Privacy Policy

Who are we?

Vanilya Elektronik Hizmetler ve Bilişim Tic. A.Ş.  a joint stock company (anonim şirket) registered at Istanbul Trade Registry with number 926625 and with its registered office at Esentepe Mah.  Kore Sehitleri Cad. No: 29, Zincirlikuyu, Şişli, Istanbul, Turkey. (“TestInvite” or “We”)

What is the purpose of this Privacy Policy?

This Privacy Policy describes the manner in which we collect, use, maintain, disclose and otherwise process personal data collected from our clients, Participants (as defined below) and website visitors (each, a "Visitor"). Visitors who have signed up for an account (“Customer”) on our website (“Website”) can create content on the Website (e.g. exams), which content can be accessed and used by the participants (“Participants”).

TestInvite generally collects personal data on behalf of its Customers for purposes of providing exam-related services to those Customers’ Participants. In such cases, the Customer will be the “data controller” of the applicable personal data, and TestInvite is the “data processor,” as those terms are used in applicable data and privacy laws. In our role as a data processor, TestInvite only processes personal data in accordance with the applicable contract for purposes of providing its exam-related services to its Customers. For more information on our data processor rights and obligations in this scenario Customers should please refer to the Data Processing Addendum available on the Website, which is a legally binding agreement between TestInvite and the Customer.

What data do we collect?

We may collect the following categories of data (as applicable) from our Visitors, Customers and/or Participants (“You”).

If you are a Participant, we may collect:

Category 1 - Exam Response Data

• The Participant’s full name, email address and phone number, group name that the company associates with the person, tags, notes taken about the person and similar
• The Participant’s answers to exam questions
• Selected options
• Matches made
• Written texts
• Saved images and videos (camera, microphone, screen)
• Any type of file uploaded (including image, video, document files)
• All results obtained from the exam (general results, section results)
• Information such as browser, operating system and IP from which the exam was accessed
• All logs recorded during the exam
• Flow records such as navigation, viewing and answering within the exam
• Technical information, such as Internet Protocol (IP) address, login information, browser type and version, screen resolution, time zone setting, browser plug-in types and versions, browser access, operating system, platform and traffic data, cookies data, web logs and other communication data.

Category 2 - Supplementary Test Taker Data

• Camera and screenshots captured of the Participant or its mouse movements, that are not within the scope of Category 1 data, shortly before, during and after the exam (Monitoring/Proctoring files)
• Any files, pictures taken or uploaded by the Participant, that are not within the scope of Category 1 data, before, during or after the exam. (Pre-start submissions)

If you get in touch with us via email, phone, post or other form of communication, we may keep records of those correspondences and their content in order to be able to respond to you or document your complaint.

If you are a Customer we may also collect:

• Registration information: When you register for an account, we collect your first and last name, username, password and email address.
• Billing information: If you make a payment to TestInvite, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number).
• Account settings: You can set various preferences and personal details on pages like your account settings page.

If you supply us with personal data about other people (for example if you are a representative from a Customer providing information about the Participant, you represent that you have the authority to provide this information on their behalf, that they have provided informed consent to such disclosure and you should direct them to this privacy notice.

How do we use the data we collect?

We will collect, process and store the personal data we have collected for creating and updating:

• Information about your organization (User profile & Billing information)
• User accounts (Customers/Participants)
• Question Bank
• Tests (i.e. Exams)
• Tasks (Welcome pages, instructions etc.)
• Information about Participants (students, candidates, employees etc.)
• E-mail templates
• Answers given during the examinations

The personal data collected will be further processed for:

• Proctoring media materials collected during the exams
• enable you to access and use the Website, when signing up and during subsequent visits;
• to prevent you from navigating away from the test window while an exam is ongoing;
• contact you when necessary and respond to your requests and enquiries;
• provide technical assistance, troubleshooting problems, detect and protect against error;
• market products and services to you, provided that, where required, we have obtained your consent to do so;
• fulfill legal and regulatory requirements;
• detect and prevent fraud, suspicious activities, and other illegal activities;
• analyse and improve products and services, collect feedback, enhance the Website, and evaluate the effectiveness of our marketing activities and overall services;
• perform statistical analyses on users of the Website and track your use of the Website; and
• on an aggregated and anonymised basis, share the data and statistical analyses with our Customers.

We do not sell your personal data. We may disclose your personal data:

• to our Customers for the purpose of exam administration;
• to our marketing partners, where you have opted-in to sharing for marketing purposes;
• to the extent required by law or regulation or as requested by a court or regulatory authority in connection with law enforcement;
• in connection with any current or prospective legal proceedings;
• in connection with a sale, merger, acquisition, or other transaction affecting the associated business; and
• to our third party service providers, such as:
• Google Cloud
• Personal data processed: contact details, proctoring media materials, answers given in an exam.
• Purpose: Used for administering exams
• Place: United States
• Mailgun Technologies, Inc.
• Personal data processed: contact details, e-mail content.
• Purpose: Used for sending e-mails
• Place: United States
• Tawk.to Inc.
• Personal data processed: contact details, chat logs.
• Purpose: Customer support
• Place: United States
• Google Analytics
• TestInvite uses software such as Google Analytics to help understand use of our Services. Google Analytics collects information sent by your browser as part of a web page request, including cookies and your IP address. Google also receives this information and their use of it is governed by their Privacy Policy.
• Place: United States

The above third parties to whom we disclose information are certified EU – U.S. Privacy Shield organisations.

All third parties to whom we disclose personal data are required by law and/or contractual requirements to keep your personal data confidential and secure.

International Transfers

The Website is hosted on Google Cloud and all its data are stored in the United States. TestInvite uses the following service providers (all in US) in order to store its data:

• Google Cloud Firebase Hosting in US Region
• Google Cloud Firestore Database in US Region
• Google Cloud Functions in US Region
• Mailgun Technologies, Inc. (San Antonio, Texas, United States)

Therefore, personal data collected by TestInvite worldwide (including within the E.U. and Switzerland) may be transferred to the United States for processing. By using TestInvite’s services or submitting personal data to TestInvite, you consent to the transmission of your information outside your own country.

All companies listed above are certified EU – U.S. Privacy Shield organizations.

Following Shrems II decision of the European Union Court of Justice dated 16 July 2020, international data transfers we make within its scope are made within the framework of standard contractual clauses. These terms are available in the Data Processing Addendum on the Website.

Security Measures

We follow industry best practices in information security. We implement security measures appropriate to the size and nature of our business, all with the aim of keeping your personal data safe and secure.

Physical Security

TestInvite uses cloud services for its operations. The physical facilities where TestInvite is located requires an RFID chip to gain access.

Information Access

Employees only have access to data contained in business applications on a 'need-to-know' basis. Privileged users are granted on a 'need-to-access' basis.

Endpoint Security

TestInvite uses Sophos for end-point security and protection against viruses and ransomware. All devices are encrypted with a remote swipe enabled should the device be lost or stolen.

While we take reasonable precautions to protect your personal data from loss, unauthorized access, disclosure and destruction, no method of transmission over the Internet, or method of electronic storage is 100% secure and therefore we cannot guarantee its absolute security.

Your Rights

TestInvite processes personal data on the following legal bases: (i) performance of TestInvite’s contractual obligations with the Customer, (ii) TestInvite’s legitimate interest, and (iii) compliance with law.

In many cases you should contact the Customer directly to exercise applicable privacy rights as they are the data controller. If you contact us directly, we may remove or update your information within a reasonable time and after advising the Customer of your request.

If our processing is based on your consent, you have the right to withdraw consent at any time.

Deletion of personal data

We delete personal data of Participants as soon as reasonably practicable and in any event within 21 days from the date of our Customer’s written request.

Unless our customer contract requires otherwise, or a written request for deletion is made, we keep:

• Supplementary Test Taker Data (as detailed above) for up to 1 year from date of collection; and
• any other form of Customer Personal Data including Exam Response Data (as detailed above) for up to 5 years from the date on which the Customer ceases to be a Customer

and then delete it permanently (without an obligation to provide notice).

TestInvite determines who has ceased being a Customer in its entire discretion taking into consideration customer engagement. Unless material evidence to the contrary, a Customer shall be deemed to have ceased being a Customer if it has not engaged in a financial transaction with TestInvite at least once on a 1 year rolling basis.

This is subject to compliance with document retention laws and TestInvite’s regulatory obligations as detailed in this Privacy Policy or the Data Processing Addendum (as applicable).

Cookies Notice

A cookie is a small text file (usually smaller than 1 kB) that is saved in your computer and stores information. Cookies are used to improve a website for the use, among other purposes.

The Website uses the friendly version of cookies, so-called session cookies. When you are surfing a web page, session cookies are sent between your computer and our server to enable them to exchange information.

• Session cookies are stored on your computer.
• There are safety settings on most browsers that can de-activate session cookies. Usually you can also remove any session cookies that have already been saved.
• If you choose not to accept session cookies on our Website, this may prevent you from taking full advantage of the Websites’ features.

When visiting the Website, your IP address is automatically registered to measure the visit frequency and we or our authorised service providers may use cookies for storing information to help provide you with a better, faster and safer experience and for marketing purposes.

Changes to this privacy policy

TestInvite may occasionally update this privacy policy and the cookies notice. When it does, it will also revise the Effective Date at the beggining of this policy. We encourage you to periodically review this privacy policy to stay informed about TestInvite’s collection, use, and disclosure of personal data. TestInvite reserves the right, at its discretion, to change, modify, add, or remove portions of the privacy policy, cookies notice and the Website at any time.

Contact Information

If you have any questions or comments about this privacy policy, please write by email to info@testinvite.com or by postal mail to Vanilya Elektronik Hizmetler ve Bilişim Tic. A.Ş. at Esentepe Mah.  Kore Sehitleri Cad. No: 29, Zincirlikuyu, Şişli, Istanbul, Turkey.