Privacy Policy

KCTEK Arge Bilişim ve Enerji San. ve Tic. LTD. ŞTİ (“True”, “Company” or “we” or “us” and/or “our”) takes the privacy of all its stakeholders seriously. For this reason, we have set the following privacy policy:

Welcome to Verificent’s Qulak qproctor Testing Platform (“Platform”), providing authentication and test surveillance services. This policy policy (“Sites”) reviews Verificient-driven policy regarding the site and all related websites (“Sites”), networks, applications, and by individuals, use, and if anything. Ancillary services by us (collectively the “Services”), including the Platform. Bu politika aracılığıyla, kişisel bilgileriniz çerçevesinde bilgilendirilir.

The terms of this policy apply to you and your relationship with us, unless your sponsoring institution or organization sets out separate terms and provides you with these terms in writing or we provide you with different terms in writing. Please take the time to familiarize yourself with this Policy and if you have any questions, please contact us at privacy@vericificient.com. This policy is included in and is governed by our Terms of Service.

Definitions:
Test Sponsor – Organization or academic institution that requires Authentication and a high level of confidence that there is no breach of test integrity.
Data Controller – Organization or academic institution that requires the collection of their users’ data to ensure high integrity of their online credentials. The requirements for the test sponsor to maintain a high level of test integrity are determined by the organization or institution. These high standards of authentication are often outlined by federal guidelines and are required for federally funded Title IV financial aid such as the Federal Pell Grant, the Federal Additional Educational Opportunity Grant, the Federal Perkins Loan, and the Federally Subsidized and Unsubsidized Direct Loans.
Data Processor – Acts as data processor for Verificient and its products (Qulak qproctor, Remotedesk), Test Sponsor and Data Controller. Processing includes authentication and ensuring that there are no difficulties with the testing policy outlined by the Test Sponsor and Data Collector. Verificient temporarily stores data in high-level encrypted data cloud storage facilities and destroys the data after it is sent (according to the specified Data retention period).
Services We Provide
We provide Services on behalf of our Clients, Test Sponsors. These may be any institution, organization or unit of which you are a member (in any form, including but not limited to a user of its services), or applicant or registered (“Test Sponsors”). Test Sponsors are organizations, educational institutions or companies that offer and control any test used to make certification, licensing or other types of decisions based on test results. We collect and/or receive personal information about a test taker in order to develop, administer or supervise a test for a Test Sponsor. “Personal Information” is any information, such as name or email address, that identifies or can be used to identify an individual to whom such information belongs to or is associated with. While providing Personal Information is optional, you must obtain the grades, test scores, service or credentials you seek from your Test Sponsor. We will first of all handle and treat Personal Information collected or received in the course of providing our Services, consistent with any binding agreement we have with your Test Sponsor. In the absence of a binding agreement, we will treat and handle your Personal Information in accordance with this Policy and applicable law.
This Policy explains how we collect, use, store and share information about you in connection with your use of the Services.

Information We Collect
Personal Information you provide through the Services: We collect Personal Information (according to requirements set by your Test Sponsor) after obtaining consent from you, the user, for example:
• Start Services from your learning management system;
• Register and/or login to the Platform; ask for customer support, demo or more information;
• Contact us via email or social media sites;
• Provide biometric data to create your identity profile, including as part of participating in the Services; or take a test using our Services.

Personal Information collected through our Services may include:
• Name
• Photo of identity document such as driver’s license
• Your photo
• Phone Number – (used for technical support only)
• Name of the Test Sponsor(s) (ie the educational institution(s) you are enrolled in) and course test information
• E
• Test submissions
• Screenshots
• Audio and video recordings that you entered in the tests
• Room scan – scan of the test room environment
• Biometric data: Face and optionally Knuckle voice scanning, which can be considered as biometric information in certain regulatory regimes
• Hardware and software details (background process list, system configuration information, etc.)
• Chat history between you and supervisors or other customer support personnel.
Ensure that actual data collected is limited to categories (other than the above) agreed with your Test Sponsor based on oversight requirements. You can contact your Test Sponsor’s (school or organization) Privacy Officer for details.
Information Provided by Test Sponsors: To enable our Services, your Test Sponsors may provide the following information,
• İsim
• E
• Government-issued ID number or relevant details
• Learning Management System User ID

We may collect information about you from Test Sponsors, such as your email address, to provide you with a registration link to our Services. This information may also be combined with Personal Information collected from you.
Information that may be required but not stored: Depending on the Test Sponsor’s configuration of the Services, you may be required to provide the following information that is not stored on our System:
• Payment: We do not collect and store Credit Card Information. Some Test Sponsors may require test takers to pay their own surveillance. “Stripe” is used as a third-party payment gateway. Credit card information and address will be required to complete payment with Stripe (only if you need to pay us directly), we do not collect or store credit card information.
• Date of Birth (DOB): We do not collect and store DOB records. With some Test Sponsors, the DOB may be required for verification purposes only at registration.
• Keystrokes: We do not collect and store Keystroke Data. We can detect and restrict only certain keystrokes to facilitate testing requirements.

Cookies and Other Tracking Technologies:
We use various technologies to collect information, including cookies. A cookie is a small file placed on your device. Across the web, cookies do many different jobs, such as allowing you to navigate between pages efficiently, storing your preferences, and generally improving your experience on a website. Cookies make the interaction between you and the website faster and easier. If a website does not use cookies, it will think that you are a new visitor every time you navigate to a new page on the site – for example, when you enter your login information and switch to another page, it will not recognize you and cannot keep you logged in.
Our Services use cookies and similar technologies, such as web beacons, to identify your device and enable our features to work, including account sign-in, authentication, security, preferences storage, performance optimization, and data analytics.
If you do not want to receive cookies, you can change your browser settings. If you use our Services without changing your browser settings, we will assume that you agree to receive all cookies on Company websites. Please note that our Services will not function properly without cookies.
Our services may use two types of cookies, session and persistent. A session cookie expires after a certain amount of time, normally when you close your web browser. A persistent cookie remains after you close your web browser and may be used on subsequent visits to our Services to allow us to recognize you as an existing user.
When you interact with our services, we record and store certain information in log files. This information may include IP address, browser information, device information, internet service provider, operating system, date/time stamp, and other system configuration information. We and our analytics providers also collect and store analytics.

How Do We Use Your Personal Information?
qulak does not share or sell any information (including user data) to third parties.
We generally use your Personal Information as a data processor on behalf of Test Sponsors in accordance with their needs to provide, improve and develop our Services. We do not use your Personal Information for any purpose other than providing online integrity as defined by your Test Sponsor. For example, we use your Personal Information to enroll you in a test, answer technical support questions or concerns you may have, administer the test, and/or communicate test integrity results. We may also use your Personal Information to contact you about timing, technical, security or other testing-related matters, or to contact you for other administrative purposes such as customer service. We use the biometric data we collect from you at sign-in for the Services to create your identity profile for the Services and to verify your identity when you take a test.
To Who We Disclose Your Personal Information
When you take an exam using the Services, we provide your Personal Information to the Exam Sponsor(s) for whom you have requested a test score, service or credential to enable them to verify your identity and test score academically. for hearing purposes. For more information on how your Test Sponsor(s) may use your Personal Information, please contact your Test Sponsor(s).
We may also disclose your Personal Information in the following situations:
• When we believe it is reasonably necessary by law and regulation or in response to a subpoena, court order or other legal process.
• To protect against misuse or unauthorized use of our Services, or to maintain the safety or integrity of our Services or any facility or equipment used to make our Services available.
• To limit our legal liability and protect our property or other legal rights or the rights of our Test Sponsors and test takers.
• Addressing actual or suspected fraud or other illegal activity.
• In the event of any merger, sale, acquisition, bankruptcy, liquidation or transfer of other assets involving the company, your personal information remaining on the company’s servers at that time may be transferred to and/or managed by the Company. the acquiring company or organization.

We may also ask for your consent to the disclosure of additional information, including your Personal Information, and we will only share it as disclosed to you.
Data security
We take the security of your Personal Information seriously. We use industry standard practices to protect your Personal Information in accordance with this Policy and applicable laws. However, you should be aware that we do not control the security of your own equipment or your own network connection and therefore any information you transmit to us through the equipment you use or internet connection is at your own risk.
Data integrity
We take reasonable steps to ensure that the data we collect is reliable for the intended use. However, it is your responsibility to update us with relevant changes to your personal information so that we can provide you with our Services. We collect Personal Information about the purposes for which it will be used. We also take reasonable steps to ensure that we process Personal Information consistent with the purposes for which it was collected.
Data Retention and Deletion
By default, data collected from supervised activities (including biometric data) is retained for up to 180 days after a supervised testing session, and your identity profile and data collected for authentication purposes (including the biometric data we use to create your identity profile) are retained for up to one year from the time the identity profile is created on our Platform. is stored.
However, your Test Sponsor has the ability to configure a custom data retention period according to their needs, which will always take precedence over our default data retention period.
After the applicable retention period, we will automatically clear (delete) your Personal Information from the Platform and our systems and retain only the minimum amount of data required for billing and necessary business purposes and legal compliance – this is minimal in most cases. , Anonymous data is stored in an anonymized form to show specific session details such as date, time, duration and volume of sessions that took place. After the retention period, your Test Sponsor will only receive your data if it has been exported and stored from our system.
As described above, we offer our Services as a processor on behalf of Test Sponsors who have the right to receive your data (for example, for academic hearing purposes). We do not control what Test Sponsors do with your data. Test Sponsors have their own policies regarding data retention and deletion. For this reason, we have set the following privacy policy: