Privacy Policy

1. Introduction

Gurully Technologies LLP (“Gurully”, “we”, “our”, “us”) is an AI-powered language test preparation platform providing practice materials, mock tests, analytics, and learning tools for PTE, IELTS, CELPIP, and Duolingo English Test.

This Privacy Policy explains how we collect, use, store, protect, and share your personal data when you access or use our website, mobile site, and related tools (“Platform”).

By using Gurully, you agree to the practices described in this Privacy Policy.

2. Definitions

  • Personal Data: Any data that identifies or relates to an individual.
  • Sensitive Personal Data: Payment-related data, audio responses, and biometric-like voice samples used for AI scoring.
  • User: Any person accessing or registering on the Platform.
  • Processing: Collecting, storing, modifying, analyzing, or deleting data.
  • AI Systems: Automated systems that evaluate user responses and generate scores.

3. Information We Collect

We collect only the information strictly necessary to provide our services.

3.1 Information Provided Directly by You

  • Full Name
  • Email Address
  • Phone Number
  • Country / City / Location
  • Password (encrypted)
  • User-generated content: answers, responses, mock test attempts, writing & speaking samples
  • Audio recordings submitted during speaking modules
  • Performance data: scores, analytics, improvement tracking
  • Support queries and communication history

3.2 Information Collected During Payments

Processed via Razorpay, Stripe, PayPal, or PayTM:

  • Payment transaction ID
  • Payment method
  • Billing details

We do NOT store complete card numbers, UPI PINs, CVV, or sensitive payment credentials.

3.3 Information We Do NOT Collect

Gurully does not collect or store:

  • Device information (OS, browser type, IP address)
  • Cookies for device fingerprinting
  • Biometric face scans or video data

4. Cookies & Tracking Technologies

We use cookies strictly for essential and functional purposes.

4.1 Types of Cookies Used

  • Login Session Cookies — to keep you logged in securely
  • Analytics Cookies — Google Analytics, Google Tag Manager
  • Advertising Cookies — Google Ads & Meta Pixel for remarketing
  • Preference Cookies — remembering settings like language or mode

You may disable cookies through browser settings; however, some features may stop working.

5. How We Use Your Data

Your data is used for enabling educational services and platform functionality:

5.1 Service Delivery

  • Creating and managing your account
  • Providing access to mock tests, practice modules, analytics
  • Delivering AI-generated scoring and evaluation
  • Tracking your performance progress
  • Personalized recommendations

5.2 Communication

  • Important account or subscription updates
  • Support interactions
  • Transactional messages
  • Marketing emails (optional; users can opt out)

5.3 Payments & Billing

  • Processing transactions via third-party gateways
  • Fraud detection (via payment partners)

5.4 Platform Optimization

  • Improving content quality
  • Enhancing user experience
  • Ensuring platform security

6. How AI Processes Your Data

Gurully uses AI algorithms to evaluate speaking, writing, reading, and listening responses.

AI Processing Includes:

  • Analyzing grammar, fluency, pronunciation, coherence
  • Converting audio responses to text
  • Generating predictive scoring aligned with real test standards
  • Offering improvement insights

AI Limitations

  • AI scoring is not identical to official exam scoring.
  • AI results should be used only for practice and preparation.
  • AI does not make academic, employment, or visa decisions.

7. Data Retention Policy

As provided by you:

✔ We retain user data until the user deletes their account.

Important Note:

Under Gurully’s Terms:

  • Accounts cannot be deleted after a free mock test attempt or any package purchase.
  • Names cannot be changed once entered during signup.

Therefore:

  • All other users’ data is retained for continuity of educational services and compliance.

8. Children’s Privacy

We allow users 16 years or older to create an account.

Users under 16 may use the platform only with parental or guardian consent.

We do not knowingly collect data from children without consent.

9. International Data Transfers

Since we serve users from India, Nepal, Pakistan, Bangladesh, Australia, Canada, and other regions:

  • Data may be processed on secure servers located inside India and abroad.
  • Transfers are done only to providers compliant with GDPR, DPDP Act, and global security standards.

10. Data Sharing Policy

We strictly do NOT sell, rent, or share personal data with:

  • Affiliate partners
  • Coaching institutes
  • External marketers
  • Advertisers

We only share data with:

  • Service providers required for platform functionality:
    • Razorpay / Stripe / PayPal / PayTM (payments)
    • Google Analytics & Tag Manager
    • Meta Pixel
    • Zoho
    • Brevo (Sendinblue) for emails

All service providers follow strict confidentiality and data protection agreements.

11. Data Security Measures

We implement multiple levels of protection:

  • AES-256 encryption
  • Encrypted passwords
  • Secure payment gateways compliant with PCI-DSS
  • Firewall & intrusion detection
  • Limited employee access control
  • Regular malware and vulnerability scans
  • Encrypted audio and answer files

However, no digital platform is 100% immune to cyber threats.

12. User Rights

Depending on your location (India/GDPR), you may have rights such as:

  • Access your data
  • Correct inaccurate data
  • Request deletion (only if eligible under our deletion policy)
  • Opt-out of marketing
  • Request information on processing

Requests can be made by emailing: support@gurully.com

13. Account Deletion Policy (Reconfirmed)

  • If you have given a free mock test OR purchased any package, account deletion is not possible.
  • If you have never attempted a test or made a payment, you may request account deletion.
  • Once deleted, access to all test history, performance analytics, and recordings will be permanently lost.

14. White-label & Partner Panel Terms

For partners who use white-label or institute panels:

  • Partner data is stored separately
  • Student data belongs solely to Gurully, not the partner
  • Partners must not export, resell, or misuse student information
  • White-label usage remains under Gurully’s full legal ownership

15. Marketing Communications

We send marketing messages via Brevo (Sendinblue).

Users may opt out anytime through:

Transactional emails (payments, OTPs, updates) cannot be unsubscribed.

16. Grievance Officer (Under IT Rules 2021)

Name: Gurully Support
Email: support@gurully.com
Office: Ahmedabad, Gujarat

17. Changes to This Privacy Policy

Gurully may update this Privacy Policy periodically.

Changes will be posted on this page with a revised “Last Updated” date.

Continued use of the platform means acceptance of the updated policy.

18. Contact Us

For questions or concerns regarding this Privacy Policy:

  • Email: support@gurully.com
  • Phone: +91-9512040070
  • Address: Atlantis One Sagar Sangeet Cross Road, 407–409, Science City Rd, Sola, Ahmedabad, Gujarat 380060

By using Gurully, you acknowledge that you have read, understood, and agreed to this Privacy Policy.