This policy was last updated on 28th April, 2020.
Please take the time to familiarize yourself with this Policy and if you have any questions, please contact us at firstname.lastname@example.org. This policy is incorporated into and is subject to our Terms of Service.
Services We Provide
We provide Services on behalf of Test Sponsors who are our clients. They may be any institution, organization or unit of which you are a member (in any form, including but not limited to a user of their services) or an applicant or at which you are enrolled (“Test Sponsors”). Test Sponsors are organizations, educational institutions, or companies that offer and control any test that is used to make certification, licensure, or other types of decisions based on test results. We collect and/or receive personal information about a test taker in order to develop, administer, or proctor a test for a Test Sponsor. “Personal Information” is any information, such as name or email address, that identifies or can be used to identify the person to whom such information pertains, or is associated with a person. While providing Personal Information is voluntary, it is necessary if you are to obtain the grades, test scores, service, or credential that you seek from your Test Sponsor. We will handle and treat Personal Information collected or received while providing our Services in a manner that is consistent with this Policy and applicable law.
This Policy describes how we collect, use, store, and share information about you in connection with your use of the Services. If you do not accept the terms of this Policy, please do not use any of our Services.
Information We Collect
Personal Information that you provide through the Services: We collect Personal Information from you when you voluntarily provide such information, such as when you: launch the Services from your learning management system; register for and/or login to the Platform; request customer support, a demo, or more information; communicate with us via email or social media sites; provide biometric data including as part of onboarding to the Services to create your identity profile; or take a test on our Services. Personal Information collected through our Services may include, but is not limited to, the following:
- Zip Code
- Photograph of identity document, such as a driver’s license
- Photograph of you
- Telephone Number
- Username and Password
- Name of the Test Sponsor(s) (i.e., the educational institution(s)) at which you are enrolled and course test information
- Employment information
- E-mail address
- Test submissions
- Audio and video recordings of you taking tests and the test-room environment
- Biometric data, including biometric identifiers (such as scans of hand or knuckles) and biometric information (such as knuckle, face, or keystroke patterns)
- Government-issued identification number (if required, or as included in the identity document you provide)
Information Collected From Test Sponsors: We may collect information about you from Test Sponsors, such as your email address, to provide you a registration link to our Services. This information may also be combined with the Personal Information collected from you.
Cookies and Other Tracking Technologies:
If you do not want to receive cookies, you can change your browser settings. If you use our Services without changing your browser settings, we will assume that you’ve agreed to receive all cookies on the Company websites. Please note that our Services will not function properly without cookies.
Our Services may use two types of cookies, session and persistent. A session cookie expires after a set time, normally when you close your web browser. A persistent cookie remains after you close your web browser and may be used on subsequent visits to our Services to enable us to recognize you as an existing user.
We record certain information and store it in log files when you interact with our Services. This information may include IP address, browser information, mobile device information, internet service provider, operating system, date/time stamp, and other system configuration information. We and our analytics providers also collect and store analytics information when you use our Services to help us improve our Services.
Non-Personal Information collected from your use of our Services: We may statistically aggregate test responses and other data collected during the testing process in a non-person-specific format and transfer this data to Test Sponsors, affiliates, agents, and partners. Such aggregated non-personal data may be used for quality control, security and marketing purposes, operations improvement and to improve the testing services, tests, or related products.
How We Use Your Personal Information
We use your Personal Information generally as a processor on behalf of Test Sponsors to provide and improve our Services and to develop new services, functions, or features for our Services. For instance, we use your Personal Information to register you for a test, answer any questions or concerns you may have, administer the test, and/or convey the results of testing. We may also use your Personal Information to contact you about scheduling, technical, security, or other testing related issues, or to contact you for other administrative purposes, such as customer service. We use biometric data we collect from you during onboarding to create your identity profile for the Services. We use biometric data we collect from you when you take a test using the Services to compare against your identity profile for purposes of verifying your identity.
To Whom We Disclose Your Personal Information
When you take a test using the Services, we provide your Personal Information to the Test Sponsor(s) from whom you seek a test score, service, or credential to enable them to validate your identity and your test score, as well as for academic hearing purposes. For further information about how your Test Sponsor(s) may use your Personal Information, please contact your Test Sponsor(s).
We may also disclose your Personal Information in the following situations:
- When we believe it is reasonably necessary to comply with laws and regulations, or in response to a subpoena, court order, or other legal processes.
- To protect against misuse or unauthorized use of our Services, or to protect the security or integrity of our Services or any facilities or equipment used to make our Services available.
- To limit our legal liability and protect our property or other legal rights, or the rights of our Test Sponsors and test takers.
- To address actual or suspected fraud or other illegal activities.
We may also seek your consent for additional disclosures of information, including your Personal Information, and will share it only as described to you.
We take the security of your Personal Information seriously. We employ industry standard practices to protect your Personal Information in accordance with this Policy and applicable law. However, you should be aware that we do not control the security of your equipment or your network connection, and therefore any information you transmit to us through the equipment or internet connection you use, you transmit at your own risk.
We take reasonable steps to ensure that the data we collect is reliable for its intended use. However, it is your responsibility to update us with any relevant changes in your personal information so that we can provide you with our Services. We collect Personal Information that is relevant for the purposes for which it is to be used. Furthermore, we take reasonable steps to ensure that we process Personal Information in a way that is consistent with the purposes for which it is collected.
Data Retention and Deletion
Data collected from proctored activities (including biometric data) are held for up to 180 days (as configured by the applicable Test Sponsor(s)) after a proctored test session. Your identity profile and data collected for identification verification purposes (including the biometric data we use to create your identify profile) is retained for up to two years from the time the identity profile is created in our Platform (as configured by the applicable Test Sponsor(s)). After the applicable retention period, we will automatically delete your Personal Information from the Platform and our systems, and maintain only the minimal amount of data required for billing and necessary business purposes and legal compliance.
As explained above, we provide our Services as a processor on behalf of Test Sponsors who have the right to receive your data (e.g. for academic hearing purposes). We do not control what they do with your data. Test Sponsors have their own policies with respect to data retention and deletion. For further information on such policies, to revoke consent related to biometric data, or to request deletion of any Personal Information outside of the retention policies described above, please contact the applicable Test Sponsor(s) (for example, your academic institution).
Please be aware: In a case where you contact us exercising your rights to delete some or all of your data, and after verification that the request is coming from you, we likely will need to contact your Test Sponsor who is the Data Controller for permission in order to legally comply with your request, and even though we agree to do so, you may still need to contact your Test Sponsor to make a similar request, or your data may be retained separately by them.
International Users and International Data Transfer
In order to provide the Services, here is how we manage your Personal Information data:
Data collected for Test Sponsors located in Canada is stored within the Canada region. Data collected for Test Sponsors located in the EU is stored within the EU region. Other data by default is stored in the United States. Also, we may transfer your data to other countries or regions in connection with the processing of data, fulfilling your requests, and operating the Services. By providing your information on or to the Services, you consent to any such storage, transfer, and processing in accordance with this Policy and applicable law.
The Choices You Have With Your Information
If you created an account with us in connection with your use of the Services, you may modify or update some of your Personal Information by logging in and accessing your profile. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. If you wish to access or modify any other Personal Information that we hold about you, you may contact us at email@example.com. If you have not created an account with us in connection with your use of the Services and wish to access or modify any Personal Information that we hold about you, please contact the applicable Test Sponsor(s) or firstname.lastname@example.org Or create a ticket request on https://www.verificient.com/support .
External Websites and Third Parties
From time to time, our Services may contain links to third party websites. The policies and procedures we describe in this Policy do not apply to the third party websites. The links from our Services do not imply that the Company endorses or has reviewed the third party websites. We suggest contacting those sites directly for information on their privacy policies before providing any of your personal information to them.
“Stripe” is used as a third party payment gateway. Stripe is only a channel used to accept payments and does not have access to any user data and no personal or user data is shared with Stripe. AWS (amazon) and GCP (Google) are our cloud service providers. All the Data stored on the cloud servers is encrypted.
Your California privacy rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.
For more details about the personal information we have collected over the last 12 months, including the categories of sources of personal information collected, please see the “Information We Collect” section above. We collect this information for the business and commercial purposes described in the “How We Use Your Personal Information” section above. We share this information with the categories of third parties described in the “To Whom We Disclose Your Personal Information” section above. Verificient does not sell the personal information we collect. Please note that we do use third-party cookies due to the technology of how Proctortrack is integrated with the testing platforms utilized by the Test-Sponsors and for continuous use of the App (Desktop app, mobile app or browser plugin/extension app) and for purposes as further described in our “Cookies and Other Tracking Technologies” section above.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), the right to request deletion of their personal information, the right to opt out of any “sales” of their personal information that may be occurring and the right to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at email@example.com Or may create a ticket request on https://www.verificient.com/support. We will verify your request using the information associated with your account along with the steps within our identifying process, including email address along with the assistance of your Test-Sponsor. Government identification may be required. Consumers can also designate an authorised agent to exercise these rights on their behalf.
Information from Children
Changes to this policy
Company reserves the right to change this Policy from time to time by posting an updated Policy to this site and the “last updated date” at the top of this page will be updated. We may also provide you additional notice, such as adding a statement to the home screen or sending you an email notification. Please review this Policy periodically, and especially before you provide any Personal Information. Your continued use of the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.
Our Contact Information
Please contact us with any questions or comments you have about this Policy, your information, our use and disclosure practices, or our Services by email at firstname.lastname@example.org.
Verificient Technologies Inc. adheres to the Privacy Shield Principles.
Note: Verificient adheres to EU General Data Protection Regulation (“GDPR“). Refer to our GDPR page for more information.
Verificient Technologies Inc. is subject to the jurisdiction and enforcement authority of the US Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, Verificient Technologies Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Verificient Technologies Inc. at: email@example.com, or contact our Support team at : firstname.lastname@example.org, or chat with us via the chat window on our website – www.verificient.com.
Verificient Technologies Inc. has further committed to refer unresolved Privacy Shield complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of BBB EU PRIVACY SHIELD are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration before a Privacy Shield Panel when other dispute resolution procedures have been exhausted.
Verificient Technologies Inc. may be required to release the personal data of EU and Swiss individuals in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
Verificient Technologies Inc. may be liable for the onward transfer of personal data of EU and Swiss individuals to agent third parties unless it can be proven that we were not responsible for the actions giving rise to the damages.
You can view the complete Terms of Service here.