Cookie Policy

Introduction

This Cookie Policy explains how Xmentra uses Cookies, Local Storage, and similar browser technologies, what each of them is for, and how you can control them.

It is written to be read by an ordinary learner rather than a lawyer. Where a technology stores something in your browser, this Policy says what it stores, why it is there, and what happens if you remove it.

This Policy owns the detail of browser storage technologies. The handling of Personal Information — what is collected, why, how long it is kept, and the rights you have — is owned by the Privacy Policy (/privacy). This Policy forms part of the Terms of Use (/terms) and should be read together with the Privacy Policy.

1. Definitions

These definitions are shared across all Xmentra legal documents and are reproduced without modification.

• Platform — the Xmentra website at https://xmentra.com, together with any applications, subdomains, and interfaces operated by Xmentra.
• Services — all functionality offered through the Platform, including lessons, learning experiences, vocabulary, grammar, listening, revision, progress tracking, the educational blog, and any features added later.
• AI Features — any part of the Services that uses automated language models or similar techniques to generate, adapt, evaluate, or respond to content, including the AI Mentor and AI Conversations when introduced.
• Personal Information — information that identifies, or can reasonably be used to identify, an individual, either alone or combined with other information available to Xmentra.
• Cookies — small files placed on a device by the Platform or a Third Party Service to store or read information.
• Local Storage — browser storage mechanisms, including localStorage and sessionStorage, used by the Platform to keep information on the User's own device.
• Third Party Services — independent providers whose infrastructure or tools support the Platform, including hosting, analytics, and, where applicable, content delivery, payment, communication, and AI providers.
• User — any person who accesses or uses the Platform, with or without an Account.
• Account — a credentialed profile that a User may create when Accounts are available, allowing Learning Data to be stored by Xmentra rather than only on the device.
• Learning Data — information about a User's learning activity, such as lessons opened, experiences completed, confidence responses, saved vocabulary, and revision history.
• Community — any feature allowing Users to interact with one another, including forums, comments, groups, or shared practice.

2. What Cookies Are

A Cookie is a small file that a website asks your browser to store, and can read again on a later visit. Cookies are commonly described in two ways.

By who sets them. A first-party Cookie is set by the website you are visiting. A third-party Cookie is set by another organisation whose code runs on the page, such as an advertising or embedded-media provider.

By how long they last. A session Cookie is removed when you close your browser. A persistent Cookie remains until it expires or you delete it.

These categories describe Cookies generally. They do not imply that Xmentra currently uses every category; the current position is set out in section 10.

3. Cookies and Similar Technologies

Several technologies are often loosely called "cookies" although they work differently. Xmentra distinguishes them because the controls differ.

• Cookies — files sent between browser and server with requests, as described in section 2.
• `localStorage` — browser storage that keeps information on your device until it is removed. It is not a Cookie and is not transmitted automatically with requests. Xmentra relies on it substantially; see section 4.
• `sessionStorage` — the same idea, limited to a single browser tab and cleared when that tab is closed.
• Analytics scripts — code loaded on a page that measures usage. A script is not itself storage, although a script may set Cookies or use Local Storage.
• Pixels, tags, and similar technologies — small requests, often for an image, used to record that a page or message was opened. These are typically associated with advertising and email measurement, neither of which the Platform currently operates.

4. Local Storage at Xmentra

This section describes the most important storage behaviour on the Platform, so it is worth reading in full.

Your learning stays on your device. Learning Data — including lesson and experience progress, confidence responses, saved vocabulary, revision history, and interface preferences — is currently written to your browser's Local Storage on the device you are using.

Xmentra does not currently keep a server copy. There is currently no Account, no login, and no server-side record of your Learning Data. That record exists in your browser, not in Xmentra's systems.

Clearing browser or site data can remove it. If you clear site data, use a browser cleaning tool, or reset your browser, that record can be removed.

Removed progress may not be recoverable. Because no server copy exists, once local Learning Data is deleted, Xmentra cannot restore it.

Progress does not follow you automatically. Local Storage belongs to one browser on one device. Opening the Platform in another browser, another device, or a private window generally shows a fresh start.

This may change if Accounts are introduced. Where Accounts or progress synchronisation are offered in future, Learning Data may be stored in Xmentra's systems so it can follow you between devices.

Any such change follows the no-surprise-migration principle. Locally stored Learning Data is not moved into Xmentra's systems without prior notice and a deliberate action by you. The Privacy Policy (/privacy) owns the detail of how such a migration would be described and handled.

The internal names of individual storage entries are technical implementation details and are not listed here. They may change as the Platform develops without affecting what is described above.

5. Essential Technologies

Some technologies are necessary, or reasonably required, for the Platform to work as intended. On Xmentra these are currently first-party and on-device:

• storage that remembers your learning progress and preferences, so a returning visit continues where you left off;
• storage that keeps a short-lived identifier for the current browser tab, so activity within one visit can be counted once rather than repeatedly;
• security, load-balancing, or availability mechanisms that hosting and content delivery infrastructure may reasonably require to serve the Platform.

Analytics is not treated as essential. It is described separately in sections 6 and 7.

6. Analytics Technologies

Xmentra measures how the Platform is used so that lessons and pages can be improved. Analytics is currently used at a level intended to describe traffic and usage patterns rather than to build a profile of an individual.

Analytics is currently used to understand, at a high level:

• how much traffic the Platform receives;
• which pages and lessons are opened, and in what order;
• engagement signals such as time on page and whether a visit continues;
• general browser and device characteristics, such as device category;
• approximate geographic information, where the analytics provider derives it;
• how the Platform performs, including slow or failing pages.

In addition, a first-party on-device usage log is written to your browser's Local Storage so that internal, aggregate usage summaries can be reviewed. That log is held on your device and is not currently transmitted to a Xmentra server. It records events such as a lesson being opened or a revision session being completed, together with device category and a tab-scoped session identifier. It is not designed to hold free-text you type, reflection notes, or audio.

Nothing in this section should be read as a claim that the analytics provider receives more than what the Platform actually sends to it.

7. Google Analytics

The Platform currently uses Google Analytics 4, provided by Google, as its analytics service. The analytics script is loaded from Google's servers, and in its default configuration Google Analytics 4 sets first-party Cookies in your browser to distinguish visits and sessions. Those Cookies are persistent, with a lifetime set by Google's default configuration rather than by Xmentra.

Google processes analytics information as an independent provider under its own applicable terms and privacy practices. Those documents are Google's, and are not reproduced or summarised here. The Privacy Policy (/privacy) names current providers and describes their roles.

Analytics measurement identifiers are configuration values held in the Platform's code and are not published in this Policy.

8. Advertising and Marketing Technologies

Xmentra does not currently operate advertising, retargeting, behavioural profiling for marketing purposes, or the sale or sharing of information with advertising networks. No advertising Cookies or advertising pixels are currently set by the Platform, and no email or push-notification measurement is currently in operation.

Where advertising, marketing measurement, or similar technologies are introduced, this Policy will be updated before or at the time they become active. The update will describe the technology, its provider, and its purpose, and, where applicable law requires consent for such technologies, consent will be handled accordingly as described in section 13.

9. Third Party Technologies

Third Party Services are described here by role. Named providers are listed in the Privacy Policy (/privacy), which owns the provider inventory.

• Hosting and content delivery — serves the Platform's pages and assets, and may use technical mechanisms reasonably required for delivery, routing, security, and availability.
• Analytics — measures usage, as described in sections 6 and 7.
• Security and monitoring — protects availability and integrity, to the extent such tooling is used by the hosting infrastructure.
• Communications — where an email or messaging provider is introduced.
• Payments — where Payments or Subscriptions are introduced.
• AI processing — where AI Features that call an external model provider are introduced.

The Platform does not currently embed third-party players, chat widgets, social media components, or map tiles that would set their own storage in your browser.

10. Current Cookie and Storage Table

This table describes the current position. It uses accurate descriptions rather than invented Cookie names, durations, or providers. Where an exact value is set by a Third Party Service rather than by Xmentra, that is stated.

11. Your Controls

You remain in control of what your browser stores.

Browser Cookie settings. Every major browser lets you block all Cookies, block third-party Cookies, or delete existing Cookies. These settings are found under privacy or site-data settings and apply across websites.

Clearing Local Storage and site data. Clearing "site data", "cookies and other site data", or "storage" for xmentra.com removes both Cookies and Local Storage for the Platform, including saved progress. See section 12 before doing this.

Per-site controls. Most browsers allow you to clear or block storage for a single site while leaving other sites untouched.

Private or incognito browsing. A private window generally keeps storage for the duration of the window and discards it afterwards. Progress made in a private window is therefore usually lost when the window is closed, and analytics still operates within that window.

Analytics opt-out. Google publishes a browser add-on that prevents Google Analytics measurement from being sent for browsers where it is installed. Blocking or clearing Cookies, or using a browser or extension that blocks analytics scripts, has a similar effect.

No dedicated consent interface currently exists. Xmentra does not currently provide a dedicated cookie consent-management interface. That describes the current technical implementation; it is not a conclusion that consent is never required, and it does not by itself establish compliance with any particular law. Where applicable law requires consent before particular cookies or similar technologies are stored or accessed, Xmentra will review the relevant technology and implement appropriate consent controls where required. See section 13.

12. Effect of Blocking or Clearing Storage

Blocking or clearing storage is a legitimate choice, and this section simply describes the consequences.

• Interface preferences may return to their defaults.
• Learning progress, confidence responses, saved vocabulary, and revision history held on that device may be removed, and cannot be restored by Xmentra.
• Features that depend on continuity, such as resuming a session or seeing your progress over time, may stop working as intended.
• Certain functionality may become limited, although Educational Content itself generally remains readable.
• Analytics measurement for your browser may stop, which does not affect your use of the Services.

13. Consent

This section separates what is technically in place on the Platform today from what applicable law may require in a given jurisdiction.

Current technical implementation. Xmentra does not currently provide a dedicated cookie consent-management interface or consent-management platform (CMP). Mere use of the Platform is not treated as consent to non-essential Cookies or similar technologies, and the absence of a banner does not by itself establish that consent was obtained or that consent was not required.

Legal requirements that may apply by jurisdiction. Requirements differ by jurisdiction, and no general exemption is claimed here for analytics or for any other category of technology. Where applicable law requires consent before particular Cookies or similar technologies are stored on or accessed from your device, Xmentra will review the relevant technology and implement appropriate consent controls where required — which may mean asking for consent before the technology loads, offering a choice, or not using it in that jurisdiction. Where applicable law instead requires clear information and a means to object, this Policy and the controls in section 11 are provided for that purpose.

How a mechanism would be implemented. Where a consent mechanism becomes necessary — for example if advertising, marketing, or profiling technologies are introduced, or where required for analytics in a particular jurisdiction — it will be implemented without dark patterns, with refusal as straightforward as acceptance, and this Policy will be updated in the same release.

14. Do Not Track and Browser Privacy Signals

Browsers may send signals such as "Do Not Track" or "Global Privacy Control". There is no consistent industry standard for how a website should respond to them.

The Platform does not currently implement automated handling of these signals, and this Policy does not claim support that has not been built. The controls described in section 11 remain effective regardless of any signal your browser sends, and browser-level blocking of Cookies or scripts works as expected. If automated handling of a privacy signal is implemented, this Policy will describe its actual behaviour.

15. Children

The Platform is intended for Users aged 14 or older and is not directed at children under 14. The Privacy Policy (/privacy) owns the detail of how children's information is treated, including what happens if we learn that information relating to a child under 14 has reached us.

16. Future Technologies

The following capabilities are not currently available. Each entry states the rule that will apply when it is introduced, so that activation is a documented change rather than a new practice.

• Accounts — session or authentication Cookies, or equivalent tokens, may be used to keep you signed in. These would be essential to the Account feature. Learning Data may then be stored in Xmentra's systems, subject to section 4.
• AI Mentor and AI Conversations — may require storage to maintain the state of a conversation. AI capability and limits are owned by the AI & Educational Use Policy when published.
• Payments and Subscriptions — a payment provider may set its own Cookies or storage for fraud prevention and transaction integrity.
• Community — may require storage for identity, moderation, and session continuity.
• Mobile Applications — would use on-device storage rather than browser Cookies, and would be described in Mobile App Terms.
• Personalisation and learning analytics — may store information used to adapt recommendations. Any profiling would be described in the Privacy Policy, together with how to opt out.
• Security tooling — may use technical mechanisms to detect automated abuse.

17. Changes to this Policy

We update this Policy when the technologies in use change, when a new provider is introduced, or where required by applicable law.

• The Last Updated date changes with every edit.
• The Version number increases: a MAJOR increase for a change to the technologies in use, their purposes, or your controls; a MINOR increase for clarification, formatting, or contact updates.
• A MAJOR change is reflected in this Policy before or at the time the technology becomes active, and, once Accounts exist, announced at least 14 days before its Effective Date.
• Superseded versions are retained internally for reference.
• This Policy is reviewed at least every 12 months.

18. Contact Information

Questions about this Cookie Policy can be sent to hello@xmentra.com.

19. Revision History