Last updated February 1, 2021 (Service providers list, 9.1)
Key changes from the previous version: Terminology alignment with Europe’s General Data Protection Regulation (GDPR) and further clarification of differences between the individually registered user and the user registered through the organisation (1.6-1.7).
Welcome to TrackTest English proficiency tests (the “Service”) provided by the company Tracktest s.r.o. (“TrackTest”, ”us”, “we”, or “our”) via the website https://tracktest.eu.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
1.1 Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
1.2 Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
1.4 Data Controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
1.5 Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
If you are signing up for a specific organisational account or use the activation code (voucher) provided by the organisation, we are a Data Processor of your personal data on behalf of the organisation. The organisation name and logo are displayed before and after the registration in the prominent locations of the website design.
We may also use the services of various Service Providers in order to process your data more effectively.
1.6 Data Subject
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data. The User can be registered as an individual or as a member of the Organisation.
The Organisation (e.g. School, Company, or Reseller) is the administrator of the Service and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your Organisation administrator, as your use of the Services is subject to that Organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Even if the Service is not currently administered to you by an organization, if you use an email address provided by an organization (such as your work or school email address) to access the Service, then the owner of the domain associated with your organizational email address (e.g. your employer or school manager) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.
Organisation administrators are able to restrict your access to and privileges within the respective account. In some cases, enterprise administrators can also:
- reset your account password;
- restrict, suspend or terminate your access to the Services or your account;
- control your ability to edit, restrict, modify or delete account information;
- change your account information, including profile information or the email address associated with your account;
- access information in and about your account;
- access or retain information stored as part of your account.
Please contact your organization or refer to your administrator’s organizational policies for more information. If you feel your personal data are at risk or misused, contact us and we will facilitate the problem with the Organisation.
2. Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
2.1 Types of Data Collected
2.1.1 Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Profile picture
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
2.1.2 Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
2.1.3 Tracking & Cookies Data
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
3. Use of Data
Tracktest s.r.o. uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
4. Retention of Data
Tracktest s.r.o. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
5. Transfer Of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
If you are located outside Slovakia (European Union) and choose to provide information to us, please note that we transfer the data, including Personal Data, to Slovakia (European Union) and process it there.
6. Disclosure Of Data
6.1 Disclosure for Law Enforcement
Under certain circumstances, Tracktest s.r.o. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
6.2 Legal Requirements
Tracktest s.r.o. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Tracktest s.r.o.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
7. Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
8. Your Rights
Tracktest s.r.o. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed of what Personal Data we hold about you please contact us.
In certain circumstances, you have the right:
- To access and receive a copy of the Personal Data we hold about you
- To rectify any Personal Data held about you that is inaccurate
- To request the deletion of Personal Data held about you
You have the right to data portability for the information you provide to Tracktest s.r.o.. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
9. Service Providers
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service. All tools used for analytics are GDPR/CCPA compliant.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
- Heatmap and session recording system (Smartlook, Hotjar, Clarity, or similar)
Heatmap and session recording system may be used by TrackTest for two purposes:
a) General usage: We may record the user actions on the website in order to analyze and improve the usability of the platform or its selected parts. Recording and processing of sensitive information, such as passwords, credit card numbers, form inputs, IP addresses, on-page email addresses, and number values are always disabled for this purpose.
b) Verification of tests taken in the proctored mode: We may record the user actions specifically during their verified exam in order to ensure that the test was taken under fair conditions, without using the not allowed assistance of another person or external tools or websites. These specific actions are recorded only during the verified test itself.
- Sentry is the error monitoring software that helps TrackTest discover, triage, and prioritize software errors in real time. No personally identifiable information (PII) is sent to Sentry.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
10. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
11. Children’s Privacy- Children’s Online Privacy Protection Act
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.