1. Who we are
The Verbal Dude is operated by GD Test Prep E.I.R.L., a company registered in Lima, Peru ("we", "us"). We run theverbaldude.com and the learning platform at learn.theverbaldude.com (together, the "Services"). We are the data controller for the personal data described here. Contact: hello@theverbaldude.com.
2. Data we collect
- Account data: name, email address, username, password (stored only in hashed form), country, language and timezone.
- Learning data: your answers, essays, spoken responses (audio recordings), scores, progress, practice history and course activity.
- Purchase data: plan, amount, dates and transaction references. Card payments are handled by our payment processors; we never receive or store your full card number.
- Communications: messages you send us and email delivery records.
- Technical data: IP address, browser and device type, log files and cookies needed to run the Services securely.
3. How we use your data
- To create and run your account and give you access to courses and exams.
- To score your writing and speaking responses and generate feedback and reports.
- To show your progress and how your results compare with other students in anonymised, aggregate form.
- To process payments, send receipts and send service emails (password resets, results notifications).
- To keep the Services secure, prevent fraud and fix problems.
- To improve our materials and scoring, using de-identified or aggregate data.
- To send marketing emails only where you have agreed; you can unsubscribe at any time.
4. Automated scoring
Writing and speaking responses are scored automatically by our proprietary scoring system, which combines our own algorithms with specialised language-processing technology operated on our behalf. Scores are estimates of TOEFL iBT performance, are not official ETS scores, and have no legal or similarly significant effect on you. You can ask us to have a person review any score by writing to hello@theverbaldude.com.
5. Voice recordings
We record your spoken responses only to score them and give you feedback. We do not use recordings to identify you, and we do not create voiceprints or any other biometric identifiers. Recordings are deleted automatically 30 days after they are scored. Your scores and written feedback remain in your account.
6. Legal basis
We process your data to perform our contract with you, with your consent (which you can withdraw at any time without affecting prior processing), to comply with legal obligations, and for our legitimate interests in running and securing the Services.
7. Who we share data with
We do not sell your personal data and do not share it for cross-context behavioural advertising. We share data only with service providers that process it on our behalf and under our instructions, such as cloud hosting, scoring and language-processing technology, email delivery and payment processing, and with authorities when the law requires it. Our providers may not use your data for their own purposes, including training their own models.
8. International transfers
Our Services are hosted on servers in the United States, and some providers may process data in other countries. When your data is transferred outside Peru or your own country, we use providers that offer adequate protection, in line with Law No. 29733 (Peru's Personal Data Protection Law) and its Regulation.
9. How long we keep data
- Voice recordings: 30 days after scoring.
- Account and learning data: while your account is active, and up to 12 months after it is closed, unless you ask us to delete it sooner.
- Purchase records: as long as tax and accounting laws require.
- Server logs and backups: up to 30 days, as part of normal rotation.
10. Your rights
Under Law No. 29733 you can exercise your rights of access, rectification, cancellation (deletion) and opposition (ARCO rights), as well as the right to information and the right not to be subject to decisions based solely on automated processing. Depending on where you live, you may have similar rights under local law, including data portability and the right to restrict processing. To exercise any right, email hello@theverbaldude.com from the address on your account; we will verify your identity and respond within the time limits set by law. If you are not satisfied with our response, you can file a complaint with Peru's National Authority for Personal Data Protection (Autoridad Nacional de Protección de Datos Personales) or with the data protection authority in your country.
11. US state privacy rights
If you live in a US state with a consumer privacy law, you may request access, correction or deletion of your personal data, and you may opt out of the sale or sharing of your personal data. We do not sell or share personal data as those laws define it. You can still send an opt-out request through our Do Not Sell or Share My Data page or by writing to hello@theverbaldude.com. We will not discriminate against you for exercising these rights.
12. Cookies
We use cookies that are strictly necessary to sign you in and keep your session secure. On theverbaldude.com we also use analytics and advertising-measurement cookies to understand how visitors use the site and measure our campaigns. You can block or delete non-essential cookies in your browser settings without affecting your access to the learning platform.
13. Security
We protect your data with encryption in transit (HTTPS), hashed passwords, access controls, restricted administrative access, monitoring and regular backups. No system is completely secure; if a breach affects your data, we will notify you and the authorities as the law requires.
14. Children
The Services are intended for people aged 14 and over. If you are under 14, you may use the Services only with the consent of a parent or legal guardian. If we learn that we collected data from a child under 14 without that consent, we will delete it.
15. Changes to this policy
We may update this policy. We will post the new version here with a new "Last updated" date and, for material changes, notify registered users by email or on the platform.