Inspera AS and subsidiaries (“Inspera”, “we”, “us”, “our”) are committed to protecting and respecting your privacy.
As we provide identity solutions and integration, we also comply with the GÉANT Data Protection Code of Conduct as a requirement for managing identities.
1 Inspera as the Data Controller
2 Why we collect personal data and legal basis for processing
Personal data is information about you that can be used alone, or combined with other information, to identify you personally. Personal data is a broad concept and includes a wide range of information, such as name, email address, mailing address, IP addresses, and cookie identifiers. Personal data does not include information that has been anonymised so that it does not allow for the identification of a specific individual.
We collect personal data to deliver our Site and Services and provide you with the best experience with Inspera for the following purposes:
- Use of the Inspera Assessment cloud-based application (SaaS) and associated services
- Provide customer support, marketing information and customer relations
- Employment or potential employment as a part of our digitised recruitment process
We rely upon the following legal basis for processing the personal data we collect from you when providing you with access to the Site and Services:
- Our legitimate business needs.
- To fulfil our contractual obligations to you.
- To comply with our legal obligations.
To the extent we process your personal data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.
3 What personal data we collect from you
You may give us information about you by filling in forms on our Site or by corresponding with us by phone, email, or otherwise. This includes information you provide when you register to use our Site, apps, subscribe to our services, or use our remote proctoring services (“Services”) or newsletter, search for a product, place an order on our Site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, and when you report a problem with our Site or Services. In particular, we collect the following information from you:
3.1 Subjects under the age of 18
Inspera does not collect information from or about people under the age of 18.
3.2 Use of Inspera Assessment
The Inspera Assessment cloud service (SaaS) collects information about all users including:
- End-user full name
- Password of end-users
- Email address of end-users
- National identification or social security number of end-users
- Student identification number of end-users
- Programme of study, location, cohort, study mode, grade level of end-users
- Identifying information from 3rd party authentication or authorisation services
- Metadata related to test events (including work assignments for administrative users)
- Test submissions including questions and answers
- Marking and annotation of test submissions
- Feedback to the test-taker
- Internal comments between marker within the system (not published to test-taker)
- IP address of end-users
- Event log of administrative actions
- Event log of test-taking actions
- Process monitoring when using Bring Your Own Device (BYOD) to prevent cheating
The information is collected through the Inspera Assessment web application, client browser, and the Inspera Secure Exam Browser.
3.3 Customer Relation Management
If you are an existing customer, previous customer, or potential customer, we collect information relevant for customer relation management and billing purposes. This includes full name, job title or function, organisation, email, phone numbers, and company addresses.
The information is collected through email, web forms, and other means of communication with Inspera.
3.4 Recruitment Process
In the online recruitment solution, we collect information relevant for any job application. This includes name, email address, date of birth, home address, phone number, profile photo and resume.
The information is collected through the online recruitment solution Homerun used by Inspera.
3.5 Remote Proctoring Services
If you choose to take part in an online test where remote proctoring is used, we may collect the following information, which includes biometric data.
a) Pre-Test Identity Checking
Before you start a test, we will match the facial image of the person in front of the camera with an approved form of picture ID. This is to ensure that the person in front of the camera is the person that is registered to complete the test.
The information collected includes biometric data and shall include facial data and anything that can and will be captured by your device’s camera, microphone or whatever is shown on the device screen. This data is stored in audio video recordings which are associated with a unique candidate and session ID.
b) Test Session
During the test, we will continue to capture audio and video from your device’s camera and microphone along with a capture of the screen of the device used for the test. The audio and video information collected is stored securely by us until the final grade of your test is awarded. The audio and video recordings are not a part of the exam itself and do not influence your grade. The recording is only used to prevent cheating, investigate fraudulent activities, and to ensure that the individual taking the exam is the actual, registered test person.
The information that is collected includes personal data:
- about your identity before you start the exam; and
- during the exam, your entire testing session in real-time is monitored and recorded over the Internet through your device via your webcam and microphone so that your face, voice, desk and workspace will be captured, and a recording will be made of these images for the purposes of test security and the integrity of the testing process.
The collection of such information is optional, but necessary if you choose to use our online testing function.
c) Purposes for which we collect Personal Data for Remote Proctoring
All video and audio recordings and biometric data are used for the purposes of:
- identity verification
- conducting the test
- security and integrity of the test and testing process
- incident resolution, such as fraud prevention
d) Sharing of Remote Proctoring Data
Where you choose to participate in an online test, we shall monitor you remotely while you participate in a test session.
The video and audio recordings are only used if there is a legitimate suspicion of cheating, and the data is only stored by us. We may at any time review recordings if concerns are raised by your educational institution who asks us to carry out the online test.
We may disclose information, including the video and audio recording of your test session, which includes special category data, to your educational institution for the purpose of your educational institution verifying that you were the person taking the online test and to check that no test protocols were breached, where the suspicion is justified and after we have reviewed the recording ourselves.
Immediately after your final grade has been awarded, all recordings are automatically deleted, unless there is an ongoing investigation into any recording.
3.6 Information we collect automatically about you
Regarding each of your visits to our Site, we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information from other online accounts to which you have given us permission to collect data from within your settings or the privacy policies of these other online services. For example, this can be via social media or by choosing to send us your location data when accessing our Site from your smartphone; or it can be from the integrations and connections that you choose to install when using the Services.
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site.
We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
4 How we use your personal data
4.1 We use information you give to us:
- to provide and improve our products and services
- to perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research, evaluating your suitability for employment opportunities, and providing customer support.
- to carry out our obligations arising from any contracts entered between you and us.
- to provide you with the information, products, and services that you request from us
- to notify you about changes to the Site and Services.
- to ensure that content from our Site and Services is presented in the most effective manner for you and for your computer.
- to provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- to permit selected third parties to contact you by electronic means only if you have consented to this by ticking the relevant consent box situated on the form on which we collected your data.
- to continually improve our products, including adding new features or capabilities.
- to evaluate your suitability for employment or recruitment opportunities.
- as required by applicable laws and regulations.
- to communicate with you and personalise our communications with you.
4.2 We use information we collect about you:
- to develop aggregate analysis and business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business.
- to diagnose product problems and provide other customer care and support services.
- to administer our Site and Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to inform you about scheduled downtimes and new features.
- to improve our Site and Services to ensure that content is presented in the most effective manner for you and your computer.
- to allow you to participate in interactive features of our service when you choose to do so.
- as part of our efforts to keep our Site and Services safe and secure.
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- to make suggestions and recommendations to you and other users of our Site or Services about our goods or services that may interest you or them.
4.3 Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We will not sell or rent your personal data to anyone.
4.4 Automated decision making
The Inspera Assessment cloud service (SaaS) uses technology to support the invigilators in the marking and grading. This includes semi-automated and automated analysis of the submitted exam and is reviewed by the invigilators responsible for the grading before the grade is final.
4.5 Marketing Communications
We will send you marketing emails if you “opt-in” to receive marketing emails when registering on our Site or if you have enquired about, or purchased, any of our goods or services.
Please note, if you change your mind about being sent marketing emails, you can “opt-out” at any time by clicking the “unsubscribe” link at the bottom of any marketing email. Once you “opt-out”, you will no longer receive any marketing emails from us. We will continue to communicate with you regarding your service billing and support via email.
We send push notifications from time to time to update you about any service updates, events, and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
5 Disclosure of your information
5.1 Information we share with third parties
We may share your information with selected third parties including:
- any member of our group, which means our subsidiaries.
- business partners, suppliers, and sub-contractors for the performance of any contract we enter with them or you, namely: Google, Zendesk, Amazon AWS, TrackJS, HubSpot, Atlassian, Deviget, Exswap, and Beetroot.
- authorised resellers of Inspera Assessment for marketing, sales and support purposes.
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 250 men aged over 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women living in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
- analytics and search engine providers that assist us in the improvement and optimisation of our Site and Services.
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering a contract with you.
5.2 Information we disclose to third parties
We may disclose your information to third parties:
- in the event that we sell or buy any business or assets, in which case, we may disclose your personal data to the prospective seller or buyer of such business or assets,
- if we or a member of our group of companies or substantially all of their assets are acquired by a third-party, in which case, personal data held by them about their customers will be one of the transferred assets,
6 Where we store personal data
Our Services are global, and your information (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence.
The personal data that we collect from you may therefore be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the UK. It may also be processed by staff operating outside the EEA or UK who work for us or for one of our suppliers or partners. Such staff or sub-contractors may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA or the UK.
Personal data is not transferred to third parties without proper data processing agreements. This includes:
- Data Processing Agreements (DPA) within the EU/EEA.
- Data Processing Agreements (DPA) with commercial parties in EU trusted countries.
- Data Export Agreements (DEA) with commercial parties elsewhere.
Our Site and Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site or Services from outside the EEA or the UK. This means that where you chose to post your data on our Site or within the Services, it could be accessed from anywhere around the world and, therefore, a transfer of your data outside of the EEA or the UK may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.
7 How we secure your data
All personal data is stored with industry-standard encryption and is transferred over a secure channel using HTTPS and SSL between the service and the client.
For detailed information about security in the Inspera Assessment cloud service, please see our cloud security statement.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site or Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your data transmitted to our Site or the Services. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.1 Links to other websites
Our Site and Services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8 Your rights as a data subject
You have the right under Data Protection Law, free of charge:
- to access your personal data,
- to request erasure or rectification of your personal data,
- to restrict the processing of your personal data,
- to transfer your personal data to you in a structured, machine-readable, and commonly used format,
- to object to the processing of your personal data, and
- to withdraw your consent to us processing your personal data at any time.
Please contact us by email at email@example.com if you want to exercise any of your rights. We will respond to such queries within 30 days and deal with requests we receive from you in accordance with the provisions of Data Protection Law.
9 Data Retention
We usually delete personal data after you have closed your account or ceased using the Services. However, we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements with your, or to fulfil your request to “unsubscribe” from further messages from us.
We will retain de-personalised information after your account has been closed.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the Site or Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
For all other individuals: contact your local data protection supervisory authority in the country in which you are located.
11 Age of Users
This Site and the Services (excluding the Inspera Assessment solution) are not intended for children (persons under 18 years of age), and we do not knowingly collect personal data relating to children.
Where you permit a person under the age of 18 (“Child”) to use the Inspera Assessment solution via your login, you are responsible for taking steps to protect that Child’s privacy in accordance with applicable law, including obtaining consent from the Child’s parents or guardian to the collection of personal data of, or from, the Child.
12 Changes to our privacy notice
13 Contact us
If you have complaints, questions or comments about our privacy practices, please contact us by email at firstname.lastname@example.org or by mail to the following address:
Cort Adelers gate 30
The same addresses can be used to contact our Data Protection Officer (DPO).