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 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.
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:
Google Cloud
Amazon Web Services, Inc.
Mailgun Technologies, Inc.
Twilio Inc.
Stripe Inc.
Tawk.to Inc.
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. 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.
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.
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.
We delete personal data of Participants as below or 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 and delete personal data permanently (without an obligation to provide notice) latest by:
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).
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.
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.
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.
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.
