Privacy Policy & Voice Data Governance

1. Scope & Overview

This Privacy Policy governs the processing of personal information, microphone audio waveforms, acoustic metrics, and telemetry data collected by the Trio English Proficiency Assessment Platform ("Trio", "we", "us", or "our").

We provide AI-powered standardized English language evaluations for enterprise recruitment, academic institutions, and assessment teams. We maintain strict security protocols to safeguard candidate privacy and institutional data integrity.

2. Data We Collect

When you take an English assessment or manage candidate evaluations, we process:

• Candidate Identification: Full Name, Email Address, Candidate ID, Application Number, and assessment invitation tokens.
• Audio & Voice Submissions: Real-time microphone audio recordings of spoken answers to speaking prompts and phoneme exercises.
• Assessment Responses: Multiple-choice selections, reading comprehension inputs, grammar fill-in answers, and listening exercise answers.
• Technical & Proctoring Telemetry: Browser metadata, operating system, audio input device identifiers, timestamp logs, tab-visibility status, window focus transitions, and copy-paste prevention logs.

3. Audio & Speech Processing (AI Analysis)

Microphone audio collected during speaking sections is analyzed by our automated AI scoring pipeline to calculate:

• Words-Per-Minute (WPM) speech tempo and pause duration ratios
• Phoneme pronunciation accuracy against phonetic standards
• Intonation patterns, pitch cadence, and speech fluency index
• Lexical vocabulary diversity and syntax coherence

4. Anti-Cheat & Proctoring Telemetry

To ensure institutional fairness and test integrity, our client-side software monitors examination activity during active sessions:

• Tab & Focus Loss Detection: Notifies our system when an exam tab loses focus or when a secondary application is opened.
• Audio Anomaly Monitoring: Detects background interference or multi-speaker voice signals during speech exercises.
• Integrity Audit Logs: All telemetry events are compiled into an objective integrity report accessible only to authorized institutional administrators.

5. Legal Basis for Processing

We process personal and assessment data under the following lawful bases:

• Consent: Explicit candidate consent provided before initiating the microphone hardware check and exam start.
• Legitimate Interests: Fulfilling hiring or academic evaluation requests from the sponsoring enterprise or university.
• Contractual Obligation: Delivering secure, certified CEFR score reports to the enterprise customer.

6. Storage, Encryption & Retention Schedule

We enforce strict data life cycle management:

• In-Transit Security: All data transmissions are encrypted using Transport Layer Security (TLS 1.3 / HTTPS).
• At-Rest Security: Candidate records, database entries, and audio artifacts are encrypted using AES-256 standards.
• Retention Schedule: Candidate audio recordings are retained for 90 days by default (or according to the enterprise client's customized retention SLA), after which audio files are securely purged. Composite scorecards remain accessible for audit verification.

7. Candidate Rights (GDPR / CCPA / Global)

Candidates residing in the European Union (GDPR), United Kingdom (UK-GDPR), California (CCPA), and other applicable jurisdictions maintain the following rights:

• Right to Access: Request a copy of your score report and recorded assessment data.
• Right to Rectification: Request correction of inaccurate candidate identity records.
• Right to Erasure (Right to be Forgotten): Request the permanent deletion of your voice submissions and telemetry logs, subject to statutory retention requirements.
• Right to Human Review: Request human evaluation of automated AI assessment scores where permitted by your evaluating organization.

8. Multi-Tenant Separation & Governance

Each enterprise account operates in an isolated data tenant. Recruiter administrators from Organization A have zero visibility or access to candidates, test records, or audio files belonging to Organization B.

9. Contact & Inquiries

If you have questions regarding this Privacy Policy, wish to exercise your data subject rights, or require information regarding institutional data processing agreements, please contact: