Privacy Policy
How “Lever” collects, processes and protects personal data
Effective from: 21 August 2026
This English text is a translation provided for convenience. The Mongolian version is the one that governs.
1.General
1.1This Privacy Policy sets out how Leverage Education System LLC (registration number: 6946577, “Lever”, “we”) collects, processes, stores, protects and transfers a User’s personal data when they use the lever.mn website, its sub-platforms and every service provided through them.
1.2We process personal data in accordance with the Law of Mongolia on the Protection of Personal Data and other applicable legislation.
1.3This policy forms part of the General Terms of Service and applies alongside the Simulation Exam Service Terms and the Online Course Purchase Terms. On any matter concerning personal data, this policy prevails.
1.4By visiting the website, creating an account or using any service, you are deemed to have read this policy and to consent to your data being processed as it describes.
2.What we collect
2.1Information you give us:
name, email address, telephone number;
the identity document details required to register for a simulation exam;
workplace or class details where the service is taken through an organisation;
correspondence: enquiries, complaints and feedback.
2.2Information created while you use the service:
learning progress, lessons watched, exercises completed, scores;
test and exam answers, and essays you write;
audio recordings of the Speaking part and their transcripts;
exam results, level assessments and the feedback report.
2.3Payment information: the amount, date, the transaction reference issued by the payment system, and invoice details. We do not receive or store full card numbers, CVV codes or full bank account numbers — those are handled only by the licensed payment provider.
2.4Technical information: IP address, device and browser type, operating system, login timestamps, the device identifier used during an exam (to prevent one sitting being taken from two devices at once), and error logs.
2.5We do not deliberately collect sensitive personal data such as ethnicity, religion, political opinion, health or criminal records. Where you yourself submit a medical certificate to evidence a compelling reason, it is used only for as long as it takes to decide that request.
3.Why we process it
3.1We process personal data only for the following purposes:
providing the service, creating accounts, identifying and authenticating you;
processing payments and issuing receipts and invoices;
running exams, producing results and delivering reports;
providing technical support and resolving complaints;
improving the quality and content of the service, and producing statistics;
safeguarding the integrity of exams and preventing misconduct;
meeting obligations imposed on us by law;
where you have consented, sending course information and promotions.
3.2Service notifications about purchases, your account, security and exam scheduling are sent even if you have opted out of marketing. They are sent under the contract between us and do not depend on consent.
3.3We do not make decisions with legal effect by automated means alone. AI assessment is advisory and is subject to the review set out in section 5.
4.Audio recordings
4.1Your answers in the Speaking part are recorded as audio, for the purposes of assessment, quality control and reviewing a disputed result.
4.2By starting the free placement test, by placing a simulation exam booking, or by completing a speaking exercise in a course, you are deemed to consent to this recording.
4.3The recording is transcribed and used for assessment. Recordings and transcripts are seen only by authorised Lever staff and teachers and by the assessment system.
4.4Recordings will not be used for advertising or public distribution without your separate written permission.
5.AI-based assessment
5.1The Writing and Speaking parts may be assessed by Lever’s teachers and/or by an artificial-intelligence based assessment tool. Where they are, your essay, audio recording and transcript are sent to a third-party AI model service for the purpose of marking.
5.2Identifying details such as your name, email address and telephone number are not sent with them — only the content of the answer that marking requires.
5.3Where automated assessment has been used, this is noted in the results report.
5.4You may request a review within 5 working days of receiving your results. The review is free of charge.
6.Disclosure to third parties
6.1We do not sell, rent or trade your personal data.
6.2We disclose it to the following kinds of service provider, to the extent needed to perform the service:
cloud infrastructure, database and file storage;
the video and audio delivery network;
AI assessment, speech transcription and speech synthesis;
email delivery;
licensed payment providers and banks;
web analytics and error monitoring tools.
6.3Where a learner takes the service under an organisation’s contract, their attendance, performance and exam results are reported to that organisation’s authorised contact within the scope of the contract. Learners are told in advance where this applies.
6.4We disclose data where lawfully required by a competent authority, or to the extent strictly necessary to protect the rights and safety of Lever or other users.
7.Transfers outside Mongolia
7.1Some of the providers above are located outside the territory of Mongolia. In particular, the platform’s database and file storage sit in cloud infrastructure data centres in the United States.
7.2When transferring data we apply appropriate safeguards, including contractual confidentiality terms, encryption and access control.
8.How long we keep it
8.1Registration details are kept for as long as the account is active, and for 1 year after it is closed.
8.2Exam answers, results and reports are kept for 3 years from the date of the exam. This is what makes it possible to resolve disputes, carry out reviews and issue confirmations.
8.3Audio recordings of the Speaking part are kept for 1 year from the date of the exam and are then deleted.
8.4Payment and accounting records are kept for the period prescribed by the applicable legislation.
8.5Once the period expires, data is deleted or anonymised and used only for statistical and research purposes.
9.Your rights
9.1You have the right to:
know what data about you is being processed, and to see it;
have inaccurate or incomplete data corrected;
have data erased where there is no longer a lawful basis for it;
have processing paused or restricted;
withdraw consent at any time;
receive your data in a structured form where that is possible;
complain about how your data is processed.
9.2Send requests to levereducation@gmail.com. We answer within 10 working days, once we have verified your identity to the extent necessary.
9.3Withdrawing consent does not affect the lawfulness of processing carried out before it. Exercising some rights may make the service impossible to continue — erasing your exam answers, for instance, voids the result and the report.
9.4If you are not satisfied with our answer, you may complain to the National Human Rights Commission or another competent authority.
10.Cookies
10.1The website uses cookies and similar technologies to operate, to remember your session and to produce statistics.
10.2Strictly necessary cookies carry your login, security and exam progress; the service does not work without them.
10.3You may restrict or delete cookies through your browser settings. Some functions may then be limited.
11.Children’s data
11.1A person under 18 may use the services with the consent of a parent or legal guardian. Registering and paying is taken as confirmation that such consent has been obtained.
11.2A parent or guardian may ask to see, correct or erase their child’s data by writing to levereducation@gmail.com.
12.Security
12.1We take organisational and technical measures to protect data against unauthorised access, alteration, disclosure and destruction, including encrypted connections (HTTPS), access controls, password protection and backups.
12.2If a personal data breach is established, we notify the competent authority and the affected Users without delay, as the legislation requires.
12.3You must keep your username and password confidential. You are responsible for what is done through your account.
13.Changes to this policy
13.1Lever may amend this policy. An amendment takes effect once it is published on the website and the “effective date” is updated.
13.2Registered Users are notified by email of significant changes.
14.Contact
- Company:
- Leverage Education System LLC (“Lever”)
- Address:
- Peace Tower, 11th floor, suite 1108, 3rd khoroo, Chingeltei District
- Phone:
- 77221138
- Email:
- levereducation@gmail.com
- Website:
- lever.mn
