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. (“Test Invite” or “We”)
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”).
Test Invite 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 Test Invite is the “data processor,” as those terms are used in applicable data and privacy laws. In our role as a data processor, Test Invite only processes personal data in accordance with the applicable contract for purposes of providing its exam-related services to its Customers.
What data do we collect?
We may collect the following data (as applicable) from our Visitors, Customers and/or Participants (“You”).
- contact information such as your name, email address, and phone number;
- live video and voice recordings captured for web camera enabled exams;
- live video and screenshot recordings of the screen, mouse movements and details of the resources that you access shortly before and during an exam;
- technical information, such as your Internet Protocol (IP) address, your login information, browser type and version, screen resolution, flash version, 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; and
- any other information you provide to us including any personal data regarding another individual that you provide in the course of using the services;
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 Test Invite, 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 an 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
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.
The Website is hosted on Google Cloud and all its data are stored in the United States. Test Invite 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 Test Invite worldwide (including within the E.U. and Switzerland) may be transferred to the United States for processing. By using Test Invite’s services or submitting personal data to Test Invite, you consent to the transmission of your information outside your own country.
All companies listed above are certiﬁed EU – U.S. Privacy Shield organizations, meaning that the transfers are performed under this legal mechanism for international transfers.
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.
Test Invite uses cloud services for its operations. The physical facilities where Test Invite is located requires an RFID chip to gain 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.
Test Invite 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.
Test Invite processes personal data on the following legal bases: (i) performance of Test Invite’s contractual obligations with the Customer, (ii) Test Invite’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.
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.