Privacy Policy

1. Privacy in short

• What we need: an email address, a password, your country and your tick in the sign-up box (section 5.5). Everything else is optional.
• AI: when you use AI feedback or the AI Coach, your writing, Speaking transcripts and some study details are sent to our external AI provider, outside the UK, but never your name or email address (section 6).
• Your rights: you can download, correct or delete your information, and complain to us or to the ICO. See sections 11 and 12.

2. Who we are and how to contact us

Ruebex is a trading name of Optamix Tech Ltd, a private limited company registered in England and Wales (company number 17202050). Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom. Email: info@ruebex.com. If you write by post, mark the envelope "Privacy".

Optamix Tech Ltd is the controller of your personal information under UK data protection law: the UK GDPR and the Data Protection Act 2018. We are not legally required to appoint a Data Protection Officer, and we have not appointed one. Our team answers privacy questions at info@ruebex.com.

3. The information we collect

3.1 Information you give us

Please keep sensitive details, and details about other people, out of your answers, chats and posts. Anything you type is saved and may be sent to our AI service (section 6).

3.2 Information created when you use Ruebex

Marks, results and progress; AI feedback and Coach replies; review topics; XP, streaks and leaderboard totals; use of hints and model answers; allowance use and Plus status; and practice timings and device type.

3.3 Information from your device and our systems

• Cookies and browser storage (section 14).
• Sign-in records: sign-in and last-active times, a random browser ID and a device label such as "Chrome on Windows", for security, device limits (1 device on the free plan, 2 on Plus) and your list of signed-in devices.
• Scrambled IP addresses: our database stores only a keyed hash of your IP address. We still treat it as personal information.
• Security and activity log: important account and moderation actions, such as sign-in, password changes and deletion requests.
• Server logs: our hosting provider records the full IP address, browser type, page and time of each visit.

3.4 Information from others

If you sign in with Google, Google gives us your name, email address and Google account ID. Our payment processor tells us about payments, subscription status, refunds and disputes. Other learners may report or mention you in Community, and our moderators record their decisions. Our AI services produce the feedback and Coach replies saved to your account.

4. Do you have to give us your information?

To create an account you must give an email address and a password (or sign in with Google), tell us your country and tick the sign-up box (and the 18+ box, where it applies). To buy Ruebex Plus you must tick the checkout box and give our payment processor your payment details. Without these, we cannot give you an account or Plus. Everything else is optional: leaving it out only makes the related feature less personal or unavailable.

5. How we use your information and why the law allows it

We rely on four lawful bases: contract (to provide the service under our Terms), legitimate interests (a genuine reason that your rights and interests do not outweigh, section 5.2), consent (which you can withdraw at any time) and legal obligation.

5.1 Purposes and lawful bases

5.2 Our legitimate interests

Our legitimate interests are keeping Ruebex secure and reliable, keeping Community safe, controlling AI costs, improving AI feedback from reports you send, proving what was agreed, legal claims and a sale of the business. In balancing them, we took into account that many learners are under 18. You can object to these uses (section 11).

5.3 Consent and choices you can change

At any time, you can switch off photo sharing or clear optional profile details in your profile, leave the leaderboard, withdraw your learner review in My review, or keep Speaking recordings on your device (section 6.8). For AI processing, see section 5.5. Withdrawing consent does not make what we did before unlawful.

5.4 Selling and advertising

We do not sell your personal information or use it for advertising or marketing profiles.

5.5 The sign-up box

To create an account, you tick one box (never ticked in advance):

☐ I agree to the Terms of Service and Privacy Policy

By ticking it, you:

1. accept our Terms of Service, including the Community Rules and the Subscription, cancellation and refund policy;
2. confirm that you have read this policy;
3. confirm that you meet our age rule: you are 13 or older and, if you are under 18, your parent or guardian has agreed to you using Ruebex;
4. agree to AI processing: your practice answers, AI Coach messages and study details are sent to our external AI provider, which passes them to AI model hosts that work under zero data retention, to produce AI feedback (section 6);
5. agree to Speaking recordings and transcripts: your Speaking recordings are saved privately to your account for 30 days and turned into transcripts by a speech-to-text host (section 6.8). You can choose "Keep them on this device" on the Speaking page at any time instead.

Your data is therefore processed outside the UK and outside your own country, with the safeguards in section 9.

The record we keep. We record which wording you ticked, the version of our Terms and of this policy, the date and time, your country, the page language and a scrambled IP address (removed after 12 months).

What makes our use lawful. Under UK law, the box is not our lawful basis: we rely on section 5.1 and, for transfers, section 9. Where the law where you live relies on consent, ticking the box is your consent under that law, including to processing outside your country.

A higher minimum age. If the law where you live sets a higher minimum age (for example, by requiring a parent's consent for under-18s, which Ruebex does not collect), you must meet it, and you also tick "I am 18 or older." If we learn that an account belongs to someone below the minimum age that applies where they live, we close it within 7 days and refund any Ruebex Plus.

Older accounts. Accounts made before the current box see it at their next sign-in, with AI features off until it is ticked. An earlier wording you already ticked still counts. If you don't agree, you can stop using Ruebex: download your data and ask us to delete your account in Profile and settings → Your data (section 10.1).

Withdrawing consent. You can withdraw your agreement to AI processing at any time by writing to info@ruebex.com. AI cannot be switched off for a single account, so we will then close your account.

6. AI in Ruebex

6.1 When we use AI

We use AI for feedback when you ask for it, for the AI Coach and translations, and to transcribe Speaking recordings saved to your account (section 6.8).

6.2 What we send to the AI service

6.3 What we never send

We never send your name, email address, account number, photo, age, bio or IP address to an AI service. But the AI receives whatever you write or say, so do not include private details such as your address, school, phone number or passwords.

6.4 Who provides the AI, and where

All AI in Ruebex goes through one external AI provider, under a written data protection agreement with us. It passes each request to a host that we allow and that, according to our AI provider, works under zero data retention: the host keeps nothing after answering. The hosts are our AI provider's sub-processors. Your answers, recordings and chats are not used to train AI models.

• Text AI: our AI provider passes every request to one approved model host only. If that host is unavailable, text AI features pause.
• Speech-to-text: our server sends each recording, and nothing else about you, to our AI provider, which passes it to one approved speech-to-text host, or, if the main model is unavailable, to a backup model on an approved host.
• Where: the provider and hosts are outside the UK and may process data in several countries (section 9). They may change to other hosts we allow, under the same rules.

6.5 What happens to the AI's answer

We save feedback and Coach replies in your account, with the name of the AI model used. We also keep an AI usage record to control costs (section 10).

6.6 Automated decisions, scores and personalisation

• No automated decisions with legal or similarly significant effects. AI feedback is study guidance only.
• Not an official score. AI feedback is never an official IELTS band score, and Ruebex is not connected to the official IELTS test. Writing feedback gives no band. Official IELTS Writing is marked by trained human examiners. For Speaking, the AI gives an estimated band for fluency and coherence, vocabulary, and grammar, labelled "practice estimate, not an official IELTS score". It can be wrong, and pronunciation gets tips only.
• Example answers written by the AI are teaching examples, not guaranteed to reach Band 9 or any other band.
• Personalisation (profiling): we use your goals and results to suggest a study plan and review topics and to give the Coach background. It is not used for marketing.

6.7 AI can be wrong: your controls

• AI can make mistakes. Check its advice against official sources.
• Ruebex AI Coach is a computer program, not a person or a teacher. It is only for study help. If you feel unsafe, upset or worried, talk to an adult you trust or call your local emergency number.
• Use "Does this feedback look wrong?", "Report this feedback" or "Report this reply" to tell us about wrong or harmful AI text. A person on the Ruebex team reads every report.

6.8 Speaking

1. Saved to your account by default. Each answer you record is kept privately in your account so you can play it back; only you can open it. It is also sent for a transcript (section 6.4).
2. Or keep them on this device. On the Speaking page you can choose "Keep them on this device instead" at any time. From then on, nothing is uploaded: new recordings stay in your browser until you leave the page, with no transcript or AI feedback. You can switch back at any time.
3. AI feedback reads your transcripts, not your voice.
4. How long we keep it. Each recording is deleted 30 days after you make it, or sooner if you delete the practice session. Switching to your device does not delete recordings already saved. Transcripts, notes and feedback stay with the session until you delete it or your account is deleted.

Speaking recordings are personal data. We do not use your voice to identify you.

7. Who can see your information

• Other signed-in learners: your display name, Community posts, replies and reactions; your photo only if you switch on photo sharing; your leaderboard name, city and monthly XP only if you join.
• Anyone on the internet: only a learner review you chose to publish, after our team approves it (your public name, the text and, if you agreed, your selfie).
• Our team: what it needs to moderate Community, answer support and run the service.
• Our service providers: only what each needs (section 8).

8. Who we share your information with

8.1 Service providers who work for us

Our hosting provider, AI provider and payment processor act on our instructions under written contracts (UK GDPR Article 28). The AI hosts are our AI provider's sub-processors.

Our payment processor is also responsible for its own use of payment information, such as fraud prevention, under its own privacy notice. If you sign in with Google, Google runs that sign-in under its own privacy policy.

You can ask us at info@ruebex.com for the names of the service providers we use today.

8.2 Other people we may share information with

• Police, the National Crime Agency, courts, regulators (such as the ICO or Ofcom) and tax authorities, when the law requires it or to protect someone from serious harm.
• Professional advisers, such as accountants and lawyers, under confidentiality.
• A buyer or new owner of our business, who must keep to this policy.

9. Sending information to other countries

We are based in the United Kingdom. Some of our service providers process data outside the UK: our AI provider and its model hosts, our payment processor, and possibly our hosting provider. When they do, we use the safeguards UK law requires:

• UK adequacy regulations: UK regulations approve transfers to that country, or to a certification scheme the provider belongs to (UK GDPR Article 45A); or
• a UK transfer contract: the UK International Data Transfer Agreement (IDTA), or the UK International Data Transfer Addendum (the "UK Addendum") to standard contractual clauses.

For the AI hosts, these safeguards are in our AI provider's contracts with them. You can ask us for a copy at info@ruebex.com.

10. How long we keep your information

We keep personal information only as long as we need it. If it is needed for an open complaint, appeal, payment dispute, regulator or police enquiry, or legal claim, we keep it until that matter is closed.

Safety hold. If Community content may be evidence of a crime, or has been reported to the police or the National Crime Agency (NCA), we keep it, visible only to our team, even if you delete it or your account. For child sexual abuse content we report to the NCA, the law requires us to keep the content, our report and related account information from the 2 weeks before it was posted for 1 year from the report, and the NCA's reference number for 5 years. We keep anything longer only if the police or the NCA ask us to.

10.1 When you delete your account

Ask in Profile and settings → Your data → Delete your account, or email info@ruebex.com. We complete the deletion within one month of your request and tell you when it is done. If someone has reported something you posted and we have not finished reviewing it, the deletion may wait briefly until we have. If you cancel your request, we delete any note you added after 90 days.

Ruebex Plus. A deletion request ends Plus. We cancel it within 7 days and refund the unused part of the period you have paid for, pro rata, as our Subscription, cancellation and refund policy explains. If you would rather keep Plus until the paid period ends, tell us in writing; we then delete your account when Plus ends, with no refund.

After deletion we keep only what the table above says outlasts an account: proof, security, moderation, safety-hold and payment records, AI usage records without your account number, and backups until they expire.

11. Your rights

How to make a request: email info@ruebex.com, use Contact us in the app, or write to the address in section 2. We reply within one month, or up to two months more for complex or several requests (we tell you within the first month). If we need to check your identity or ask what you mean, the time runs from your reply. Requests are free unless clearly unfounded or excessive. Some rights have limits, for example payment records we must keep for tax law; we will explain if we cannot do what you ask.

Parents and guardians with authority can make a request for a learner. Learners aged 13 and over can usually make their own.

12. Complaints

12.1 Complain to us first

Use Contact us in the app (choose "Privacy complaint") or email info@ruebex.com. We confirm your complaint within 30 days (we usually do this within 24 hours), look into it without undue delay, keep you updated and tell you the outcome.

12.2 Complain to a regulator

You can complain at any time to the UK regulator, the Information Commission, formerly the Information Commissioner's Office (ICO). It usually expects you to come to us first:

• Online: ico.org.uk/make-a-complaint
• Phone: 0303 123 1113
• Post: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom

If you live outside the UK, you can also complain to the regulator where you live, or go to court there.

13. Children and teenagers

• Minimum age 13. If we learn that an account belongs to someone under 13, we delete it. Parents who think their child under 13 has an account should contact us.
• Under 18: you need your parent's or guardian's agreement (section 5.5), and a parent or guardian must buy Ruebex Plus. Our short guide for young learners explains the main points.
• Private by default, for everyone, with the UK Children's Code in mind: profiles are private; photo sharing and the leaderboard are off until you switch them on; there are no private messages; and Community is visible only to signed-in learners and is moderated.
• Community includes adults. Never share your full name, address, school, phone number or social media there.
• Higher ages in some countries: where local law requires a parent's permission for consent until a higher age (for example 16), ask a parent or guardian before you join the leaderboard, share your photo or publish a review.

14. Cookies and browser storage

Ruebex uses only four essential cookies:

Your browser also keeps unsent work, display settings and a few records of your choices. We use no analytics, advertising or tracking, so there is no cookie banner. Full list: Cookie notice.

15. How we keep your information safe

We use security measures suited to the risks, such as encryption, hashed passwords and restricted admin access. If a breach puts you at high risk, we will tell you without undue delay.

16. Our social media channels

If you message us or join our channels on social media platforms, we see your public profile and messages and use them to reply and to moderate the channel (legitimate interests), keeping any copies as long as support messages (section 10). The platform's own privacy policy applies to what you do there.

17. Changes to this policy

Each version has a version number and date. We tell you about important changes in the app or by email before they take effect, and ask for your agreement where it is needed (section 5.5). You can ask us for earlier versions.

18. Contact us

Email info@ruebex.com, or write to us at the address in section 2. Nothing in this policy limits the rights you have under the law where you live.