacy and security incidents and provide appropriate notifications.

13. Your Privacy Choices and Rights

Subject to applicable law, you may request to:

• Access personal information we hold about you;
• Correct inaccurate or incomplete information;
• Withdraw consent where processing depends on consent;
• Close your account;
• Request deletion of information that we are not legally or contractually required to retain;
• Ask how your information has been used or disclosed; or
• Submit a privacy complaint.

Withdrawal of consent may limit our ability to provide certain services.

We may need to verify your identity before completing a privacy request. Some requests may be restricted where disclosure would affect another person’s privacy, reveal confidential business information or conflict with a legal requirement.

14. Third-Party Websites

Our website may contain links to third-party websites, platforms and services. We are not responsible for the privacy practices, content or security of third-party services. Review their policies before providing personal information.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technology or legal obligations.

The revised policy will be posted with a new “Last Updated” date. Where a change materially affects how personal information is handled, we will provide additional notice where reasonably appropriate or legally required.

16. Privacy Officer and Contact Information

Questions, concerns and privacy requests may be sent to: