Sumadi Global BV wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information collected through the Sumadi Website (the “Website”). The Website is used by your academic institution (the “Institution”) to detect instances of academic dishonesty. The Institution is a data controller and the BV is its data processor. The Institution requires its students to use the Website for proctoring during assessments through the Institution’s learning management system or testing system. The Institution collects and processes data for its internal purposes, and passes this data to the BV for analysis so that the BV can provide the Institution with services related to the detection of academic dishonesty (the “Services”). The Institution is responsible for determining the appropriate legal basis for using the Website.
For questions or concerns about our Privacy Policy and the treatment of data we collect, contact:
privacy@sumadi.net
The information shown above is for illustrative purposes only, Sumadi only collects the information necessary to develop the supervision, this information is provided by The Institution and is subsequently processed as established with The Institution.
The Website gathers Personal Information during a proctored assessment or test. We need to collect Personal Information in order to provide the Services to the Institution. If you do not provide the Personal Information requested, we may not be able to provide the Services, which may affect your status as an enrolled student at the Institution under the Institution’s academic integrity policies.
Sumadi only stores facial biometric information and information necessary for the supervision process such as photos, videos and audios. All these data are encrypted and can only be accessed by approved representatives of the institutions that contract Sumadi’s services.
We do not routinely collect or process sensitive data about you. However, where this is the case we will ensure we take appropriate precautions to protect your data.
We may collect personal data from third parties, such as service providers, advertisers, and social media platforms. The types of data we may collect include name, address, email, and other information that can be used to identify an individual.
We collect this data to improve the user experience, to provide personalised content or advertising, or for fraud prevention and security purposes. We may share this data with third parties, including service providers, or other entities that process the data on our behalf.
We use the data that we collect from third parties to better understand our users and to improve our products and services. We may also use this data for other legitimate business purposes.
We recognise the right of the data subjects to be informed about their data being collected from other sources. In such instances we will provide the following information:
If you have any questions about how we collect or process personal data, please contact us at privacy@sumadi.net.
We will only use your personal data for the purposes for which it was collected, as outlined in this Privacy Policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground for processing.
We will not sell, rent or disclose your Personal Information to a third party except as described herein. We only disclose Personal Information to our affiliates, vendors and partners listed below and then only for the purpose of fulfilling our contractual obligations to the Institution:
Purpose: Cloud service provider
Location: International
Website: https://aws.amazon.com
Purpose: Logging & Monitoring
Location: USA
Website: https://www.datadoghq.com/
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
We and our service providers collect Other Information in a variety of ways, including:
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Sumadi Global BV takes the responsibility of the management and security of your personal data extremely seriously. In accordance with the General Data Protection Regulation, Sumadi, acting as a data controller and data processor, follows the key principles of data protection. These require that personal data to be:
Under GDPR, the data subjects have certain important rights. These include (but are not limited) to the following:
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), you may contact us using the “Contact Us” information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the Contact Us address below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country, but only in accordance with the Institution’s direction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by following this link.
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
Sumadi Global BV, with its principal place of business at Barbara Strozzilaan 201, 1083 HN, Amsterdam, the Netherlands, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at privacy@sumadi.net or at the postal address above. Because email communications are not always secure, please do not send sensitive information in your emails to us.
Office of General Counsel. You can get in touch with us in any of the following ways:
By email: privacy@sumadi.net
Call: +31 20 240 25 74 [Office Hours]
Through our website: https://sumadi.net
Barbara Strozzilaan 201,1083 HN Amsterdam, the Netherlands
Adam Brogden
By email: contact@gdpr.com
Call: + 441 772 217 800
GDPR Local Ltd
1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
