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”)
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 please refer to the template Data Processing Addendum available on the Website, which is or as amended is a legally binding agreement between TestInvite and the Customer.
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:
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:
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.
We will collect, process and store the personal data we have collected for creating and updating:
The personal data collected will be further processed for:
We do not sell your personal data. We may disclose your personal data:
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. TestInvite uses the following service providers (all in US) in order to store its data:
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.
In cases where the KVKK (Turkish Personal Data Protection Law) applies, the transfer of personal data provided to us abroad is carried out in accordance with Article 9 of the KVKK by ensuring appropriate safeguards. In this context, the Standard Contract published by the Turkish Personal Data Protection Authority is used.
As of the update date of this Privacy Policy, the following foreign data sub-processors have signed the standard contract, and the application to the Authority has been submitted and the approval process completed:
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.
