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General Data Protection Notice

This General Data Protection Notice (‘the Notice’) explains how we collect, use, and store personal data in as clear and transparent way as possible, as well as details on your rights under the applicable data protection laws. Your privacy and personal information are important to us and we are committed to keeping it protected.
Should any questions or concerns occur, you can get in contact with us using the contact details provided herein.

Who are we and whose personal information do we collect?

When we refer to “we”, “us” and “our” in this Notice, this means Examus Inc., Examus OÜ, and their affiliated companies.
When we say “you”, “your” and “individuals” in this Notice, we refer to anyone whose personal information we may collect, including:

anyone seeking a service quote from us or whose details are provided during the quotation process; and
anyone who may uses our proctoring and other services.

How do we use personal information?

We use personal information in the following ways:

to provide quotes, to present our services and to fulfil our contracts;
to manage our business, conduct market research and manage our relationships with business partners to meet the legitimate needs of our business;
to send marketing information about our products and services if we have received your specific consent or in specific situations based on our legitimate interest;
to identify students and analyse their behaviour using remote control systems during taking oral and written exams;
to analyse audience’s reaction to videos posted on various online services.

There is no obligation to provide us with personal information, but we cannot provide our products and services without it. In the specific case we use an individual’s personal information to market our products and services, it is done only upon receiving their consent or based on our legitimate interest. Our marketing activities may include:
Providing information about products and services by telephone, post, email, and SMS: We will either do this ourselves or use third-party partners to do it for us.
Working with selected partners to display relevant online advertisements on third-party websites and social media platforms: To do this, we may provide our partners with an individual’s personal information in an encrypted format, which they use only to identify the appropriate audiences for our advertisements. We ensure that our partners delete this information once the advertisement audiences have been identified, and do not use the information for their own purposes.

If you do not wish to receive marketing information about our products and services, you can tell us at any time by using the contact details found in Section ‘Know your rights’.


What personal information do we collect?

The information we collect will depend on our relationship with you.
To complete the activities listed in Section ‘How do we use personal information?’, we collect the following types of personal information:
full name, e-mail, photo image, photo of an identity document (e.g., passport), age, gender, contact details like job title, company, etc.;
financial details such as direct debit or payment card information;
photographs and/or videos, including during demo sessions;
business activities such as provision and support of our services, etc.;
facial recognition, identification by photo.

When we provide you with demonstration of our services, we may use special category of personal data and more specifically - biometric data (e.g., facial recognition data, facial expression tracking data), which can be processed only based on your explicit consent.

How do we collect personal information?

We collect personal information directly from individuals, their representatives or from their proctoring sponsors (schools, universities, employers, etc.).

We may collect personal information from other persons or organizations whereas embedded functionality ensures the login and registration processes for users to access portions of our website(s) and other functions and features provided by us.

We also collect information from your computer in the form of cookies. For further information, please refer to our Cookie Policy accessible at https://examus.com/cookies-policy.


When do we share personal information with third parties?

We only share your information with third parties when absolutely necessary for the purposes stated in Section ‘How do we use personal information?’.

We may share personal information with:
our approved service providers, e.g., cloud service providers, developers and proctors;
external agencies for market research purposes;
any organization (such as school, university, employer, testing facility, etc.) you have agreed to disclose personal information to as part of the terms and conditions you have agreed with them, that is using our products and services to facilitate applicable proctoring or other related activities; as well as any corporate and university clients who have used our system to deliver exams to their job or student candidates. Personal information and exam information are never disclosed to candidates or unauthorized thirds parties, unless required by law;
affiliated companies in the event we sell or part of our business.

However, as our services are offered around the world, we take special care to comply with the respective regional legislation. With respect to that, we store data of citizens of the European Union on servers located in the territory of the European Union, and we ensure the same level of compliance with all our suppliers via dedicated data protection agreements and regular data protection audits.


How long do we keep your personal information?

We will not retain your personal data for periods longer than it is necessary for the provision of our services and we will keep it only for the purposes for which it was obtained.

Personal data collected during demonstration session of our products is being stored for not longer than 7 days.


Know your rights

You may access the information we hold about you. If you would like to update, correct, modify, or delete from our database any personal data you previously submitted to us, please let us know. Please note that if you request to delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain personal data in our database whenever we are required to do so by law.

Please note that we need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you initiate a service, you may not be able to change or delete the personal data provided until after the completion of the service). We will retain your personal data for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.

If you are a United States client and you wish to exercise any of these rights, you can do so by contacting us using the contact details below:
Email: query@examus.com
Address: Examus Inc., 2150 Shattuck Avenue, Penthouse, Suite 1300, Berkeley, California 94704, USA

Data subjects’ rights under the European data protection legislation (applicable for European customers only)

If you are a resident of the European Union (EU) or the European Economic Area (EEA), you can exercise certain rights with respect to the information we process in our capacity of a data controller of their personal data. If we are processing your personal data on behalf of another data controller and you exercise your rights before us, we will forward your request to the responsible data controller.

You, as an individual whose personal data is being processed, have the following rights:
the right to object – individuals can object to us processing their data and we will either agree to stop processing or explain why we are unable to;
the right of access – individuals can request a copy of the personal information we keep for them, subject to certain exemptions (via a subject access request);
the right of rectification – individuals can ask us to update or correct their personal information to ensure its accuracy;
the right to be forgotten – individuals can ask us to delete their personal information from our records if it is no longer needed for the purposes it was obtained;
the right of restriction – individuals can ask us to restrict the processing of their personal information in certain circumstances;
the right to data portability – individuals can ask for a copy of their personal information in a machine-readable format, so it can be used for their own purposes;
the right to withdraw consent – individuals can ask us, at any time, to stop processing their personal information, if the processing is based only on the individual’s consent;
the right to make a complaint – individuals can complain if they feel their personal information has been mishandled. We encourage individuals to come to us first, but they are entitled to complain directly to the Estonian Data Protection Authority as well, by using the following contact details: info@aki.ee, or visiting the website http://www.aki.ee/.

If you wish to exercise any of these rights, you can do so by contacting us using the contact details below:

Email: gdpr@examus.net
Address: Examus OÜ, Estonia, Tallinn, Kesklinna linnaosa, Narva mnt 5, 10117
or by getting in contact directly with our Data Protection Officer at
Email: anton.ivanov@libreresearchgroup.org


This General Data Protection Notice was last updated оn 1st March 2021.
Occasionally it may be necessary to make changes to this Notice. When that happens, we will provide an updated version at the earliest opportunity. Any subsequent changes shall be effective from the date indicated with the corresponding amendments.



Contact information
Address: Examus OÜ, Estonia, Tallinn, Kesklinna linnaosa, Narva mnt 5, 10117
or by getting in contact directly with our Data Protection Officer at
Email: anton.ivanov@libreresearchgroup.org

gdpr@examus.net

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