PRIVACY POLICY

PRIVACY POLICY

Invigilate Technologies Private Limited

Last Updated: 01 December 2025

Invigilate Technologies Private Limited (“Invigilate”, “Company”, “we”, “our”, “us”) is committed to protecting the privacy, confidentiality, and security of all users (“you”, “your”) who access or use our website, online assessment platforms, mobile/web applications, remote-proctoring tools, and related services (“Services”).

This Privacy Policy explains how we collect, use, process, store, disclose, and safeguard your personal information when you interact with Invigilate. By using our website or services, you consent to the practices described in this Privacy Policy.

1. SCOPE & APPLICABILITY

This Privacy Policy applies to:

• Website visitors
• Registered users, candidates, examinees
• Educational institutions, training partners, corporates, assessment bodies
• Remote-proctoring users
• Vendors, clients, and partners interacting with our systems
• Users who make online payments

This Policy is aligned with:

• Information Technology Act, 2000
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”)
• Digital Personal Data Protection Act, 2023 (DPDP Act) – principles
• Relevant NCVET/Assessment Agency norms

2. INFORMATION WE COLLECT

We collect the following categories of personal and non-personal information:

2.1 Personal Identification Data

• Full Name
• Date of Birth / Age
• Gender (if required for assessments)
• Photograph
• Government ID proof (Aadhaar*, PAN, Passport, Driving License, etc.)
• Contact number
• Email address
• Residential address (if required by the client/institution)
• Institutional/Employer details

Note: We never collect Aadhaar biometrics. Only Aadhaar number/last 4 digits may be collected for identity verification if permitted by law.

2.2 Assessment & Exam-Related Information

• Candidate profile, registration details
• Exam logs, attendance, timestamps
• Assessment responses, scores, evaluation results
• Exam behaviour logs
• Device information, browser data
• Screen recordings, screenshots, screen-sharing data

2.3 Remote Proctoring Data

(Only if proctoring is enabled by the client/institution)

• Live video feed
• Captured images
• Audio feed & voice data
• Screen recording
• Keystroke patterns (non-sensitive)
• Face recognition / liveness verification results
• Multi-camera inputs (if required)
• Background detection metadata

2.4 Technical & Usage Data

• IP address
• Device type, OS, browser
• Location (approximate, via IP)
• Cookies, analytics, session logs
• Application crash logs
• User behavior on platform (clicks, navigation, time spent)

2.5 Payment Information

Processed through third-party, secure payment gateways:

• Transaction ID
• Payment mode (UPI, card, net banking, wallet)
• Status of payment
• Billing records

We DO NOT store card numbers, CVV, UPI PIN, or any sensitive payment credentials.

2.6 Third-Party / Institutional Data

When an institution / corporate register you for an exam, we may receive:

• Registration list
• Candidate database
• Roll numbers
• Batch details

3. HOW WE USE YOUR INFORMATION

We use your data for the following purposes:

3.1 To Deliver Assessment Services

• Registration & user account creation
• Exam scheduling & access permissions
• Candidate identity verification
• Generating reports, scores, certificates

3.2 Remote Proctoring & Exam Integrity

• Live invigilation
• Automated/AI-based proctoring
• Detection of rule violations
• Fraud prevention, malpractice monitoring
• Maintaining secure exam environment

3.3 Platform Operation & Improvement

• Analytics and platform optimization
• Troubleshooting technical issues
• Enhancing user experience
• Training AI/ML models (anonymized)

3.4 Communication & Alerts

• OTP verification
• Exam instructions & updates
• Payment confirmations
• Support or grievance communication

3.5 Legal, Compliance & Security Requirements

• NCVET/Assessment Agency guidelines
• Govt/Regulatory reporting
• Prevention of fraud or unlawful activity
• Dispute resolution
• Contractual obligations with clients

4. LEGAL BASIS FOR PROCESSING

We process your data based on:

• Your consent (e.g., during registration, examination start)
• Contractual necessity (delivery of assessment services to you or your institution)
• Legal obligations (government/NCVET compliance, audit trails)
• Legitimate interests (fraud prevention, system improvement)

5. COOKIES & TRACKING TECHNOLOGIES

We use cookies and tracking tools for:

• Session management
• Authentication
• Analytics (Google Analytics, etc.)
• Proctoring functions
• Security monitoring

Users may disable cookies, but some features may not function correctly.

A separate detailed Cookie Policy will be available on the website.

6. SHARING & DISCLOSURE OF INFORMATION

We DO NOT sell your personal data.

We may share your data only with:

6.1 Educational Institutions / Corporates / Assessment Bodies

For whom the assessment is conducted, including:

• Scores, reports
• Proctoring output
• Compliance reports
• Exam logs

6.2 Third-Party Service Providers

• Identity verification partners
• Remote proctoring tools
• Cloud hosting providers
• Payment gateway providers
• SMS/Email providers
• Analytics providers

All service providers operate under confidentiality agreements and data-processing contracts.

6.3 Government / Regulatory Authorities

Only when legally mandated (e.g., NCVET audits, law enforcement).

6.4 Within Invigilate Group

(If multiple entities or affiliates exist)

For internal administration and service improvement.

7. DATA STORAGE & SECURITY PRACTICES

We follow ISO/industry-standard security practices including:

• Encryption (data at rest & in transit)
• Secure hosting on reputed cloud servers
• Firewall & intrusion detection
• Access control (role-based access)
• Protected exam logs
• Frequent vulnerability assessments
• Strict retention & deletion rules

Payment information is protected under PCI-DSS standards (via payment gateway).

8. DATA RETENTION

We retain data only for as long as necessary:

• Candidate profile data: as long as the account is active
• Assessment responses, logs, recordings: 6–36 months (as per client/assessment body requirements)
• Payment transaction details: 7–10 years (for statutory compliance)
• Proctoring data: 30–180 days unless otherwise required

After the retention period, data is securely deleted or anonymized.

9. YOUR RIGHTS

Subject to Indian laws, you may request:

• Access to your personal data
• Correction or update
• Withdrawal of consent
• Data portability (where applicable)
• Deletion (unless retention is legally required)
• Restriction on processing

To exercise these rights, contact us at:

📧 info@invigilate.in
📞 +91 86065 56789

We will respond within the legally required timeframe.

10. CHILDREN’S PRIVACY

We do not knowingly collect data from children under 13 unless:

• Allowed by law
• Registered through educational institutions
• Provided under parental/institutional consent

11. INTERNATIONAL DATA TRANSFERS

If data is stored or processed outside India, we ensure:

• Adequate protection measures
• Compliance with Indian laws
• Binding contractual safeguards

12. LINKS TO EXTERNAL WEBSITES

Our website may contain links to third-party websites or tools.
We are not responsible for their privacy practices or content.

13. DATA BREACH NOTICE

In the event of any data breach, we will:

• Take immediate corrective measures
• Notify affected users, if required
• Document and report all incidents
• Document and report all incidents

14. CHANGES TO THIS PRIVACY POLICY

We may update or modify this Policy from time to time.
Changes will be posted on this page with a revised “Last Updated” date.

Continued use of our services constitutes acceptance of the updated Policy.

15. CONTACT US

For questions, concerns, or complaints regarding this Privacy Policy, contact:

Invigilate Technologies Private Limited

Kerala Address: Invigilate℗, 1st Floor, PeeYems Towers, Vennala P.O, Cochin, Kerala - 682028
UAE Address: FL.H-00060, Ajman Free Zone B1 Building

📧 Email: info@invigilate.in
🌐 Website: www.invigilate.in