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Privacy notice

How we handle your personal data, and the rights you have under the GDPR (EU) 2016/679. Document AQS-POL-03.

Draft — subject to legal review before launch. Draft v0.1, last updated 3 November 2026. This text is provided for the demonstration platform and must be reviewed by qualified legal counsel before AQSCERT begins live operations.

1. Who we are

AQSCERT S.R.L. (“AQSCERT”, “we”) is the controller of your personal data. Company number: To be confirmed. Registered office: Registered office address to be confirmed. Contact our data protection lead at [email protected]. Our lead supervisory authority is the competent data protection supervisory authority of the member state of our registered office (to be confirmed).

2. Data we collect

  • Identity and contact: name, name for certificates, email, phone, country, date of birth.
  • Account and security: hashed password, two-factor settings, session and sign-in records, pseudonymised IP addresses.
  • Examination: bookings, answers, scores, score reports, incident reports and, for online exams, proctoring data.
  • Identity verification: images of your photo ID and the verification outcome.
  • Certification: eligibility evidence, decisions, certificates, CPD records and status history.
  • Financial: invoices and payment status. Card details are handled by Stripe; we never see or store full card numbers.
  • Communications: enquiries, complaints, appeals and email delivery records.

We collect most data from you directly. Employers or partners may provide your name and email when inviting you or issuing a voucher.

3. Purposes and lawful bases

PurposeLawful basis
Creating and managing your accountContract (Art. 6(1)(b))
Booking, delivering and marking examinationsContract (Art. 6(1)(b))
Verifying your identity and protecting exam integrity, including proctoringLegitimate interests (Art. 6(1)(f)) — DPIA-001 and DPIA-002
Eligibility review and certification decisionsContract; legitimate interests in a reliable certification scheme
Publishing certificate verification (number, name, title, dates, status)Legitimate interests of employers and the public in verifying credentials
Payments, invoicing and tax recordsContract; legal obligation (Art. 6(1)(c))
Service emails (bookings, results, expiry reminders)Contract; legitimate interests
Marketing emailsConsent (Art. 6(1)(a)) — withdraw any time
Complaints, appeals and malpractice investigationsLegitimate interests; legal claims
Sharing outcomes with your employer (corporate accounts)Consent — DPIA-003
Security logging and fraud preventionLegitimate interests

We do not make decisions about you based solely on automated processing. Every certification decision and every proctoring flag is reviewed by a person.

4. Special category data

If you request reasonable adjustments, you may give us health or disability information. We process it only to arrange adjustments, on the basis of your explicit consent (Art. 9(2)(a)), restrict access to trained staff, and delete it when no longer needed. You can withdraw consent, although we may then be unable to provide the adjustment.

5. Remote proctoring

Online exams are supervised by an external proctoring provider acting as our processor. It records webcam video, audio and your screen during the exam, and images of your ID and room at check-in. We do not use biometric identification or emotion analysis by default. Recordings are normally deleted after three months. Remote proctoring is optional: you can choose a test-centre exam instead.

6. Sharing and processors

We share data with service providers who process it on our behalf under written data processing agreements, with your employer only where you have consented, with anyone using our public verification service (limited to certificate details), and with authorities where the law requires. We never sell personal data.

ProcessorServiceLocationTransfer safeguard
Stripe Payments Europe LtdPayment processingIreland / United StatesEU Standard Contractual Clauses
ResendTransactional email deliveryUnited StatesEU Standard Contractual Clauses / EU–US Data Privacy Framework
S3-compatible storage providerCertificates, ID documents (encrypted), documentsEuropean Union (to be confirmed)No transfer outside the EEA
Remote proctoring provider (to be appointed)Online exam invigilationTo be confirmedEU adequacy decision or Standard Contractual Clauses, after transfer impact assessment

7. International transfers

Where data is transferred outside the European Economic Area, we rely on European Commission adequacy decisions or the EU Standard Contractual Clauses, supported by a transfer impact assessment. Contact us for a copy of the relevant safeguards.

8. Retention

DataRetention period
Certification records (certificate number, holder name, dates, status)10 years after expiry or withdrawal, then anonymised
Examination responses and results6 years after result confirmation
Identity verification documents6 months after the verification decision
Remote proctoring recordings (held by processor)3 months, unless under investigation or appeal
Payment and invoice records6 years after the end of the financial year
Complaints and appeals6 years after case closure
Audit logs7 years
Inactive candidate accounts with no certificates3 years after last sign-in
Marketing preferences2 years after consent withdrawal or last interaction

9. Security

We use encryption in transit and at rest, additional field-level encryption for sensitive data, Argon2id password hashing, mandatory two-factor authentication for staff, role-based access and tamper-evident audit logs.

10. Your rights

Under the GDPR you have the right to:

  • access your data and receive a copy (subject access);
  • data portability — a machine-readable copy;
  • rectification of inaccurate data;
  • erasure, where there is no overriding reason for us to keep the data;
  • restrict or object to processing, including objecting to processing based on legitimate interests;
  • withdraw consent at any time, without affecting earlier processing.

Self-service: signed-in candidates can download a data export and request erasure from the Privacy section of the dashboard. You can also email [email protected]. We respond within one month, which may be extended by two further months for complex requests. We may need to verify your identity first.

11. Cookies

We use only a strictly necessary session cookie and store your colour-theme preference in your browser. See the cookie policy.

12. Complaints to a supervisory authority

Please contact us first so we can try to help. You also have the right to complain to the competent data protection supervisory authority of the member state of our registered office (to be confirmed), or of the EU member state where you live or work, or where an alleged infringement took place.

13. Changes to this notice

We will post any changes here and, for significant changes, notify account holders by email.