PERSONAL DATA PROCESSING POLICY

1. Preamble

Assessment Systems International and all companies operating as separate legal entities within the Assessment Systems Group of companies (“ASI”) understand that how information about you is used and shared is important to you and value your trust that ASI will use and share this information carefully and sensibly. One of ASI’s goals is to ensure the security, availability, confidentiality and processing integrity of all information collected. This Privacy Policy applies to all of ASI’s online platforms, including its commercial websites and application products, administrative tools, assessment portals, research and subscription sites. By visiting any ASI website, you agree to the terms set forth in this Privacy Policy.

This Privacy Policy aims to provide you with important information about how we process your personal data when you visit our website and any information based on Regulation (EU) 2016/679 of the European Parliament and of the Council (EU General Data Protection Regulation, hereinafter referred to as “GDPR”).

2. Information processing

ASI collects information and personal data from users when they create an account on the website, request copies of publications or other information about our services or employment opportunities, or when users register for conferences or other ASI-sponsored events. Some ASI forms for registration, login, account setup, etc. may ask for personal information, areas of interest and/or demographic information. ASI may use this personal information (name, home address, email address, phone number, areas of interest, etc.) to customize your user experience on the Website, to contact you as needed, or – as appropriate – to consider applications for employment or qualifications for employment with ASI.

2.1. Visiting and using our website

When you visit our site, we process your technical data for the technical measures of our website, to provide you with information about our services, products and solutions and to understand your interests and needs. We process your technical data in accordance with Article 6 (1)(f) of the GDPR.

2.2. Contact, event registration and free trial logins

If you contact us (using the contact forms on our website), we process your technical data and your contact details where requested (e.g. “Contact us”, “Request a free trial login”, “Event registration”) and allow you to download materials relevant to your needs. We process your technical data in accordance with Article 6 (1)(f) of the GDPR. For a better user experience and communication security we use HubSpot as an independent service provider, more regarding their privacy and data processing policy here:  http://legal.hubspot.com/privacy-policy. We will not process your personal data for longer than necessary and after the necessary period of time your personal data will be deleted from our system and from the HubSpot database (for more information on the length of the data retention period, please contact our Data Protection Officer at:  dpo@asystems.as.

2.3. Careers

If you voluntarily respond to any job offer on our website, we process your contact and technical data and information about your previous jobs (sent directly to our email) to facilitate the recruitment process. We process your personal data in accordance with Article 6 (1)(b) of the GDPR.

2.4 Newsletter

If you give us permission to send newsletters and/or promotional materials (i.e. questionnaires, invitations to seminars, workshops and other events, or other communication activities related to the various services offered by ASI worldwide) to your e-mail address, we process your technical and contact data. You can cancel your consent to receive newsletters and/or promotional materials at any time by clicking on the “Unsubscribe” option in the newsletter or by sending an unsubscribe request to the following email  marketing@asystems.as. We process your personal data in accordance with Article 6 (1)(a) of the GDPR. We use MailChimp to send our email newsletters, more about their privacy policy and data processing here:  http://mailchimp.com/legal/privacy/.

We will not sell, share, share or disclose your personal information to any third party, but we may disclose it to third parties who provide services on our behalf and who need to have access to it in connection with those services. When signing up for our email newsletter, you may choose not to receive our communications where we request information from you. In any event, you may also contact us using the methods listed below.

3. International transfer of information

ASI is an international organization, information collected on our website or otherwise may be transferred from time to time between ASI locations or personnel, including locations outside the European Economic Area, and our website may be viewed and hosted anywhere in the world, including countries that do not have laws governing the use and transfer of personally identifiable information. ASI complies with the requirements of the EU General Data Protection Regulation 2016/679 (“GDPR”) and assures that no personal information of our users will be sent to any third party outside the ASI group of companies unless (a) you have consented to such international data sharing and access, or (b) you have been informed of and consented to the data transfer by reading our Privacy Policy.

ASI and all companies within the Assessment Systems Group are the primary recipients of your personal data. We may share your personal information with third parties who provide administrative, marketing, professional and technical support for the operation of our website, namely MailChimp, HubSpot and Google. ASI and all companies belonging to the Assessment Systems Group may be required to disclose personal information by law or legal process. We reserve the right to notify the appropriate authorities in the event of illegal or unlawful activity on our website.

4. Cookies and other means of tracking

ASI may use browser cookies on our website to track your traffic. A “cookie” is a small amount of data that a web server sends to your browser and stores on your computer’s hard drive. Cookies enable ASI to provide a better and more relevant customer experience. In addition, the use of cookies allows ASI to automate entry into password-protected sections of the website so that whenever you visit our website, you do not have to re-enter your password. We also use cookies to determine which sections of the website are most popular among our users and to gain a deeper overall understanding of our users’ use of the website. In most web browsers, you can delete cookies from your hard drive, set to block all cookies, or have a warning displayed before cookies are placed on your computer. We recommend that you read your browser’s instructions or the help screen; you can also find more information about these features and how to use them. Remember that you may not be able to open certain sections or functionality of the website if your browser does not allow cookies. For more information on the use of cookies, please visit  www.allaboutcookies.org.

Some of the cookies we use are provided by third-party companies, such as Hubspot and Google, through which we obtain analytics and data about our website. These companies have programs that collect information about your interaction with our website, such as what pages you visit, what links you click on, and how much time you spend on our website. For more information on how these companies collect and treat your data, please read their privacy policies.  Hubspot Privacy Policy and Google at Google Privacy Policy. The ASI website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) is transferred to and stored by Google on servers in the United States. Google will only use this information to analyse your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage. Google may also disclose this information to third parties if required to do so by law or if such third parties process the information for Google. Google will not associate your IP address with other data held by Google. By visiting this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information about Google Analytics, please visit:  http://support.google.com/analytics/answer/6004245?hl=cs.

ASI also uses web beacons (including conversion pixels) and other technologies for similar purposes as the aforementioned Google Analytics. We use these technologies on our website, in our newsletters, and/or in promotional materials to determine whether messages have been opened and links clicked. Web beacons do not store any data on your device. MailChimp uses these technologies in our newsletters. For more information about web beacons, visit their  Privacy Policy.

5. Security processes

ASI has technological and operational security processes in place designed to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized personnel and contractors have access to the information you provide and such access is limited by their need to know the information. Any employee and contractor having access to personally identifiable information is subject to an obligation to maintain the confidentiality of that information. Although we take steps generally recognized as the industry standard to protect your personally identifiable information, ASI cannot guarantee that your personally identifiable information will not be accessible to unauthorized persons.

6. External Links and Plugins

ASI is not responsible for the privacy policy or the content of non-ASI websites linked to our website by external links and/or plugins (generally social networks). In the event that you click on these links and/or plugins, your personal data will be shared with that external site. When you leave our site, the processing of your data is no longer governed by us and this Policy. When you click on a social media plugin (indicated by the appropriate symbol), your personal data is shared with that site. This includes your IP address, information about the page that redirected you to it, and if you have automatic login on your device to social media, it will receive your profile information. Clicking on external links and plug-ins is completely voluntary, so if you do not want your data to be processed in this way, do not click on external links and plug-ins.

7. Data retention

We will not retain your personal data for longer than is necessary to process it and/or only for the period of time specified by the laws in your location. We will not process your data for longer than we need to.

For more information on the length of the data retention period, please contact our Global Data Protection Officer at: dpo@asystems.as.

8. Control over your personal data

ASI will not sell, share, share or disclose your personal information to any third party (other than the third party providers mentioned in Section 2 above), unless you give us your permission or we are required by law to share the information. You have the right to request from ASI any data it holds about you. For more information about whether your data is processed by us or if you would like access to your personal data, please contact  dpo@asystems.as.

9. Modification and/or deletion of information, restriction of processing and data transfer

If you would like to ensure that your personal information is accurate and up-to-date, or if you would like to request that we amend or delete information, restrict our processing of your data, or request an easily portable copy of your personal information, please contact us at dpo@asystems.as.

10. Complaints

If you are concerned about alleged violations of privacy rights or any other regulations, please contact us at the above email address. The ASI Privacy Officer will investigate your complaint and provide you with information on how to resolve the situation.

If you are unhappy with the way we have handled your complaint, you have the right to take your complaint further to the authorities responsible for data protection in your country. You can also take your complaint to a court with appropriate jurisdiction.

11. Changes to the Privacy Policy

ASI reserves the right to change the terms of the Privacy Policy from time to time by posting the current version of the Privacy Policy. We encourage you to periodically review this Privacy Policy for any changes or updates.

12. Use of the ASI website

The use of our website is voluntary. If you do not wish your data to be processed in the ways set out above, you should stop using our site. Your access to and use of the website is subject to certain terms and conditions, summarised in the Terms and Conditions document.  Conditions.

13. Contact us

Please contact us on our website or email dpo@asystems.as if you have any questions about this Privacy Policy or ASI’s collection or use of information.