Privacy Policy

    Effective March 1, 2017

    Introduction

    Contact Us

    Definitions

    Authorization and Consent

    Protection and Security

    Collection and Processing

    Disclosure and Use

    FERPA

    Access, Correction and Portability

    Changes to the Policy

    Information about Cookies

     

    Introduction

    This Privacy Policy describes how NCS Pearson, Inc. (Pearson) collects, protects, uses and shares personal information collected and processed through the Versant language skill assessment services (Service).

    The Service generally is purchased and used by businesses, government agencies and higher education institutions. Individuals also may purchase tests.

    Use of the Service is subject to this Privacy Policy.   

    Contact Us

    If you have any questions or concerns about this Privacy Policy, please contact us at support@pearsonkt.com.

    Definitions

    For purposes of this Privacy Policy:

    “Assessment” means a Versant language skill assessment delivered through the Service.

    “Customer” means a purchaser of the Service.

    “Pearson” means NCS Pearson, Inc.

    “Personal Information” means personally identifiable information.

    “Service” means the Versant language skill assessment services, which may be delivered via phone or via mobile app, web or computer (Windows-based) applications or Versant test management platforms.

    “Test Administrator” means an individual who, on behalf of a Customer, manages the assignment of the Assessment to Test Takers and receipt of Assessment results, scores and reports for a Customer.

    “Test Taker” means an individual who takes an Assessment through the Service.

    Authorization and Consent

    Customer. A Customer authorizes Pearson to collect and process Personal Information by ordering the Service, installing a Service application, logging-into the Service, using the Service, designating a Test Administrator, assigning an Assessment to a Test Taker or providing a Test Taker with a Pearson-supplied code to take an Assessment. Customers are responsible to obtain any additional required consents from Test Administrators and Test Takers.

    Test Administrators. Test Administrators accept this Privacy Policy and grant consent to the collection and processing of Personal Information through the Service by installing a Service application, logging-into the Service or using the Service.

    Test Takers. Test Takers accept this Privacy Policy and consent to the collection and processing of Personal Information by installing the Service application, entering an assigned or purchased code to use the Service or taking an Assessment.

    Data Transmission and Storage. Due to the global nature of Pearson’s business and this Service, Personal Information may be transmitted, stored and processed in a country other than the one in which a Customer, Test Administrator or Test Taker resides. The computer servers for the Service are currently based in the United States. The Internet is a global environment. The authorization and consent for Pearson to collect, process and otherwise handle Personal Information under this Privacy Policy includes consent and authorization for a Customer’s, Test Administrator’s or Test Taker’s Personal Information (as applicable) to be transferred and stored in countries outside of their residence or location.

    Protection and Security

    To protect Personal Information from unauthorized access, use and disclosure, Pearson maintains a comprehensive information security program and employs reasonable and appropriate physical, administrative and technical safeguards. Pearson performs periodic risk assessments of its information security program and prioritizes remediation of identified security vulnerabilities. The transmission of Personal Information is protected through SSL or another form of encryption that provides substantially the same or greater protection.

    Collection and Processing

    Pearson collects and processes data in order to provide the Service. This data may include Personal Information.

    Payment Data. If the Service is purchased online, payment data submitted by the Purchaser will be used and disclosed to the Customer’s financial institution and Pearson’s payment processor for the purpose of processing payment for the Service ordered.

    Account Data. Pearson collects and processes account data to set up, maintain and enable a Test Administrator to obtain and assign Assessment codes and receive Assessment results and score reports. Account data may include a Test Administrator’s name, organization, email address, user name and password.

    Rostering Data.  The Test Administrator, on behalf of the Customer, may choose, on an optional basis, to upload first name, last name, email address or an alternative ID for a Test Taker into a roster to facilitate assigning Assessments and tracking Assessment results.

    Assessment Data. Assessment data may include the Examinee’s first name and last name*; city*; country*; gender*; year of birth*; native language*; Assessment responses and answers (which may be spoken or, in certain cases, written); Assessment score, report and recommendations and the Assessment code assigned to and used by the Test Taker to take an Assessment.  

    * Optional Data: The following Test Taker information is not required by Pearson, but may be required by a Customer: name*; country*; gender*; year of birth*; or native language.* City information is required for the phone version of the Service, but is optional for all other versions. In lieu of a name, a Customer may assign an alternative ID for a Test Taker.

    Cookies and Related Technologies. The Service uses cookies to enable Test Administrators to sign-in to the Service and access stored preferences and settings and to enable Test Takers to take an Assessment. Cookies also may be used for Service maintenance, support and security. There are a variety of tools to control the use of cookies and similar technologies, including browser controls to block and delete cookies. Disabling or blocking these technologies, however, may prevent or impair required functionality and use of the Service. For more information, please see Information about Cookies below.

    Application and System Logs. Application and system logs are critical to ensuring the availability and security of the Service. Pearson collects log data to monitor the health of the Service, detect unauthorized access and fraudulent activity, prevent and respond to security incidents and appropriately scale the computing resources for the Service.

    De-Identified and Aggregate Data. Pearson may use de-identified data to maintain, support, evaluate and improve the Service, conduct educational research, develop new products and services and for other purposes. De-identified data is not considered Personal Information under this Privacy Policy.

    Do Not Track. Do Not Track (DNT) is a proposed mechanism for allowing website visitors to control the collection of certain usage data. Although there has been research into the development of a standard to support the use of DNT signals, there is no adopted standard to follow. The Service does not currently respond to Do Not Track signals.

    Disclosure and Use

    Delivery of the Service. Pearson processes and uses Personal Information in order to deliver the Service. In delivering the Service, Pearson provides and discloses Personal Information of a Test Taker to the Customer who assigned the Assessment and Test Administrators of the Service for such Customer.

    Affiliates and Contractors. Pearson may share or disclose Personal Information with affiliated Pearson companies and other companies and organizations who perform work for Pearson under contract and are obligated to protect the privacy of Personal Information consistent with this Privacy Policy.

    Other Circumstances. Pearson otherwise does not share, disclose or use Personal Information collected and used for purposes of providing the Service except as follows: (a) with the explicit consent of the individual to whom such Personal Information relates; (b) to the Customer; (c) in response to a subpoena, court order or legal process, to the extent permitted or required by law; (d) as otherwise required by law; (e) to protect the security and safety of the individual and other persons, data and systems, consistent with applicable law; (f) in connection with a sale, joint venture or other transfer of some or all of Pearson’s business or its assets, subject to the commitment of the acquiring entity to comply with this Privacy Policy; (g) to investigate or address actual or suspected fraud or other illegal activities; or (h) in order to enforce any applicable contract or terms of use.

    Marketing and Advertising. Pearson will not use Test Administrator Personal Information for marketing or advertising purposes, unless a Test Administrator or Customer has consented and opted-in to such use. Pearson does not seek such consent from a Test Taker through the Service. Pearson does not permit third-party ad networks or similar services to access or collect Personal Information within the Service.

    No Sale of Personal Information. Pearson does not sell or rent Personal Information.

    FERPA

    Pearson complies with all applicable provisions of the United States Family Educational Rights and Privacy Act, 20 U.S.C. 1232g, 34 CFR Part 99 (FERPA) as a “school official” under FERPA in receiving and handling personally identifiable information from education records of a Customer who is an education agency or institution subject to the FERPA.

    Access, Correction and Portability

    Test Administrators may access and correct their Personal Information through use of the functionality of the Service. Test Administrators may contact Pearson Support for assistance.

    The Customer has primary responsibility for fulfilling Test Taker requests for access, amendment, correction and export of Personal information. Test Takers may not change responses to an Assessment after the response has been recorded by the Service. For Assessment security and validity, Assessment prompts and responses are not accessible after completion of the Assessment.  The Test Taker’s response to the open question section (which is not used for scoring) is accessible, however, to the Customer and Test Administrator after the Assessment is taken.    Test Taker access, correction or deletion requests may be limited by any applicable restrictions or requirements of the Customer or law.

    Changes to the Policy  

    This Privacy Policy may be revised from time to time through an updated posting. Pearson will identify the effective date of the revision in the posting. If the updates involve material changes to the collection, protection, use or disclosure of Personal Information, Pearson will endeavor to provide notice of the revision in advance to registered Test Administrators through a notice conspicuously posted on the Service, an email or other appropriate way. Continued use of the Service after the effective date of a posted revision will evidence acceptance. Please contact us at support@pearsonkt.com, if you have questions or concerns about the Privacy Policy or any objection to any revisions.

    Information about Cookies

    Pearson may use cookies and related technologies to deliver, support, secure and maintain the Service. Customers, Test Administrators and Test Takers consent to such use of cookies and related technologies by using the Service and accepting and consenting to the Privacy Policy for the Service.

    Cookies. Cookies are small text files that a web server places on a computer or mobile device. Cookies contain information that can later be read by the web server that originally placed the cookie on the computer or mobile device. Cookies that may be used in connection with the Service include:

    Strictly Necessary Cookies. These cookies are essential for use of the Service, such as accessing an Assessment and secure areas of the Service. Without these cookies, the Service cannot be provided.

    Performance Cookies. These cookies collect information about how the Service is used, such as what time is spent in a portion of the Service. Some of these may be analytics cookies, set using third party web analytics software, which provide information about how the Service is used. These cookies generally collect data on an aggregated basis for system administration purposes and to identify problems and improve service.  For example, like many companies, Pearson may use Google Analytics to obtain web trend information about user interaction with a Service. While Google Analytics reports information on an anonymous basis, Google Analytics uses cookies and collects IP addresses to gather web trend information. For further information about Google Analytics, and for links to Google’s Privacy Policy and an opt-out tool for Google Analytics, go to http://www.google.com/intl/en/analytics/privacyoverview.html

    Functionality Cookies. These cookies enable the Service to remember choices made and options selected in order to provide enhanced, more personal features. For example, these cookies can be used to remember changes made to text size. They may also be used to provide the specific functionality requested. 

    Web Beacons. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data. For example, when the Service is used, the code for the part of the Service accessed may be transferred to Pearson via a web beacon. Pearson uses any information transmitted through web beacons to deliver the Service in accordance with the Privacy Policy.

    Managing and Disabling Cookies.  Browser controls and other tools may be used to manage and disable the use of cookies and similar technologies. See, for example, https://ico.org.uk/for-the-public/online/cookies. Disabling or blocking cookies and related technologies, however, may prevent or impair required functionality and use of the Service.