IELTS Navigator Privacy Policy

July 11, 2022

1. Introduction

Before you continue using our website, we advise you to read our Privacy Policy. This Privacy Policy informs you of our policies and practices regarding the collection, use and disclosure of Personal Information we receive from users of the Site and Service.


Xelentememória, Unipessoal Lda is a company registered in Portugal, a Member State of the European Union, operating the website (the “Site”) and the IELTSNavigator AI scoring system (the “Service”).


By using the Site and Service, you (the “Data Subject”) agree to the collection and use of information in accordance with this Privacy Policy.

If you have any questions about this Privacy Policy or the use of your personal data, you can contact us at


This Privacy Policy is a part of our Terms and Conditions; by agreeing to Terms and Conditions, you also agree to this Policy. In the event of collision of terms used in Terms and Conditions and Privacy Policy, the latter shall prevail.

2. Changes

We reserve the right to make a change to this Privacy Policy. If You are a registered User, we will inform you about material changes via email. The last modification was made on the 21st of July, 2022.

3. Data Collection Principles

We promise to follow the following data protection principles:


a. Processing is lawful, fair, and transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you with information regarding Processing upon request.

b. Processing is limited to its purpose. Our Processing activities fit the purpose for which Personal Data was gathered.


c. Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.


d. Processing is limited by a time period. We will not store your personal data for longer than needed.


e. We will do our best to ensure the accuracy of the data.


f. We will do our best to ensure the integrity and confidentiality of data.

4. Data Subject Rights

The Data Subject has the following rights:


a. Right to information – meaning you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.


b. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.


c. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.


d. Right to erasure – meaning in certain circumstances, you can request for your Personal Data to be erased from our records.


e. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.


f. Right to object to processing – meaning in certain cases, you have the right to object to the Processing of your Personal Data, for example, in the case of direct marketing.


g. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling, and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.


h. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or, if it is feasible, as a direct transfer from one Processor to another.


i. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way, your request has been handled, please contact us.

j. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.


k. Right to withdraw consent – you have the right to withdraw any given consent for the Processing of your Personal Data

5. Disclosure

We do not disclose Your Personal Information to any third parties unless we have Your explicit consent to do so. However, anonymised user interactions are shared with third-party data processors for analytics, business intelligence, and generally improving the Site and Service.

6. Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We use safe protocols for communication and transferring data (such as HTTPS). We use anonymisation and pseudonymisation where suitable. We monitor our systems for possible vulnerabilities and attacks.

7. Children

Our Services are only provided to those over eighteen years old, and therefore, we do not intend to or knowingly collect information from children. We do not target children with our services.

8. Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, and the time spent on those pages and other statistics. In addition, we may use third-party services such as Google Analytics that collect, monitor and analyze this.

9. Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.


We use cookies for the following purposes:


a. Necessary cookies – These cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.


b. Functionality cookies – These cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and email in comment forms so you don’t have to re-enter this information next time when commenting.


c. Analytics cookies – These cookies are used to track the use and performance of our website and services.


d. Advertising cookies – These cookies are used to deliver advertisements that are relevant to you and your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed on the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website, and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

10. Embedded Content

Pages on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Below you can find a list of the services we use:

Twitter. We use the Twitter API to display our tweet’s timeline on our site. Twitter has its own cookie and privacy policies over which we have no control. Your IP is not sent to a Twitter server until you consent to it. See their privacy policy here: Twitter Privacy Policy.

YouTube. We use YouTube videos embedded on our site. YouTube has its own cookie and privacy policies over which we have no control. There is no installation of cookies from YouTube, and your IP is not sent to a YouTube server until you consent to it. See their privacy policy here: YouTube Privacy Policy.