PRIVACY POLICY

Last updated November 18, 2024

This Privacy Notice for Engineray Inc ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at https://www.engineray.com/, or any website of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dev-team@engineray.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
  • Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.
  • Do we collect any information from third parties? We do not collect any information from third parties.
  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information.
  • In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
  • How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.
  • What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
  • How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
  • Want to learn more about what we do with any information we collect? Review the privacy notice in full.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You:

  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • job titles
  • passwords
  • profile picture

Sensitive Information:

We do not process sensitive information.

Payment Data:

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored and processed by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Social Media Login Data:

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider. The specific information collected is described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.engineray.com/legal/cookies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
  • Assessment Proctoring and Monitoring. We process personal information, including video recordings and screen captures, to maintain exam integrity and prevent cheating during assessments.
  • Automated Evaluation and Analysis. We analyze user responses, code submissions, and assessment performance to provide automated grading, scoring, and skills evaluation.
  • ATS Integration. We share assessment results and candidate information with integrated Applicant Tracking Systems (ATS) when authorized by employers.
  • Platform Security and Fraud Prevention. We process user data to detect and prevent fraudulent activities, unauthorized access, and maintain platform security.
  • Platform Improvement and Analytics. We analyze user interactions and platform usage patterns to improve our services, enhance user experience, and develop new features.
  • Assessment Integrity Monitoring. Process video recordings and screen activity during assessments.
  • AI-Powered Question Generation. Process uploaded documents and topics to generate assessment questions.
  • Resume and Skills Analysis. Analyze candidate resumes and assessment responses with AI.
  • Integration with HR Systems. Share assessment results with integrated ATS platforms.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • Analyze how our Services are used so we can improve them to engage and retain users
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and services so we can improve user experience
    • In order to ensure fairness and prevent academic dishonesty in assessments, protecting the validity of results for all users
    • In order to create relevant and customized assessment content while maintaining quality standards
    • In order to provide objective candidate evaluation and streamline the hiring process
    • In order to provide seamless hiring workflows and maintain data consistency across employer systems
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with specific categories of third parties.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

  • AI Platforms
  • Cloud Computing Services
  • Communication & Collaboration Tools
  • Data Analytics Services
  • Data Storage Service Providers
  • Payment Processors
  • Performance Monitoring Tools
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers
  • ATS (Applicant Tracking System) Integration Partners
  • HR Technology Integration Partners

We may also need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Specific sharing practices:

  • Assessment Results: When you complete an assessment, your results may be shared with:
    • The employer or organization that requested the assessment
    • Integrated ATS platforms as authorized by the employer
    • Our automated evaluation systems for scoring and analysis
  • Proctoring Data: Video recordings and screen captures from proctored assessments are:
    • Retained for 90 days after assessment completion
    • Accessible only to authorized proctoring staff and automated systems
    • Used solely for integrity verification and security purposes
  • Integration Partners: When enabled, assessment data may be shared with:
    • Authorized ATS platforms
    • HR management systems
    • Other authorized recruitment tools

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to:

  • Help manage and display advertisements
  • Tailor advertisements to your interests
  • Send abandoned shopping cart reminders (depending on your communication preferences)

The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.engineray.com/legal/cookies

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI and Anthropic. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

  • Machine learning models
  • Natural language processing
  • Image analysis
  • Video analysis
  • Text analysis
  • AI bots
  • AI document generation
  • AI insights
  • AI predictive analytics
  • AI automation

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

Specific AI Processing Activities:

  • Assessment question generation from provided content
  • Resume and skills analysis for candidate evaluation
  • Automated grading and scoring of assessments
  • Performance pattern analysis and insights generation
  • Content validation and quality checks

Data Protection in AI Processing

  • All AI processing follows strict data protection protocols
  • Personal information is encrypted during processing
  • Access to AI-processed data is strictly controlled
  • Regular audits ensure compliance with privacy standards
  • AI models are regularly updated to maintain accuracy and fairness

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Social Login Information

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider.

The profile information we receive may include:

  • Your name
  • Email address
  • Friends list
  • Profile picture
  • Other information you choose to make public on such a social media platform

Use of Social Login Data

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services.

Important Notice

Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

Social Login Security

  • All social login integrations use secure OAuth protocols
  • We don't store your social media passwords
  • You can disconnect your social media account at any time
  • We regularly review and update our social login security measures

Control Over Your Information

  • You can manage which information is shared through your social media account's privacy settings
  • You can switch to a regular email-based account at any time
  • Disconnecting your social media account won't delete your account with us
  • You can review and update the information we've received through social login in your account settings

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

General Retention Policy

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twenty four (24) months past the termination of the user's account.

Retention Periods by Category

CategoryRetention Period
Category A - Identifiers24 months after account termination or last activity
Category B - Personal Information24 months after account termination or last activity
Category C - Protected Classifications24 months after account termination or last activity
Category D - Commercial Information24 months after account termination or last activity
Category E - Biometric Information24 months after account termination or last activity
Category F - Internet Activity24 months after account termination or last activity;
90 days for assessment session activity data
Category G - Geolocation Data1 month
Category H - Audio/Visual Information90 days after assessment completion
Category I - Professional Information24 months after account termination or last activity
Category J - Education Information24 months after account termination or last activity
Category K - Inferences24 months after account termination or last activity

Information Deletion

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Special Considerations

  • Assessment recordings and proctoring data are retained for 90 days after completion
  • Backup archives are maintained separately with restricted access
  • Legal hold periods may extend retention when required by law
  • You can request deletion of your data at any time, subject to legal requirements

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Security Overview

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Technical Security Measures

  • Industry-standard encryption for data in transit and at rest
  • Secure HTTPS/TLS connections for all web traffic
  • Regular security assessments and penetration testing
  • Multi-factor authentication support
  • Automated threat detection and monitoring
  • Regular security patches and updates

Assessment Security

  • Secure proctoring environment with encrypted video streams
  • Protected test content delivery
  • Anti-cheating measures and automated fraud detection
  • Secure storage of assessment results and recordings
  • Access controls for proctoring staff and reviewers

Organizational Security Measures

  • Regular security training for staff
  • Strict access control policies
  • Data handling procedures and guidelines
  • Incident response plans
  • Regular security audits
  • Vendor security assessments

Data Protection Measures

  • Encryption of sensitive personal information
  • Secure backup systems
  • Data loss prevention systems
  • Regular vulnerability assessments
  • Compliance with industry security standards
  • Physical security measures for data centers

Your Role in Security

While we implement strong security measures, you can help protect your information by:

  • Using strong, unique passwords
  • Enabling two-factor authentication when available
  • Not sharing your account credentials
  • Accessing the service from secure networks
  • Keeping your devices and browsers updated
  • Logging out after completing your session

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

Our Policy on Minors

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

Protection Measures

  • Age verification during registration
  • Immediate account deactivation if minor status is discovered
  • Prompt deletion of any collected data from minors
  • Parental consent verification for any exceptions

If We Learn of Minor Data Collection

If we learn that personal information from users less than 18 years of age has been collected, we will:

  • Deactivate the account immediately
  • Take reasonable measures to promptly delete such data from our records
  • Implement additional measures to prevent future collection

Report Underage Data Collection

If you become aware of any data we may have collected from children under age 18, please contact us at: dev-team@engineray.com

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you may have certain rights regarding your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Your Basic Rights

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:

  • Request access and obtain a copy of your personal information
  • Request rectification or erasure of your personal information
  • Restrict the processing of your personal information
  • Data portability (where applicable)
  • Object to the processing of your personal information
  • Not be subject to automated decision-making

Withdrawing Your Consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided
  • Log in to your account settings and update your user account

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.engineray.com/legal/cookies

Questions or Concerns?

If you have questions or comments about your privacy rights, you may email us at: dev-team@engineray.com

Additional Rights by Region

Depending on your location, you may have additional rights. Please see the sections "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?" and "DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?" for more information about region-specific privacy rights.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Current DNT Status

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California DNT Notice

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Alternative Privacy Controls

While we may not respond to DNT signals, we offer other ways to control data collection and usage, including:

  • Account privacy settings
  • Cookie preferences management
  • Opt-out of marketing communications
  • Data collection preferences in your account settings

Future Updates

We are committed to respecting your privacy choices and will update our practices regarding DNT signals if and when a consistent standard is established. Any changes to our DNT practices will be reflected in updates to this Privacy Notice.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information categoriesName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristicsGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataYES
D. Commercial informationTransaction information, purchase history, financial details, and payment informationYES
E. Biometric informationFingerprints and voiceprintsYES
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsYES
G. Geolocation dataDevice locationYES
H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesYES
I. Professional or employment-related informationBusiness contact details, job title, work history, and professional qualificationsYES
J. Education InformationStudent records and directory informationYES
K. Inferences drawn from collected personal informationInferences drawn to create a profile about preferences and characteristicsYES
L. Sensitive Personal Information-NO

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, you can contact us by:

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

  • offer you the products or services that you want
  • respond to or help with your requests
  • manage your account with us
  • confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints: PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

Additional Information

For questions about your rights in your region or to exercise your rights, please contact us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

15. ASSESSMENT INTEGRITY AND PROCTORING INFORMATION

Assessment Monitoring Overview

Our platform employs advanced proctoring and assessment security measures to ensure fair and accurate evaluations. This includes:

  • Video recording and monitoring during assessments
  • Screen captures and behavioral data collection
  • Identity verification procedures
  • Automated analysis of assessment sessions

Data Collection During Assessments

  • Video recordings of assessment sessions
  • Screen activity and content
  • Behavioral patterns and interactions
  • System and environment information
  • Identity verification documents

Automated Analysis Features

  • Facial recognition for identity verification
  • Gaze tracking for attention monitoring
  • Screen monitoring for unauthorized activity
  • Behavioral pattern analysis
  • Integrity verification systems

Data Retention and Security

Assessment-related data is subject to specific retention policies:

  • Video recordings are retained for 90 days after assessment completion
  • Screen captures are stored for 90 days post-assessment
  • Identity verification data is kept for the duration of account activity
  • Assessment results are maintained according to standard retention policies

Data Sharing and Access

Assessment data may be shared with:

  • Authorized company representatives
  • Integrated ATS platforms (when enabled)
  • Automated evaluation systems
  • Proctoring review staff

Security Measures

We implement strict security protocols for assessment data:

  • Encrypted storage of all assessment recordings
  • Limited access controls for proctoring staff
  • Secure transmission of assessment data
  • Regular security audits and updates
  • Compliance with data protection regulations

User Acknowledgment

By participating in proctored assessments, users acknowledge and consent to:

  • Video and screen recording during assessments
  • Automated analysis of assessment sessions
  • Identity verification procedures
  • Sharing of assessment results with authorized parties
  • Data retention policies as described above

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

Update Policy

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Material Changes

  • Changes to data collection practices
  • Updates to data sharing policies
  • New data processing procedures
  • Changes to user rights
  • Updates to security measures

Notification Methods

  • Website announcements
  • Email notifications
  • In-app notifications
  • Service notifications
  • Direct communications

Your Responsibilities

  • Regularly review the Privacy Notice for updates
  • Check the "Revised" date at the top of the notice
  • Review any notifications about policy changes
  • Contact us with any questions about updates

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Contact Methods

If you have questions or comments about this notice, you may email us at dev-team@engineray.com or contact us by post at:

Engineray Inc

2799 Marsh Drive

San Ramon, CA 94583

United States

When to Contact Us

  • Questions about this Privacy Notice
  • Requests about your personal information
  • Concerns about our privacy practices
  • Updates to your contact information
  • Privacy-related complaints

Response Time

  • General inquiries: 2-3 business days
  • Data access requests: Within 30 days
  • Urgent privacy concerns: 1 business day
  • Technical support: 24-48 hours
  • Complaint resolution: 5-7 business days

Information to Include

To help us respond to your inquiry more efficiently, please include:

  • Your full name
  • Your account email address
  • A detailed description of your concern
  • Any relevant screenshots or documentation
  • Your preferred method of contact
  • The urgency of your request

Note: For security reasons, we may need to verify your identity before processing certain requests related to your personal information.

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information:

Types of Requests

  • Access your personal data
  • Update incorrect information
  • Delete your personal data
  • Export your data
  • Review processing activities
  • Withdraw consent

Required Information

  • Full name
  • Email address
  • Account information
  • Request details
  • Verification documents
  • Time period of data requested

Request Processing

  • We will respond to your request within 30 days
  • Complex requests may require additional time
  • We may need to verify your identity
  • Some information may be exempt from access requests
  • We will provide reasons if we cannot fulfill your request

Verification Process

To protect your privacy and security, we will verify your identity before granting access to personal information. This may include:

  • Confirming your email address
  • Requesting government-issued ID
  • Asking security questions
  • Verifying account ownership

Important Note: While we will make every effort to accommodate your request, please be aware that certain information may need to be retained for legal, security, or business purposes. We will inform you if this affects your request.