1 - Introduction
Central Test's commitment to personal data protection extends beyond mere legal compliance. It primarily reflects our desire to engage with our clients in a relationship grounded in respect and trust. This guiding principle is why the safeguarding of your personal data is a top priority for us. By choosing Central Test’s products, services, and websites, you entrust us with your valuable personal information. Our privacy policy is crafted to transparently communicate the rationale behind, and the methods through which we collect and manage your data.
Unless specified otherwise, Central Test acts as the data controller in the context outlined within this privacy policy.
2 - Personal Data of Website Visitors
This section outlines how Central Test processes personal data when you visit Central Test's websites. The purposes for which we collect and utilise personal data include:
- Operating, improving, optimising, and monitoring the performance of Central Test's websites
- Facilitating Central Test's business operations, including activities related to sales and marketing.
The types of personal data we collect include browser specifics, internet use metadata, and data on web activities on Central Test’s platforms.
For the aforementioned purposes, Central Test and its partners deploy cookies. Further information about Central Test's cookies can be found in the cookie consent banners on Central Test's websites.
Our processing of personal data is grounded in legitimate interests for the objectives mentioned herein. Such data will be retained only as long as necessary for fulfilling these objectives, with further details on retention timelines available upon request.
Entities within the Central Test framework and our affiliate companies may access personal data processed in connection with Central Test's billing and administrative functions, as required for their respective billing and administrative operations.
3 - Use of Personal Data of Users in Central Test's Commercial Activities
Central Test utilises user’s personal data for various commercial purposes, detailed as follows:
- Billing and Administration: Processing necessary for billing and administrative tasks involves the use of names, contact details, titles, organisations, and billing information.
- Sales, Marketing, and Quality Control: Activities in these domains require names, contact details (including email and phone numbers), titles, organisations, and records of interactions with sales and marketing teams, in addition to browser and internet usage data.
- Strategic Decision-Making: Input on Central Test’s services and communications with sales and marketing teams inform our strategic planning at the service level.
For these purposes, Central Test leans on legitimate interests as the foundation for processing personal data, committing to delete such data when it no longer serves the initial purposes. Information on data retention periods is available upon request.
4 - The Key Predict Application by Central Test for Users
This section addresses personal data processing related to the Key Predict application, under Central Test's responsibility. Other processing activities, like those concerning participants and assessors within the Key Predict application, fall to our clients. Chapter 12 provides further details on the division of responsibilities.
Central Test processes users' personal data to:
Enable the use of the Key Predict application, covering usernames, passwords, activity logs, browser and internet metadata, and any other data synced with the application.
Central Test upholds legitimate interests as the rationale for data processing here, with data retention periods primarily determined by the client or user, or as outlined in agreements between them and Central Test. We assure deletion of personal data post the cancellation of associated services or when it's no longer needed for the stated purposes. Further details on data retention are available upon request.
5 - Newsletters, Webinars/Events, Demonstrations, and Training
Central Test may also process the personal data of individuals registering/requesting for Central Test’s newsletter, product demonstration, or webinars/events. In such cases, it includes:
- Managing the attendance and/or participation of the registered individuals in the product demonstration and/or the webinar/event (Name, Contact details, email address, phone number, title, and organisation)
- Sending a newsletter to which the registered person has subscribed (Name, title, organisation, email)
Legitimate interests serve as the legal basis for this data processing, with a commitment to delete personal data once it's no longer required for the initial collection purposes. Further information on retention periods is available upon request.
6 - Others
Central Test may also handle personal data to address claims or disputes related to its services, comply with legal obligations, or respond to legal or governmental requests, including those from law enforcement. The legal basis for such processing is compliance with legal obligations or, where applicable, Central Test’s legitimate interests in resolving service-related issues.
Additionally, should Central Test acquire personal data through other means not specified in this privacy policy, individuals will be promptly informed through alternative communication methods. Please note that if Central Test processes your personal data, you can always contact Central Test to request to exercise your rights, for example, to inquire how we process your data. Your rights under data protection law are further described in paragraph 14.
7 - Social Networks and Distributed Content
Central Test may use its partners' services to stay in touch with you or to provide you with content. For instance, we may share articles on our Facebook page. The services of Central Test's partners may also be used so that Central Test and its partners process personal data or place cookies on your device for the following purposes:
- Sales and marketing
- Enhancing product and user experience
- Communicating with customers and potential customers via social networks
The types of personal data collected may include social network profiles, unique identifiers for these networks, and contact details such as email addresses.
Central Test may also monitor public messages on social networks to stay updated on activities related to our services and to respond appropriately.
Central Test relies on legitimate interests as the legal basis for processing personal data for the purposes listed in this section. The personal data specified will be retained only as long as necessary for the described purposes, with further details on retention periods available upon request.
8 - Advertising
The following companies process your personal data that have been collected for marketing and sales purposes to help Central Test offer advertisements on third-party websites and applications: Facebook, Google, LinkedIn, and Twitter. This includes unique identifiers via cookies, contact information, and browsing history. You have the option to opt out of this data processing at: http://optout.aboutads.info/ (Facebook, Google, LinkedIn, Twitter)
9 - Emails and Other Communications
Central Test may send you emails about our services or other relevant information that may interest you. Emails will only be sent with your prior consent unless you have already subscribed to Central Test's services. As a subscriber, you may receive emails related to similar services or to support your effective use of our services. To unsubscribe, you can contact us by email or use the unsubscribe links in our email communications.
All communications, including chats, emails, phone conversations, and private messages between you and Central Test, may be stored to enhance our communication quality and for future reference. Information regarding the retention periods for these records is available upon request.
10 - Participants on the Key Predict Application
This section pertains to participants of the Key Predict application. Please note that our clients may have separate privacy policies for their activities, such as recruitment, internal mobility, and skills assessments, which are not governed by this privacy policy.
When a client to participate in an assessment (e.g., tests, 360 feedback, smart interviews) on Key Predict, Central Test may process the following personal data:
- Contact details such as full name and email address
- Photo, CV, and/or LinkedIn profile
- Evaluation data including results or audio/video recordings
Central Test relies on the client's legitimate interests as the legal basis for processing personal data for the purposes listed in this section. Data will be deleted when it is no longer necessary for the purposes for which it was collected.
11 - Cookie Permissions
Upon your first visit to our websites, you will encounter our cookie consent tools, which allow you to accept or reject cookies that require consent under data protection laws. Central Test respects your choices regarding cookies. You can also manage cookie settings directly through your internet browser.
12 - Responsibility of Central Test and Client Responsibility
In many cases, Central Test processes personal data as a service for the clients of SaaS products. In these cases, the client assumes responsibility for the processed personal data. According to the terms of the EU GDPR, the client is the data controller and Central Test is the data processor. This privacy policy only describes the processing activities where Central Test is the data controller. We encourage you to review our clients' privacy policies, which detail their processing activities, before submitting personal data to them.
The other sections of this privacy policy provide detailed information on the processing of data for which Central Test is responsible, but for a simplified overview of the identity of the data controller, please refer to the following information:
Central Test is responsible for the personal data of clients on the Key Predict application for:
- Providing application functionalities
- Billing, administration, sales, strategic decision-making, and marketing
- Customer support and success
- Monitoring the application's status and performance
- Improving the application
The Client is responsible for the personal data of participants on the Key Predict application for:
- Providing application functionalities
- Customer support and success for the application
- Monitoring the application's status and performance
- Improving the application
13 - Transfers Outside the European Union
Central Test may transfer personal data outside the European Union (e.g., to Madagascar or the United Kingdom) as part of our global operations. In such cases, Central Test remains responsible as the data controller. In the absence of an adequacy decision (such as the Data Protection Framework and the UK adequacy decision), we utilise standard contractual clauses for use between data controllers (module 1) and between data controllers and processors (module 2) to ensure the protection of your data and to legitimise such a transfer. Please note that Central Test never transfers personal data processed on behalf of our clients outside the EU to any entity other than our subsidiaries. Please contact us for more information on data transfers to countries outside the European Union.
14 - Your Rights, Requests, or Questions
Please do not hesitate to contact us if you have any questions or wish to exercise your rights under European data protection laws. Your rights include access, rectification, erasure, restriction, portability, and objection to processing.
If we process your data based on consent, you can withdraw that consent at any time without affecting the lawfulness of processing before the withdrawal.
In some cases, we have a legitimate interest in using your data, which varies based on its use. We have explained above what this interest consists of and how it is related to the processing operations we perform. If you wish to exercise your rights or if you have requests or questions regarding your personal data, you can contact us at legal@centraltest.com.
If your concerns are not resolved, you have the right to lodge a complaint with a data protection authority in your country of residence, place of work, or where an alleged infringement has occurred. If you are based in the EU, you can find the contact details of your local data protection authority here.
15 - Updates to the Policy
Central Test periodically reviews this policy and recommends that you check for updates regularly. However, we aim to notify users of significant changes through the application's live chat or by email. This policy does not cover third-party services accessible via links from our services.
16 - Identity and Central Test’s Address
The contact details for Central Test are as follows.
Postal address: Central Test, 21 rue Saint Charles, 75012 Paris