Last Updated: April 16, 2026
Privacy Policy
Last updated Oct 6, 2025
Thank you for using EngGym! Your trust matters to us.This Privacy Policy explains how Elite Learning New York Inc., doing business as “EngGym” (“EngGym,” “we,” “our,” or “us”), collects, uses, discloses, and protects your personal information when you use our mobile application, website, and related services (collectively, the “Service”). For purposes of this Privacy Policy, and unless the context expressly provides otherwise, all references to “EngGym” mean and include Elite Learning New York Inc., which is the legal entity responsible for the ownership, operation, and control of the Service. By using EngGym, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. Please note that EngGym is continually testing and improving its features. As a result, certain features described in this Policy may not be available to all users or in all regions.
1. Information We Collect
We collect information to make EngGym work effectively for you — to personalize your learning experience, keep your account secure, and improve the quality of our services.
a. Account Registration
To register for an EngGym account, you may provide us with your age and email address. In some countries, you may also provide us with your phone number. You may also register for an EngGym account using certain social logins, such as Facebook or Google. If you register for EngGym using a social login, EngGym may receive information about you from your social login provider, including your email address and contacts. You can manage your EngGym account and social logins from your Settings.
b. Profile Page and Learning Content
After registration, a personal EngGym Profile is created for you. Your profile may include your display name, username, profile picture, and short bio if you choose to add one.
Your profile also contains information about your learning activity, such as your current study plan, progress reports, and achievements. Your writing samples, speaking recordings, and practice exercises are considered User- Generated Content. These materials are stored securely and used to deliver personalized feedback, track progress, and improve the learning experience.
c. AI Features & Speaking Practice
EngGym offers AI-powered features that allow you to practice speaking and writing in English through interactive feedback and conversational exercises. These tools may include voice-based practice sessions where you can have AI-assisted spoken interactions or text-based tasks where you receive real-time corrections and suggestions. When you use these AI features, the text and audio you submit are processed by EngGym’s AI systems or by trusted third-party providers that support our artificial intelligence technology. Additionally, EngGym may generate, record, and store audio recordings or transcripts of your submissions, and use them to improve product performance and personalization — including training and refining our AI models.Please do not submit any personal, sensitive, or confidential information when using EngGym’s AI features or speaking activities.
d. Speaking Activities
Some activities in EngGym involve you speaking into the app to practice pronunciationand fluency. To recognize and process your speech, your audio may be sent to a third- party provider such as Google, Apple, or Amazon Web Services. Additionally, EngGymmay collect and analyze your audio recordings to help us evaluate the effectiveness of our lessons and to improve or personalize your learning experience. You may skip speaking activities at any time if you prefer not to participate.
e. Activity Data and IP Addresses
When you use EngGym, we automatically generate data related to your activity on the Service. This includes your IP address, browser type, app version, time zone, and general engagement information such as lesson completions and time spent on exercises. We use this information to secure our systems, detect potential misuse, and maintain accurate records of learning activity. Your IP address may also be used to estimate general location (for example, your country or region) to localize app content and comply with regional data rules. We retain IP data as long as necessary for security and performance monitoring and delete or anonymize it afterward.
f. Analytics and Experience Tools
EngGym uses analytics and user experience tools such as ContentSquare, and Branch to help us understand how users discover, navigate, and interact with our app and
website. These tools collect technical and usage information such as device type, operating system, pages viewed, navigation flow, clicks, scrolls, and session duration. The goal is to identify usability issues and improve overall performance. They help us design a smoother learning experience. These recordings do not capture sensitive information such as names, passwords, payment details, or written lesson content.
g. Cookies
When you visit EngGym’s website, we may store small pieces of information called cookies on your device. Cookies help us confirm that you’re logged in, remember your preferences, and analyze how users navigate our site. You can manage or disable cookies through your browser settings, but some features may not function properly without them. We may also use cookies or similar technologies from third-party providers (such as Google or Meta) to measure traffic sources or aggregate engagement data.
h. Google Analytics
EngGym uses analytics tools like Google Analytics to understand how users interact with our platform and to improve performance. These services use cookies or similar identifiers to collect non-identifiable information such as device type, usage duration, and navigation flow. We use aggregated reports generated by these tools to improve lesson design, enhance speed, and troubleshoot errors. These reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics by installing Google’s browser add-on
2. How We Process Your Information
EngGym may process your personal information according to the following legal bases: to provide the products and services you request, to promote EngGym’s legitimate interests, to comply with legal obligations, and with your consent. In particular, EngGym may process and share your information in the following ways:
a. Providing and Improving the Service
EngGym processes your personal information to deliver and enhance the learning experience. This includes maintaining your account and learning profile, tracking your progress, personalizing lessons and feedback, identifying and fixing technical issues, and providing customer support. We also use your data to analyze how learners use EngGym, so we can improve lesson quality, design better features, and ensure stable performance. To achieve this, EngGym may share information with trusted third-party service providers that help us operate, analyze, and improve the Service. These partners may include hosting and infrastructure providers such as Amazon Web Services; analytics and experience platforms such as Branch; payment processors and subscription managers such as Apple; and AI or speech recognition partners that help process writing and audio submissions. All third-party providers are required to handle your information securely and only for the purposes specified by EngGym. All third-party service providers are bound by strict confidentiality and data protection obligations. If you redeem a promotion code to gain an EngGym subscription, we may share data regarding your use of EngGym with the organization that provided the promotion code to you.
b. Delivering notices or updates
EngGym uses the contact information you provide — such as your email address or phone number — to communicate with you in several ways. This may include:
• Essential messages needed to operate your account, confirm payments, or address support requests.
• Learning reminders and updates, such as progress summaries, study tips, or motivational notifications to help you stay consistent.
• Announcements about new features, app updates, or changes to this Privacy Policy.
• Occasional product news or offers, if you have opted in to receive them.
You may opt out of non-essential messages at any time by adjusting your notification settings in the app or using the “unsubscribe” link in our emails.
c. Complying with Law and Preventing Harmful Activities
EngGym may process or disclose personal information when necessary to comply with legal requests or obligations, such as subpoenas, court orders, or government regulations. We may also share data when we believe it is reasonably necessary to:
• Protect the rights, property, or safety of EngGym, our users, or others
• Prevent fraud, abuse, or other illegal activity
• Cooperate with law enforcement or respond to valid government requests
Such disclosures are made in good faith and only when required by applicable law or legitimate safety concerns.
d. Product Analytics and Research
EngGym may process and share non-identifiable data for the purposes of analytics, and product improvement. These analyses help us refine our AI feedback models, enhance course design, and develop new learning experiences. Any data used for this purpose is aggregated or de-identified so that individual users cannot be identified.
e. Anonymous and Aggregated Information
EngGym may process aggregated, de-identified, or otherwise anonymized information for any lawful purpose, including statistical analysis, academic research, and performance reporting. This data is not considered personal information.
3. Your Data Subject Rights
You have certain rights in relation to the personal information we hold about you, in addition to any other rights provided under applicable law. These rights may vary depending on where you live, but in general, EngGym gives all users meaningful control over their personal information. You have the right to:
• Know what personal information we have collected about you.
• Know which categories of personal information about you we have shared with third parties, if any.
• Opt out of the sharing of your personal information with third parties, where applicable.
• Request limitation of our use of your sensitive personal information to what is necessary to provide the services you requested.
• Not be discriminated against for exercising your privacy rights.
• Request correction of any inaccurate or outdated personal information about you.
• Delete your EngGym account at any time by following the instructions within the
app or contacting our support team. You can update or correct certain personal information and manage opt-out
preferences. Please note that these rights are not absolute and EngGym may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law, or if the request could interfere with a EngGym service or prevent us from delivering a service you requested.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority.
4. Data Retention
EngGym will generally retain your personal information for as long as your account remains active. This allows us to provide you with access to your learning history, progress records, and personalized feedback. However, EngGym may retain certain information for a longer period if necessary to operate and maintain the Service, protect our legitimate interests or those of third parties, comply with legal obligations, resolve disputes, investigate potential misuse or security issues, or enforce our agreements. Once you delete your account or request data removal, we will delete or anonymize your personal information within a reasonable timeframe, unless we are required by law to keep it longer. We may also retain aggregated or anonymized data indefinitely for product improvement purposes.
5. Child users
EngGym is designed for learners aged 13 and above. We understand the importance of protecting children’s privacy online and comply with all applicable child data protection laws, including the Children’s Online Privacy Protection Act (COPPA) in the United States, the General Data Protection Regulation for children (GDPR-K) in the European Union and United Kingdom, and the Personal Data (Privacy) Ordinance (PDPO) in Hong Kong. We do not knowingly collect, use, or store personal information (such as names, contact details, photos, voice recordings, or written content) from children under 13 years old (or under 16 where local law requires) without verified consent (emails) from a parent, guardian, or authorized teacher. If EngGym learns that a child has created an account or provided personal information without proper consent, we will take immediate steps to delete the child’s data and account from our systems. Parents, guardians, or teachers who believe a child under their care has used EngGym without consent may contact us at support@enggym.com
6. Links to Third-Party Websites
The EngGym Service may contain links to third-party websites or online services. EngGym is not responsible for the content, accuracy, or privacy practices of these external sites, including any personal or financial information collected by third-party payment processors or service providers.
We encourage users to exercise caution and review the privacy policies of any third- party websites they choose to visit. Any time you click on a link (including advertising banners) or submit your personal information to a third-party website, you will be subject to that third party’s privacy policies.
7. Privacy Policy Updates
EngGym may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. If we make any material changes, we will provide notice by posting an updated version on our website. We will post a notice that we have made changes to this Privacy Policy on the Website for at least seven (7) days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that seven (7) day period.
8. Data Transfer
EngGym is based in the United States, which may not provide equivalent levels of data protection as your home jurisdiction. EngGym may transfer the data of users outside the United States to the United States. Data Privacy Framework (DPF) EngGym complies with the EU–U.S. Data Privacy Framework (EU–U.S. DPF), the UK Extension to the EU–U.S. DPF, and the Swiss–U.S. Data Privacy Framework (Swiss– U.S. DPF) as set forth by the U.S. Department of Commerce. EngGym has certified to the U.S. Department of Commerce that it adheres to the DPF Principles regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom (and Gibraltar), and Switzerland to the United States. In compliance with the DPF Principles, EngGym commits to:
• Resolve complaints regarding our handling of personal information received under the DPF.
• Cooperate with the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to address unresolved complaints.
Individuals located in the EU, UK, or Switzerland who have concerns about EngGym’s data practices under the DPF may first contact us at legal@enggym.com. If a complaint cannot be resolved through our internal process, individuals may invoke binding arbitration under certain conditions, as described in Annex I of the DPF Principles.
EngGym remains responsible under the DPF Principles for personal information that it transfers to third-party agents acting on its behalf. EngGym will not be liable if it can demonstrate that it was not responsible for the event giving rise to any damage. The U.S. Federal Trade Commission (FTC) has jurisdiction over EngGym’s compliance with the Data Privacy Framework. EngGym may disclose personal information in response to lawful requests by U.S. public authorities, including to meet national security or law enforcement requirements.
9. Supplemental Terms in Certain Jurisdictions
In some jurisdictions, the EngGym Service may be subject to additional privacy requirements or local laws that provide specific rights or protections for users. Where applicable, those local laws or supplemental privacy notices will take precedence over this Privacy Policy to the extent they conflict.
10. Contact Us
EngGym, Inc. is the data controller of your personal information for purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws. If you have any questions, concerns, or requests about this Privacy Policy or how we handle your data, please contact us at support@enggym.com.
Last updated Oct 6, 2025