Privacy Policy

Last updated: September 29, 2026

This policy explains how Dextrata Software Inc. ("Dextrata", "we", "us") handles personal information for the Road English website and app (the "Service"). It applies to everyone who uses the Service, wherever you are.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial law. If you are in the European Union, the EEA, the United Kingdom, or Switzerland, Section 13 also applies to you. If you are in a US state with a privacy statute, Section 14 also applies to you. Where those sections give you more, they win.

The short version: we collect the minimum needed to run an account and a course. We do not sell or share your personal information, and we run no advertising or third-party analytics trackers. Your section-by-section lesson progress is kept in your browser, but our servers do record which lessons your account opens, your Virtual Teacher score, and how the site is used, and your Virtual Teacher messages are processed by OpenAI — all described below.

1. Information we collect

You give us

• Account information: your email address, and a password (stored only as a cryptographic hash — we never store your password itself).
• Google sign-in: if you sign in with Google, Google sends us your basic profile. We keep only your email address, whether Google has verified it, and a Google account identifier; the name and profile picture Google includes are not stored. We do not receive your Google password.
• Preferences: your chosen course language and narrator voice.
• Messages: anything you send us through the contact form, the chat widget or the in-course "Report an issue" form, including the email address and question you enter there and, for an issue report, the page you were on. These are delivered to us by email.
• Virtual Teacher messages: what you type to the Virtual Teacher. Each message is sent, with the recent conversation, to OpenAI to produce a reply (see Section 4). We do not store the text of your messages on our servers; the conversation is kept only in your browser tab's session storage and is cleared when you close the tab. Please do not type personal information into it.

Created when you use the Service

• Enrollment records: the plan purchased, amount, currency, a payment transaction reference, and the enrollment start and expiry dates.
• Referrals: if you use the referral program, your referral code; and if you signed up through someone's link, a record linking your account to the referrer's. Nothing about a referral is stored on your device, except briefly in the Google sign-in cookie if you sign up with Google. The referrer sees only a count of drivers who enrolled with their link — never your name or email.
• Session data: a session identifier stored as a hashed token, with its expiry.
• Technical logs: standard server logs such as IP address, timestamp, requested URL, and user agent, generated by our hosting and web server and used for security, abuse prevention, and troubleshooting.
• Product events: a first-party record, stored in our own database and tied to your account identifier, of account milestones — an account created, a sign-in, an email verified, a password reset, a checkout started, an enrollment completed (with the plan and amount) or cancelled, a referral bonus credited — and of course activity: each lesson page your account opens, and when; use of lesson audio, the truck diagram and the Virtual Teacher (the feature and language, not what you typed); your language and voice choices; and the category of any issue you report. We use it to count how the Service is being used, to reconcile enrollments, and to protect the course (see Section 9). It is ours alone: it is not a tracking pixel, it is not shared with an analytics vendor, and it does not follow you to other sites.
• Checkout acceptance: each time you start a checkout, the version of the Terms of Use, Privacy Policy and Refund Policy you accepted and when you accepted it; and, at your first checkout, when you confirmed you are 18 or older and whether you opted in to marketing email.
• Virtual Teacher progress: your XP, the number of messages you have sent and answers marked correct, your day streak and best streak, the last day you practised, and the badges you have earned — kept against your account so they follow you between devices.
• Lesson watermark: every lesson page we serve to you carries an invisible identifier linked to your account. It is not read or stored on your device and tells us nothing about you while you study; we use it only to trace a copy of the course found outside the Service back to the account it was served to (Terms of Use, Section 9).
• Account-protection records: if our automated checks lock your account (Section 9), we record the reason and the technical details of the request at that moment — IP address, browser and device headers, your recent lesson opens and your active sessions — and email them to our team so a person can review the lock.
• Site analytics: our own first-party script records how pages are used — the pages you open and in what order, the referring site, any campaign (utm_) tags and any referral code (ref) in the link you followed, where on a page you click and how far you scroll, time on page, lesson sections reached, page-load speed, and script errors — together with your browser, operating system, device type, screen size, language and time zone. It sets no cookie and stores nothing on your device. To tell one visit's page loads apart from another's, our server combines your IP address and user agent with a random value that is replaced every day and kept only in memory, and stores the resulting one-way hash — not your IP address. That hash cannot be reversed, and cannot link your visits across days. If you are signed in, these records are also tied to your account identifier. We never record what you type into forms. The script does not run if your browser sends Do Not Track or Global Privacy Control. We use it to improve the site and the course, and it is not shared with anyone.
• On your own device: your section-by-section lesson progress is stored in your browser's local storage, and that record itself is not sent to us. We do separately know which lessons your account opens (product events above), which lesson sections are reached (site analytics above), and your Virtual Teacher progress. See the Cookie & Storage Policy.

Your microphone

The pronunciation exercises can use the speech-recognition feature built into your browser to compare what you said with the phrase on screen. We ask before the microphone is used for the first time, you can decline and still complete every lesson, and your answer is remembered on your device.

No audio and no transcript ever reaches Road English. The recognition is performed by your browser; in Chrome and Edge the browser uploads the recording to its own servers for transcription, under that vendor's privacy policy and not ours. We create no voiceprint, we do not use voice to identify anyone, and we store no biometric identifier. The scoring runs in your browser and is discarded when you leave the page. More detail is in our AI Disclosure.

What we do not collect

We do not store your full credit card number, CVV, or card expiry — those go directly to our payment processor. We do not run advertising networks, third-party analytics, or tracking pixels on the Service, and we do not build advertising profiles. We do not collect special categories of data (health, biometrics, race, religion, politics, sexual orientation, union membership), government identifiers, precise geolocation, or contact lists. Please do not send us any of those.

2. Why we use it, and our legal basis

We use personal information only for the purposes below. The stated legal basis applies to users covered by the GDPR or UK GDPR (Section 13); for users in Canada and elsewhere, we rely on your consent or on the exceptions permitted by applicable law.

• Create and operate your account, verify your email, keep you signed in. Basis: performance of our contract with you (Art. 6(1)(b)).
• Process payments and determine whether you have access to the course. Basis: performance of our contract (Art. 6(1)(b)).
• Run the referral program: credit bonus access and prevent referral abuse. Basis: performance of our contract (Art. 6(1)(b)) and our legitimate interest in preventing fraud (Art. 6(1)(f)).
• Deliver the Service, including generating lesson audio on request, answering your Virtual Teacher messages, and keeping your Virtual Teacher progress. Basis: performance of our contract (Art. 6(1)(b)).
• Protect the course from scraping and redistribution: the lesson watermark, the record of lesson opens, the sign-in limit, and automatic account locks. Basis: our legitimate interest in protecting our content and the enrollments of paying learners (Art. 6(1)(f)).
• Keep evidence that you accepted the Terms of Use, Privacy Policy and Refund Policy at checkout. Basis: performance of our contract (Art. 6(1)(b)) and our legitimate interest in defending legal claims and chargebacks (Art. 6(1)(f)).
• Send transactional email (verification, account, and support messages). Basis: performance of our contract (Art. 6(1)(b)).
• Send occasional email about new courses and updates — only if you ticked the optional box at your first checkout. Basis: your consent (Art. 6(1)(a)), which you may withdraw at any time. See Section 2a.
• Respond to your enquiries. Basis: our legitimate interest in answering people who write to us (Art. 6(1)(f)), or steps taken at your request before entering a contract (Art. 6(1)(b)).
• Secure the Service, enforce rate limits, prevent fraud and abuse, and debug problems. Basis: our legitimate interest in keeping the Service working and unattacked (Art. 6(1)(f)).
• Establish, exercise, or defend legal claims, including contesting chargebacks. Basis: our legitimate interest in defending ourselves (Art. 6(1)(f)).
• Comply with legal, tax, and accounting obligations. Basis: legal obligation (Art. 6(1)(c)).

We do not sell, rent, or trade your personal information, we do not share it for cross-context behavioural advertising, and we do not use it for third-party advertising. We do not use your personal information to train artificial-intelligence models.

2a. Email we send you

There are two kinds, and the difference matters:

• Account email — verifying your address, confirming an enrollment, answering something you asked us. We send these because you have an account with us; they are part of the Service and there is no way to switch them off while the account is open.
• Anything else — news about a new course or a significant update. We send this only to people who ticked the optional box shown at their first checkout (it is not offered when you create an account), we record when you ticked it, and the box is never pre-ticked. If you did not tick it, we will not send you this kind of email at all.

To stop non-essential email, email [email protected] with Unsubscribe in the subject line, and we will withdraw the consent on record. Every message we send carries our identity and this same address, as Canada's anti-spam legislation and the US CAN-SPAM Act require.

We never sell, rent, or hand your address to anyone else to email you, and we do not send email on behalf of third parties.

3. Consent and withdrawal

Where we rely on consent, you give it by creating an account and using the Service, and you may withdraw it at any time by closing your account (see Section 8). Withdrawal is not retroactive: it does not affect processing already carried out. Withdrawing consent ends your ability to use the Service, and no refund is owed.

Where we rely on legitimate interests, you may object (Section 13), and we will stop unless we have compelling legitimate grounds that override your interests, or we need the information for legal claims.

4. Service providers we share with

We share the minimum personal information necessary with providers who process it on our behalf under written terms that restrict them to our instructions:

• Helcim (Canada) — payment processing. Your card details are submitted directly to Helcim; we keep only a transaction reference, the amount and the payment status.
• Google (United States) — optional sign-in, if you choose it.
• Google (United States) — delivery of our email, which we send through Google's Gmail service: your email address and the content of each message we send you or you send us.
• ElevenLabs (United States) — AI text-to-speech synthesis of course phrases. Lesson text is sent for synthesis; your identity, email, and account data are not. See the AI Disclosure.
• OpenAI (United States) — generates the Virtual Teacher's replies. Purpose: answering your messages about the course. Data sent: your message; up to your last ten messages and replies in that conversation; the course language; and excerpts of our lesson text. Your latest messages are also sent to OpenAI's embeddings service to find the relevant lesson excerpts. We do not send your name, email address, or account identifier — but anything you type into a message reaches OpenAI, so please do not include personal information. Transfer: OpenAI processes this data in the United States, under the safeguards in Section 5 and OpenAI's API terms, which state that API data is not used to train its models by default and may be kept by OpenAI for a limited period to monitor abuse. Our internal lesson editor also uses OpenAI, with lesson content only. See the AI Disclosure.
• DigitalOcean (hosting in Canada; corporate entity in the United States) — hosting and database infrastructure.

These providers are bound by their own agreements and privacy commitments. We are not responsible for the independent practices of any third party.

We may also disclose personal information where required or permitted by law — for example, in response to a lawful request from a court, regulator, or law enforcement — or to establish, exercise, or defend legal claims, or in connection with a merger, acquisition, financing, or sale of all or part of our business (in which case the recipient will be bound by this policy for the transferred information). Where the law permits, we will tell you before responding to a government request for your data.

5. Where information is stored (cross-border transfers)

Our servers and database are located in Canada. Some of our service providers operate in the United States and other countries, so personal information may be transferred to, stored in, or accessed from those countries.

Personal information stored or processed outside your own country is subject to the laws of the country it is in, and may be accessible to that country's courts, law enforcement, and government authorities. No transfer mechanism can fully exclude that.

For transfers out of the EEA, the UK, or Switzerland: Canada holds an adequacy decision from the European Commission for commercial organizations subject to PIPEDA, which covers our own storage of your data. For our onward transfers to providers in the United States, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum, or the Swiss equivalent), together with supplementary measures including encryption in transit and minimizing what is sent. You may request a copy of the relevant safeguards by emailing us.

By using the Service, you acknowledge this transfer and processing.

6. Cookies and local storage

We use a single essential cookie to keep you signed in, plus a short-lived one only while you sign in with Google. It is HttpOnly and expires after 14 days or when you sign out. We also use your browser's local storage to remember your language choice, light or dark theme, and your lesson progress, and your browser tab's session storage to hold the current Virtual Teacher conversation. We do not use advertising or analytics cookies, and we do not need a cookie banner because we set no non-essential storage. Blocking the session cookie will prevent you from signing in. Full detail is in the Cookie & Storage Policy.

7. Retention

We keep information only as long as we need it:

• Account and profile: while your account exists, then deleted or de-identified on request.
• Enrollment and payment records: up to seven years after the transaction, because Canadian tax and accounting law requires it.
• Sessions: expire and are removed after 14 days.
• Server logs: a short rolling window, generally 30 days, unless retained longer for an active security or abuse investigation.
• Site analytics and product events (including the record of lessons opened and account-lock records): deleted automatically after 13 months (395 days). If your account is deleted sooner, product events are de-identified.
• Virtual Teacher progress (XP, streaks, badges): for the life of your account, and deleted when your account is deleted.
• Virtual Teacher messages: not stored on our servers. The conversation stays in your browser tab until you close it; OpenAI's retention is described in Section 4.
• Checkout acceptance records: kept with the checkout they belong to, for the same seven years as payment records.
• Support and contact messages: up to two years, so we can follow up and keep a record of what was asked.
• Records needed for a live or anticipated legal claim: until the claim and any limitation period ends.

When information is no longer needed, we delete or irreversibly de-identify it.

8. Your rights (everyone)

Wherever you are, you may ask us to:

• Access the personal information we hold about you, and know how it has been used and disclosed.
• Correct anything inaccurate or incomplete.
• Delete your account and the personal information associated with it.
• Withdraw consent to our handling of your information.
• Receive a copy of the information you gave us, in a portable, machine-readable format.

Email [email protected] from the address on your account, with Privacy Request in the subject line. We respond within 30 days (or within the shorter period your local law requires). We may need to verify your identity before acting, and we may keep information we are required or permitted by law to keep — for example, payment records within the seven-year window above.

Exercising any of these rights is free, and we will never penalize you, degrade your service, or charge you a different price for exercising them. Deleting your account does not entitle you to any refund, and any remaining enrollment time is forfeited.

9. Automated decision-making

Access to the course is determined by whether a payment succeeded, whether your enrollment term has expired, and two automated protections against scraping and account sharing:

• Sign-in limit. An enrolled account can have at most two sessions active within the last 30 minutes. A further sign-in is refused until one of them signs out or goes idle.
• Automatic account lock. Our systems lock an enrolled account automatically, without a person reviewing it first, when its activity matches automated or bulk copying — for example, opening lessons far faster than a person could read them, loading lessons in an automated or headless browser, or following a link on a lesson page that people cannot see. A locked account cannot open lessons until we unlock it. The lock uses the account-protection records described in Section 1, and our team is alerted to every lock.

How to contest a lock. Email [email protected] from the address on your account with Account Review in the subject line, and tell us anything you want us to consider. A person will review the evidence and your explanation, decide, and tell you the outcome; if the lock was a mistake, we unlock the account. Where the GDPR, UK GDPR or Quebec law applies, this is how you obtain human intervention, express your point of view, and contest the decision.

The Virtual Teacher marks your practice answers right or wrong to award XP and badges. That marking is automated, but it is for motivation only: it never affects your access, what you pay, or any certificate or record outside the Virtual Teacher. We carry out no other profiling or automated decision-making that produces legal or similarly significant effects.

10. Security

We use safeguards appropriate to the sensitivity of the information, including encryption in transit (HTTPS), password hashing, hashed session tokens, gated access to course content, rate limiting, and client-certificate protection of our authoring tools. No method of transmission or storage is completely secure, and we cannot and do not guarantee the security of your information. You are responsible for keeping your own credentials and device secure.

If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the applicable regulator as required by law — including within 72 hours of becoming aware, where the GDPR applies.

11. Children

The Service is intended for adults (18+) and is not directed to children. We do not knowingly collect personal information from children, and we do not knowingly sell or share the personal information of anyone under 16. If you believe a child has provided us information, contact us and we will delete it.

12. Changes to this policy

We may update this policy at any time by posting a revised version with a new "Last updated" date. Changes take effect when posted. Where a change is material and the law requires it, we will notify you by email or in the Service before it takes effect. Your continued use of the Service constitutes acceptance.

13. Additional rights — EU, EEA, UK, and Switzerland (GDPR)

This section applies if you are in the European Union, the European Economic Area, the United Kingdom, or Switzerland. It adds to, and where it conflicts overrides, the rest of this policy.

13.1 Controller and representative

The controller of your personal data is Dextrata Software Inc., a Canadian corporation, reachable at [email protected]. We are not required to appoint a Data Protection Officer under Article 37, and have not appointed one; privacy enquiries go to the address above.

We have not appointed an Article 27 representative in the Union. We rely on the derogation in Article 27(2)(a): our processing of EU residents' data is occasional, does not include special categories of data or criminal-conviction data on any large scale, and is unlikely to result in a risk to the rights and freedoms of individuals. If that ceases to be true, we will appoint a representative and name them here.

13.2 Legal bases

Our legal basis for each purpose is set out in Section 2. Where we rely on legitimate interests (Article 6(1)(f)), we have balanced those interests against your rights, and you may ask us for a summary of that assessment.

13.3 Your rights

Subject to the conditions in the GDPR, you have the right to:

• Access your personal data and receive a copy (Art. 15).
• Rectification of inaccurate or incomplete data (Art. 16).
• Erasure — the "right to be forgotten" (Art. 17).
• Restriction of processing (Art. 18).
• Data portability — a structured, commonly used, machine-readable copy of data you provided, and transmission to another controller where technically feasible (Art. 20).
• Object to processing based on legitimate interests, at any time and on grounds relating to your situation (Art. 21). We will stop unless we demonstrate compelling legitimate grounds that override your interests, or need the data for legal claims. If you object to direct marketing, we stop unconditionally. We send marketing email only to people who opted in (Section 2a).
• Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Art. 22). The only such decision we make is the automatic account lock in Section 9, which is necessary to protect the course you contracted for; you may obtain human intervention, express your point of view, and contest it as described there.
• Withdraw consent at any time, where processing is based on consent (Art. 7(3)).
• Be informed of the safeguards used for international transfers (Art. 46), described in Section 5.

Email [email protected]. We respond within one month, extendable by two further months for complex requests, in which case we will tell you within the first month and explain why. There is no charge, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse and tell you why.

13.4 Complaints to a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU or EEA member state of your habitual residence, place of work, or the place of the alleged infringement (Art. 77). In the United Kingdom this is the Information Commissioner's Office; in Switzerland, the Federal Data Protection and Information Commissioner. We would appreciate the chance to address your concern first, but you are not required to come to us before going to a regulator.

13.5 Statutory or contractual requirement

Providing your email address and either a password or a Google sign-in is a contractual requirement: without them we cannot create an account or give you access to the course. Everything else is optional.

14. Additional rights — United States

This section applies if you are a resident of a US state with a comprehensive consumer privacy law, including California (CCPA as amended by the CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states as their statutes take effect.

14.1 Notice at collection

We collect, and in the twelve months before the date of this policy have collected, the following categories of personal information, for the business purposes listed in Section 2, from you and from your use of the Service:

• Identifiers — email address, account identifier, Google account identifier. Retention: life of your account. IP address. Retention: approximately 30 days in server logs, and 13 months where it is part of an account-lock record; see Section 7.
• Customer records and commercial information — enrollment plan, amount paid, currency, transaction reference, enrollment dates. Retention: seven years.
• Internet or network activity — server log entries: requested URL, timestamp, user agent. Retention: approximately 30 days. Site analytics: pages viewed, referrer, clicks, scroll depth, lesson sections reached, browser and device details, and a daily-rotating visit hash (see Section 1). Product events: lessons your account opens and features it uses, and account-lock records. Retention: 13 months. Virtual Teacher progress. Retention: life of your account.
• Your communications — the content of messages you send us. Retention: up to two years. Messages you send the Virtual Teacher are passed to OpenAI and not stored by us.

We collect no other categories. We do not collect biometric information, precise geolocation, government identifiers, or any category of sensitive personal information, and therefore there is nothing for a "Limit the Use of My Sensitive Personal Information" link to limit.

14.2 We do not sell or share your personal information

We have not sold or shared personal information in the preceding twelve months, and we do not do so now. "Sale" and "sharing" carry their statutory meanings, and "sharing" includes disclosure for cross-context behavioural advertising. We have never done either. We do not sell or share the personal information of minors under 16. Because we do not sell or share, we are not required to provide, and do not provide, a "Do Not Sell or Share My Personal Information" link — there is nothing to opt out of.

We disclose personal information to service providers and contractors for the business purposes in Section 4 only. They are contractually restricted from retaining, using, or disclosing it for any other purpose.

14.3 Your rights

• Right to know the categories and specific pieces of personal information we have collected, the sources, the business purpose, and the categories of third parties to whom we disclose it.
• Right to delete personal information we have collected from you, subject to statutory exceptions (such as completing a transaction, security, and legal compliance).
• Right to correct inaccurate personal information.
• Right to opt out of sale, sharing, and targeted advertising — we do none of these, so this right is satisfied by default.
• Right to limit the use of sensitive personal information — we collect none.
• Right to data portability — a copy in a readily usable format.
• Right to non-discrimination — we will not deny you service, charge a different price, or provide a different quality of service because you exercised a right. We offer no financial incentives for personal information.
• Right to opt out of profiling in furtherance of decisions producing legal or similarly significant effects — we do no such profiling. The automatic account lock in Section 9 is a security measure, and you may contest it there.

14.4 How to exercise them, and how to appeal

Email [email protected] with Privacy Request in the subject line, from the address on your account. We will verify your identity by confirming control of that email address; for a request about specific pieces of information we may ask for additional confirmation. We respond within 45 days, extendable once by a further 45 days where reasonably necessary, in which case we will tell you.

An authorized agent may submit a request on your behalf with written permission signed by you; we may still contact you directly to confirm.

Appeals. If we refuse your request, you may appeal by replying to our decision with Privacy Appeal in the subject line. We will respond in writing within 45 days with our decision and the reasons for it. If we deny the appeal, we will tell you how to complain to your state Attorney General.

14.5 Global Privacy Control

We honour opt-out preference signals such as Global Privacy Control by default, because we never sell, share, or use personal information for targeted advertising in the first place.

14.6 California "Shine the Light"

We do not disclose personal information to third parties for their own direct-marketing purposes, so there is nothing to request under California Civil Code section 1798.83.

15. Additional rights — Quebec

If you are in Quebec, the Act respecting the protection of personal information in the private sector (as amended by Law 25) also applies. The person responsible for the protection of personal information at Dextrata is reachable at [email protected]. In addition to the rights in Section 8, you have the right to data portability in a structured, commonly used technological format; the right to request that we cease disseminating your personal information or de-index it where dissemination contravenes the law or a court order; and the right to be informed of, and to submit observations on, any decision based exclusively on automated processing — the only one we make is the automatic account lock in Section 9, and you may submit observations and ask for it to be reviewed as described there. We conduct privacy impact assessments before transferring personal information outside Quebec, as the Act requires. Complaints may be made to the Commission d'accès à l'information du Québec.

16. Contact and complaints

Privacy questions, requests, or complaints: Dextrata Software Inc., [email protected], subject line Privacy Request.

If you are not satisfied with our response, you may complain to:

• Canada — the Office of the Privacy Commissioner of Canada, or your provincial commissioner.
• Quebec — the Commission d'accès à l'information du Québec.
• EU and EEA — your national data protection supervisory authority.
• United Kingdom — the Information Commissioner's Office.
• Switzerland — the Federal Data Protection and Information Commissioner.
• United States — your state Attorney General.

This policy is written in English. Translations, if any, are provided for convenience; the English version governs.