Privacy Policy

PractiseNow (practisenow.com) is owned and operated by Comingwave (comingwave.com.au), Sydney, NSW, Australia. In this policy, “we”, “us” and “our” mean Comingwave trading as PractiseNow.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy explains what personal information we collect when you use PractiseNow, why we collect it, how we use, share and protect it, and the choices and rights you have.

If you have a question about this policy or about your personal information, email us at support@practisenow.com (see our contact page). We are based in Sydney, NSW, Australia.

We only collect the information we need to run PractiseNow. Depending on how you use the service, this includes:

Account details

Your name, email address and password when you sign up with email. If you sign in with Google, we receive your name, email address and a Google account identifier from Google; we never see your Google password. Passwords are handled by Firebase Authentication and we do not see them either.

Your test and goals

The test you choose to practise for (IELTS Academic, IELTS General Training, PTE Academic, PTE Core or OET), your OET profession (nursing or medicine) if you choose OET, your target score and your test date.

Your practice work

Your answers to practice questions, your written responses (essays, letters and other writing tasks) and your speaking recordings, together with your attempt history (which tasks you tried, when, and how long you took).

Scores and AI feedback

The scores, estimated bands and feedback produced when your work is marked, including feedback produced by AI.

Credits and passes

Your AI credit balance, the passes and top-ups you hold, when they started and when they expire.

Payment records

Payments are sold and processed by Red Migration FZC (United Arab Emirates) through Stripe. When you buy, we keep a record of the purchase: the product, amount, currency, date, your account email and Stripe’s payment references. Your card details are entered on Stripe’s payment page and handled by Stripe; PractiseNow never sees or stores your card number.

Device, browser and usage data

Like most websites, our servers automatically record technical information when you use PractiseNow, such as your IP address, browser type, device type, the pages you request, the date and time of each request, and error information. This is kept in server logs.

Analytics

We use Google Analytics 4 (Google LLC) and Microsoft Clarity (Microsoft Corporation) to understand how visitors use PractiseNow: which pages are viewed, how far a page is scrolled, which buttons and links are clicked, and the device, browser and country of a visit. Google Analytics also records when a purchase is started or completed, without the amount. Both services use cookies and similar technologies.

Microsoft Clarity also records clicks, scrolling and mouse movement as heatmaps and session replays; text typed into form fields is masked. Clarity runs only on our public pages, such as the home page, the test pages, the blog and the help and legal pages. It never runs inside practice tests or mock tests, on results pages, on your dashboard or in your account area, and it does not run on the sign-in or pricing pages. Microsoft may also use this data for advertising, as described in the Microsoft Privacy Statement.

We do not send your name, your email address, your practice answers or recordings, or the content of your forms to either service, and the advertising features of Google Analytics are switched off. More information: Google’s privacy policy, the Google Analytics opt-out add-on and the Microsoft Privacy Statement.

Cookies and device storage

We use one essential cookie, called __session, which keeps you signed in. It is marked httpOnly, which means scripts running in the page cannot read it.

The analytics services described above set these cookies:

• _ga and _ga_<ID> (Google Analytics): kept for up to 2 years.
• _clck (Microsoft Clarity): kept for 1 year.
• _clsk (Microsoft Clarity): kept for 1 day.
• CLID and MUID (Microsoft): kept for 1 year.

Separately from cookies, the site may save drafts of your written answers in your browser’s local storage on your own device, so you do not lose your work if the page reloads. These drafts stay on your device; you can remove them by clearing your browser’s site data.

We do not ask for sensitive information (such as health information, racial or ethnic origin, or religious beliefs). Please do not include sensitive information about yourself or anyone else in your practice answers or recordings.

• From you, when you create an account, set up your test and goals, practise, record your voice, buy a pass or top-up, or contact us.
• Automatically, when you use the site: our servers record device, browser and usage data, the sign-in cookie keeps your session, and the analytics services described in section 2 record how the site is used.
• From Google sign-in, if you choose to sign in with Google: Google shares your name, email address and account identifier with us.
• From our payment provider, Stripe, which tells us whether a payment succeeded and gives us the purchase record described above.

If an organisation (such as a migration agent, school or institute) gives you a seat on PractiseNow, that organisation may give us your name and email address so that the seat can be assigned to you.

You can browse our public pages without giving us personal information. You cannot practise or save work without an account, because we need it to store your attempts and results.

We use your personal information to:

• provide practice tasks for the test you chose, at the right level, and save your progress;
• mark your work: listening and reading answers are marked by our code, and written answers and speaking recordings are marked with AI to give you feedback;
• create, run and secure your account, including signing you in;
• manage your credits, passes and top-ups, and keep records of purchases;
• answer your questions and provide support;
• keep PractiseNow secure, prevent fraud and misuse, and fix errors;
• improve our practice content and the service, for example by finding questions that are unclear or tasks that cause errors, and by measuring which pages are used;
• send you service emails (about your account, security and receipts) and, only if you agree, marketing emails;
• meet our legal obligations, such as tax and record-keeping laws, and respond to lawful requests.

We do not use your personal information for any other purpose unless you agree or the law allows or requires it.

When you submit a written answer or a speaking recording for AI marking, we send it (together with the task instructions) to Google’s Gemini API, which produces the feedback and estimated score you see on your results page.

• Your work is sent only to mark it and give you feedback.
• We do not sell your work or your feedback.
• We do not use your work or your feedback to build advertising profiles.
• Listening and reading tasks are marked by our own code and are not sent to an AI service.

AI feedback is produced automatically and can contain mistakes. Scores and bands are practice estimates only. They are not official results and do not predict or guarantee the result you will receive in a real test.

We share personal information only with the service providers who help us run PractiseNow, and only as far as they need it to provide their service to us:

• Google Firebase and Google Cloud host the website and store your account and practice data (App Hosting, Cloud Firestore, Cloud Storage and Firebase Authentication).
• Google Gemini API marks written answers and speaking recordings, as described in section 5.
• Red Migration FZC (United Arab Emirates) sells and processes PractiseNow payments. It receives your purchase details (your name, email address, what you bought and the amount) to process the payment, issue refunds and keep its payment and tax records.
• Stripe processes the payment for Red Migration FZC. Stripe collects and handles your card details under its own privacy policy; they are never stored by PractiseNow.
• Google Analytics (Google LLC) and Microsoft Clarity (Microsoft Corporation) receive the usage information described under “Analytics” in section 2. They do not receive your name, email address, practice work or card details.

Organisations that provide your seat. If you use a seat provided by an organisation (for example a migration agent, school or institute), that organisation can see your progress on PractiseNow, such as the tasks you have completed and your scores. Organisations cannot see the practice of learners who do not use a seat they provide.

When the law requires it. We may disclose personal information if we are required or authorised to by law, for example in response to a court order or a lawful request from a government agency, or where it is reasonably necessary to protect someone’s safety.

We never sell your personal information, and we do not share your account details, practice work, scores or payment records with advertisers. The only information that may be used for advertising is the usage information Microsoft Clarity collects on our public pages, which Microsoft may use as described in the Microsoft Privacy Statement.

Your personal information is stored and processed outside Australia. Our data is held by Google in the United States: our Cloud Firestore database is in Google’s nam5 multi-region in the United States, and Cloud Storage (where speaking recordings are kept) and website hosting are in Google’s us-central1 region in the United States. Work sent for AI marking is processed by Google’s Gemini API, which may process it in the United States or other countries where Google operates. Purchase details are disclosed to Red Migration FZC in the United Arab Emirates, and Stripe may process payment information in the United States and other countries where it operates. Google Analytics and Microsoft Clarity process usage information in the United States and other countries where Google and Microsoft operate.

Before disclosing personal information overseas, we take reasonable steps, as required by Australian Privacy Principle 8, to make sure the recipient handles it in a way that is consistent with the Australian Privacy Principles. We do this by choosing established providers that are bound by contractual data protection and security commitments.

How we protect your information

• All connections to PractiseNow are encrypted in transit (HTTPS).
• Access to our systems and data is limited to the people who need it to run the service, and protected by access controls.
• Our database and storage rules deny access by default: you can reach only your own data, and everything else is blocked unless a rule specifically allows it.
• Our providers store data in secure data centres and encrypt it at rest.

No system is perfectly secure, but we take reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, change or disclosure.

How long we keep it

• Your account is kept while it is active. If you ask us to delete your account, we delete it, together with your practice data, within 30 days of your request.
• Speaking recordings are deleted 12 months after they are made, or when your account is deleted if that is earlier.
• Written answers, scores and feedback are kept while your account is open.
• Inactive accounts: if you have not used your account for 3 years, we email you a warning and then delete the account.
• Payment and tax records are kept for 7 years, as required by Australian tax law.
• Backups are overwritten within 35 days, so deleted information disappears from backups within that time.

You have the right to:

• access the personal information we hold about you;
• correct personal information that is wrong, out of date or incomplete (you can also change your test, target score and test date yourself on your account page);
• delete your account and practice data;
• withdraw your consent to marketing emails at any time.

To make a request, email support@practisenow.com from the email address on your account (or quote it in your email). To protect your information, we may need to check your identity before we act on a request. We will respond within 30 days.

We do not charge for making a request. If we refuse a request, for example because the law requires us to keep a record, we will tell you why in writing and how you can complain.

PractiseNow is for people aged 16 and over. If you are under 18, you may use PractiseNow only with the permission of a parent or guardian. We do not knowingly collect personal information from children under 16. If you believe a child under 16 has created an account, please contact us at support@practisenow.com and we will delete it.

We send marketing emails (for example study tips, new content or offers) only if you have agreed to receive them. Every marketing email has an unsubscribe link, and you can also opt out at any time by emailing support@practisenow.com.

Even if you opt out of marketing, we will still send service emails that you need to use PractiseNow, such as emails about your account, security and purchase receipts.

If you think we have mishandled your personal information or breached the Australian Privacy Principles, please contact us first at support@practisenow.com and tell us what happened. We will look into your complaint and respond in writing within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992

We may update this policy from time to time, for example when we add a feature or change a service provider. We will post the new version on this page and change the “Last updated” date at the top. If a change materially affects how we handle your personal information, we will also tell you by email or with a notice in the app before it takes effect.

See also our Terms of Use and Refund Policy.