Internet Testing Systems – EU Privacy Policy

Internet Testing Systems – EU Privacy Policy

Internet Testing Systems understands the importance of assessment data security and takes its responsibility to protect stakeholder data seriously. The following policy outlines the steps we take to ensure data security.

 

EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF

Internet Testing Systems complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Internet Testing Systems has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.

 

Standard Contractual Clauses

Internet Testing Systems has Standard Contractual Clauses (SCCs) in place with our partners for delivery of exams in the European Union and the United Kingdom and the transfer of data for those exams. The SCCs ensure all data processing activities undertaken by Internet Testing Systems comply with the requirements of the assessment sponsor. They also ensure compliance with assessment sponsor data security requirements with respect to the collection, processing, and retention of personal information.

 

Data protection

Internet Testing Systems maintains industry recommended physical and electronic security measures to ensure appropriate use of information and protect against data loss. Internet Testing Systems also maintains regularly reviewed security policies and conducts regular security audits.

 

Information we collect for assessments

Internet Testing Systems provides assessment services for assessment sponsor partners. The assessment sponsor is the company or organization that owns the assessment content and data. Assessments, including surveys, quizzes, and tests, are delivered on Internet Testing Systems servers.

Assessment sponsors determine the information to be collected as part of the assessment process. This often includes demographic information. Internet Testing Systems also collects your IP address, login information for the purchase site, purchase information, and connection information, including browser type, browser version, operating system, platform. Internet Testing Systems also uses cookies to ensure a positive assessment experience.

Internet Testing Systems uses this information and data internally to deliver the assessment, analyze the outcome, and provide reporting. This information is shared with the assessment sponsor.

If you use Internet Testing Systems software to create content, information and data is treated the same way as it is when taking an assessment.

By taking an assessment or using content creation software provided by Internet Testing Systems you agree to information and data being transmitted to the applicable assessment sponsor. Assessment sponsors have their own privacy policies, so please reference those for any additional use cases for information and data beyond transmission between Internet Testing Systems and the assessment sponsor.

 

Information we collect for purchases

Internet Testing Systems provides product catalog services to some of our assessment sponsor partners. The assessment sponsor is the company or organization that owns the assessment content and data.

As part of the purchase process, you enter various information, including name and contact information. Internet Testing Systems may also collect your IP address, login information for the purchase site, purchase information, and connection information, including browser type, browser version, operating system, platform. Internet Testing Systems also uses cookies to ensure a useful website experience.

Internet Testing Systems uses this information internally to associate products and assessments with your user profile. We also share this information with the assessment sponsor as required.

If you use a credit card to make your purchase, Internet Testing Systems does not retain a copy of the card number. A secure credit card handling service is used to process the transaction.

You can always choose not to provide information. However, if you choose not to provide essential information you might not be able to make an online purchase.

 

Testing and quality assurance

Internet Testing Systems requires information and data for internal quality assurances purposes. All information and data used for quality assurance is scrubbed of all personally identifiable information before it is used for these purposes.

 

Data transmission

Information and data collected by Internet Testing Systems may be transmitted around the world. Data is only shared with assessment sponsors, but those sponsors may be in the United States or many other countries. By taking an assessment, creating content with our software, or purchasing products through our catalogs you are consenting to this transmission..

 

Identity of third parties to which personal information is disclosed

Internet Testing Systems does not sell or rent any personal information or data that it collects. Information and data is only shared with the assessment sponsor. Internet Testing Systems does not currently transfer personal data, received pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, to third party agents. However, if personal information of European Union and the United Kingdom individuals is transferred to third parties in the future, Internet Testing Systems is potentially liable.

 

Choices and means offered to individuals for limiting the use and disclosure of their personal data

Internet Testing Systems only collects data as required by the assessment sponsor. As such, all data collected is required to administer an exam, so users who do not wish to provide the data will not be able to sit for an assessment. A user may elect to request the removal of all data collected in conjunction with an assessment after the assessment has been given.

 

Requirement to disclose personal information in response to lawful requests by public authorities

Internet Testing Systems is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Internet Testing Systems will cooperate with disclosure of data only in response to a subpoena, court order or legal process, to the extent permitted and required by law, and to the extent agreed upon with the assessment sponsor.

 

Investigatory and enforcement powers of the Federal Trade Commission (FTC)

Under this agreement, Internet Testing Systems is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

 

Right of individuals to access their personal data

You may request your personal information for review or to correct or delete any information Internet Testing Systems retains about you by sending an email request to privacy@testsys.com.

When submitting your request, please clearly list all information you would like to review, correct, or delete, along with the assessment sponsor if it is known. European Union and the United Kingdom individuals have rights to access personal information stored about them and to limit its use and disclosure. Internet Testing Systems will respond in accordance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

Internet Testing Systems maintains information and data as requested by the assessment sponsor, which is usually indefinitely. Internet Testing Systems will act in good faith to provide information we have. This privacy policy only applies to information held by Internet Testing Systems. Information transmitted to assessment sponsors or held by other content owners is not covered in this policy, so privacy policies for assessment sponsors should be reviewed to determine access policies for those sponsors.

If you are a parent or guardian of a minor that you believe has information or data held by Internet Testing Systems, please contact us as privacy@testsys.com.

 

Enforcement

Internet Testing Systems is committed to the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF and to obtaining a fair resolution to any complaints or disputes. Please contact us at privacy@testsys.com with any questions, concerns, or disputes. We will respond to your request within the scope of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF within 60 days.

Individuals in the European Union and the United Kingdom may report privacy complaints to their local Data Protection Authority in the event the response from Internet Testing Systems does not resolve their dispute.

 

Right to invoke binding arbitration

If all other dispute resolution mechanisms have been exhausted, individuals may have the right to initiate binding arbitration with regards to this policy, as set forth in Annex I of the DPF Principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

 

Alternative Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Internet Testing Systems commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS are provided at no cost to you.

 

Changes to this privacy policy

Internet Testing Systems reserves the right to change or modify this privacy policy at any time. If the policy is changed, the new version will be posted to our website and the last modified date will be updated.

Last updated: September 2023