Privacy Policy

Effective date: August 1, 2026.

Upshores is currently in public beta before incorporation. Michelle Lorraine Watts operates the service as an individual and determines the processing described in this Policy. The address for privacy and legal notices is Sai Ho Wan, Hong Kong Island, Hong Kong, and the contact email is support@upshores.com.

This Policy applies to upshores.com, upshores.cn, and related Upshores account, practice, report, and support services.

Account and security information: email address, hashed password, verification codes and status, account identifiers, login sessions, and necessary security records.

Practice and learning information: selected practice, responses, timing, progress, scores, credits and redemption records, and the answer explanations and learning reports generated by the service.

Speaking and Writing information: recordings, written responses, automated transcripts, assessment dimensions, feedback, and revision suggestions.

Manual-purchase information: if you buy credits through a published contact channel, we record the purchase confirmation, amount, payment status, and necessary transaction reference to grant credits, reconcile the transaction, and handle support. The website does not collect full payment-card details.

Device and service information: IP address, browser and device type, request time, error and security logs, and cookies or similar local storage used to maintain sign-in, language, and theme preferences.

Communications: information you choose to provide when contacting us through email, WeChat, or another published channel, together with records needed to respond.

We use this information to create and protect accounts, save responses, run practice and mock tests, generate scores and feedback, display learning history and credits, and respond to support requests.

We also use necessary logs to diagnose failures, prevent abuse, protect the service, and understand whether features work through aggregated or de-identified information. We do not sell personal information or use Speaking or Writing responses to build advertising profiles.

Speaking, Writing, and some learning feedback are processed by automated models. Inputs may include the task, your response or recording, transcript, and context needed for assessment. Outputs may include practice scores, dimension assessments, explanations, and improvement suggestions.

These results are for practice and learning reference. They are not official TOEFL scores and should not be the sole basis for admission, employment, or another significant decision. Report an evident technical or content error to support@upshores.com.

We do not use identifiable responses to train general-purpose or commercial AI models unless we later explain that purpose clearly and obtain any consent required.

To operate the service, we may ask agents, contractors, or other service providers to process the minimum information needed for a function. The relevant service categories include website and network infrastructure, object storage, databases, AI model inference and transcription, Speaking assessment, transactional email, and mainland-site network forwarding and related logs.

These contractors may process data in Hong Kong, mainland China, or other countries and regions. We use access restrictions, technical settings, and applicable service terms to limit use. Model requests use no-data-collection or zero-data-retention options under the current production configuration, and contractors are not permitted to use the requests to train their own models.

If you choose to contact us through WeChat, that communication is also processed by WeChat under its own rules.

We currently use only cookies or similar storage needed to maintain sign-in, protect the service, and remember language and theme preferences. We do not currently use advertising cookies, cross-site marketing trackers, or session-replay tools.

Blocking necessary cookies may prevent sign-in or stop preferences from persisting.

We keep information only for as long as needed to provide accounts and learning records, handle support, protect the service, and meet applicable legal obligations. While an account remains in use, responses, reports, and credit records will generally remain with it. Security records and system backups are removed according to their operational cycles after they are no longer needed.

We use reasonable measures including access controls, encryption in transit, restricted credentials, and logging. People may access information only when needed for support, troubleshooting, security, or compliance. No internet service can guarantee absolute security.

You may contact support@upshores.com to request access to or correction of personal information associated with your account, or to request deletion of the account and information we no longer need. We may verify account ownership and retain limited records required for legal, security, dispute, or backup purposes.

The product does not yet offer self-service export or deletion. These requests are handled through support. Choosing not to receive optional messages does not stop account-security or service notices.

Upshores is for people preparing for TOEFL and is not directed primarily to children. If you have not reached the age at which you may independently agree to this Policy and the Terms where you live, a parent or legal guardian must review and agree before you use the service.

If you believe a child supplied personal information without appropriate authority, contact support@upshores.com so we can verify the situation and take appropriate action.

We will update this Policy when the product, operator, service providers, or legal requirements change materially and will show a new effective date. We will provide reasonable notice of significant changes through the site, account, or email.

For privacy questions, data requests, security concerns, or complaints, email support@upshores.com. Written notice address: Sai Ho Wan, Hong Kong Island, Hong Kong.