PRIVACY POLICY – TESTWE

LAST UPDATED: 21/07/2025

1. PREAMBLE

Welcome to our « Privacy Policy » page of the website managed by TestWe accessible at https://charleszhutestweeu.wpcomstaging.com/en/ (the « Site« ).

We thank you for using our Site and our online services (the « Services« ). TestWe is committed to preserving the confidentiality of your Personal Data and attaches great importance to protecting the privacy of users of its Services.

On this page, you will find, among other things, the following information:

what data we may collect about you;
why and how we use this data;
the origin of this data;
with whom we may share it;
what is the legal basis on which we rely to do so and;
what measures we take to ensure their security

TestWe, a simplified joint-stock company, registered with the Paris Trade and Companies Register under number 801731571 and whose registered office is located at 6, rue Notre Dame de Nazareth, 75003 Paris (« TestWe », « we » or « our »), is committed to protecting and respecting the privacy of any person whose Personal Data we process in the context of providing the Services.

The processing of Personal Data of visitors and users of our Services is subject to European Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the « GDPR ») and to Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended (the « Data Protection Act ») (hereinafter the « Regulation« ).

Under this Regulation, TestWe acts on behalf of private higher education institutions, certifying bodies or employers who use TestWe Services, as a subcontractor of Personal Data processing carried out through our online Services, and undertakes through this Policy to comply with the legal and regulatory obligations incumbent upon it.

The data controller is required to provide you with all the information set out in the Privacy Policy. However, we want to explain here how we process your Personal Data and how we go about respecting your integrity in accordance with the GDPR. We encourage you to read this privacy policy. Its use should help you make informed decisions.

If you have any questions about this Privacy Policy or about your Personal Data in general, please contact us at privacy@testwe.eu or by mail at the following address: TestWe, GDPR Service, 6 rue de Notre Dame de Nazareth, 75003 Paris.

The content of our Privacy Policy may be subject to change. You will be regularly informed of updates, by any means (email, pop-up window, etc.).

In general, the Policy is always easily accessible at the bottom of the page on the different pages of the Site.

2. WHO IS CONCERNED BY THIS PRIVACY POLICY?

The processing carried out by TestWe through the Site concerns simple visitors and Users (both candidates and administrators) of the Site wishing to benefit from TestWe’s online Services (the « Data Subjects« ).

3. HOW IS YOUR PERSONAL DATA COLLECTED?

TestWe directly and indirectly collects Personal Data from users through the online account creation form (first connection to the platform), webcam streams (activation of students/candidates’ webcam during online examination), connection logs (collection of connection logs), and all other data integrated by institutions and reported by candidates.

Technical information (for example, IP address, information about your browser, etc.) is also transmitted to TestWe by your terminal when you use the Site.

4. TYPOLOGY OF PERSONAL DATA, PURPOSES AND LEGAL BASIS

By « Personal Data » or « Personal Data », we mean any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to elements specific to their physical, physiological, genetic, psychic, economic, cultural or social identity (« Personal Data »). This does not include data from which identity has been removed (anonymous data).

Below you will find an overview of the different categories of persons concerned by this Privacy Policy, as well as:

the type of personal data concerning you that we use and store;
the purposes for which personal data is collected;
the legal basis for processing operations.

4.1 Types of personal data collected

We collect and process the following Personal Data:

identity data (first name, last name, university assignment, examination concerned);
control recordings (video of the candidate’s face and upper body, video of the candidate’s ears, video of the room where the candidate takes the examination);
data relating to an identity document (copy of the candidate’s identity card or passport);
non-anonymized examination copies;
audio recordings (in case of fraud, vocal exchange between the surveillance agent and the candidate concerned);
video recordings (video of the candidate taken throughout the examination session which is deleted simultaneously);
first name and last name, email address, login identifier (professors/instructors/correctors and candidates);
connection logs.

Furthermore, we collect navigation data through our platform (the « Cookies« ). These are only AWS cookies allowing to identify the instance to which the user is attached and the recording of the user’s default language choice. These technical cookies do not require your consent.

TestWe also collects information relating to your browsing activity on the Site, for example:

the type of terminal you use (smartphone, computer, tablet…);
your terminal’s operating system;
your internet service provider;
the geolocation of your terminal.

4.2 Purpose and legal basis for collecting your Personal Data

TestWe’s clients must define the legal basis for processing in their capacity as data controller. We collect and use your Personal Data for the following reasons and purposes and on the following legal bases:

Objective	Legal Basis
Providing the Services	Execution of the contract binding us with the data controllers and execution of the Terms of Use
Ensuring the security of Personal Data (e.g., preventing identity theft)	Execution of the contract binding us with the data controllers and execution of the Terms of Use
Allowing you to access and use the Site	Our legitimate interest
Ensuring the proper functioning of the Site	Our legitimate interest
Storing information about your preferences and allowing us to personalize the site based on your interests (cookies)	Your consent
Preparing reports or compiling statistics to improve our products and services (cookies)	Your consent
Resolving any disputes or addressing issues arising in connection with the use of the services	Our legitimate interest
Retaining Personal Data necessary to meet legal obligations and handle data requests from authorized authorities	Compliance with our legal or regulatory obligations

5. IF YOU DO NOT PROVIDE PERSONAL DATA

If you choose not to provide the Personal Data that we request from you, we may not be able to provide you with the Services you have requested or achieve the objectives for which we requested the Personal Data.

Access to your Personal Data is strictly limited:

internally to TestWe employees authorized by reason of their function and bound by an obligation of confidentiality;
to third parties involved in the provision of our Services (technical providers, hosting provider, email or service notification router, etc.). TestWe undertakes to communicate your Personal Data only to authorized and trusted providers, who process it on our behalf, according to our instructions. In the context of the execution of their services, TestWe’s providers respect the provisions of the GDPR and TestWe has concluded an agreement on the processing of your Personal Data.

TestWe may share your Personal Data with judicial authorities, independent administrative authorities or any other organization if the law, a regulatory provision, or a court order requires it, or if such disclosure is necessary for the needs of an investigation, injunction or judicial proceeding, nationally or abroad.

7. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

TestWe does not transfer Personal Data outside EU/EEA countries, to countries that have not been the subject of an adequacy decision by the European Commission within the meaning of Post 45 of the GDPR, or without the European Commission’s standard contractual clauses having been concluded, or with regard to transfers of Personal Data to the United States, without the providers being certified under the new EU-US adequacy decision of the European Commission and the Data Privacy Framework dated July 10, 2023. TestWe ensures that these recipient providers of Personal Data are authorized organizations that appear on the list of DPF certified companies, available at the following address https://www.dataprivacyframework.gov/s/participant-search.

8. RETENTION PERIOD OF YOUR PERSONAL DATA

We will only retain your Personal Data for the time necessary to achieve the objectives for which they were collected, including to meet any legal or accounting requirements as well as CNIL recommendations.

Above all, retention periods are set by the data controller.

To determine the appropriate retention period for Personal Data, we take into account the quantity, nature and sensitivity of the Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and the possibility of achieving these purposes by other means, as well as applicable legal requirements. The retention period of your Personal Data may therefore vary in number of days, months or even years depending on your profile (student/candidate or teacher/professor/instructor/corrector), the category of Personal Data and the purposes of processing.

In principle and unless otherwise instructed by your data controller, we retain your Personal Data as follows:

first name, last name, email and ID of professors/instructors/correctors: duration of service use;
candidate identity data (first name, last name, institution assignment, examination concerned) are retained for 2 years after the examination, unless a disciplinary procedure is triggered;
connection logs: 2 months;
the photograph and copy of the candidate’s identity document are retained for two months;
for ProctorWe Live, video recordings are not retained on TestWe servers and are therefore deleted instantly and for ProctorWe, photographs taken every five seconds as well as audio recordings are also retained for two months.
Furthermore, we retain Personal Data for:

complaints, questions, complaints: 3 years after the closure of a complaint, question or complaint;
contact form: 3 years from your request;
newsletter subscription: as long as the Data Subject does not unsubscribe.
For visitor Personal Data, please refer to section 13.2 on cookies.

Beyond the set deadlines, the Data is either deleted or retained after being anonymized, particularly for statistical purposes. They may be retained in the event of pre-litigation and litigation. It should be recalled that deletion or anonymization are irreversible operations and that TestWe is no longer able to restore them.

9. RIGHTS OF DATA SUBJECTS

As a Data Subject, you have several rights. These rights are not absolute and each of them is subject to certain conditions in accordance with the GDPR and applicable national laws.

the right of access – you have the right to obtain from us confirmation that your Personal Data is or is not processed by us, as well as certain other information (similar to that provided in this Privacy Policy) about how it is used. You also have the right to access your Personal Data by requesting a copy of it. This allows you to know and verify that we use your information in accordance with data protection laws. We may refuse to provide information if it reveals Personal Data concerning another person or if it infringes the rights of another person.
the right of rectification – you can ask us to take measures to correct your Personal Data if they are inaccurate or incomplete (for example, if we have a wrong name or address).
the right to erasure – also known as the « right to be forgotten », this right allows you, in simple terms, to request the erasure or deletion of your Personal Data when, for example, we have no compelling reason to continue using it or that its use is illegal. However, this is not a general right to erasure and there are certain exceptions, for example when we need to use the information to defend a legal claim or to be able to comply with a legal obligation.
the right to restrict processing – you have the right to « block » or prevent the further use of your Personal Data when we are examining a rectification request or as an alternative to erasure. When processing is limited, we can still retain your Personal Data, but we can no longer use it.
the right to data portability – you have the right to obtain and reuse certain Personal Data for your own purposes in different companies (which are separate data controllers). This only applies to Personal Data that you have provided to us, that we process with your consent and for the purpose of executing the contract, and that is processed by automated means. In this case, we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (when technically possible) we may transmit your data directly to another processor or data controller.
the right to withdraw your consent – when we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, this withdrawal does not affect the legality of the processing that took place before this withdrawal.
the right to give us instructions on how to use your personal data after your death – In France, you have the right to give us instructions on how to process (for example, retain, delete and disclose) your data after your death. You can modify or revoke your instructions at any time.

10. EXERCISE OF RIGHTS

If you have questions about this Privacy Policy, about how we process your Personal Data or if you wish to exercise any of your rights, you have the possibility to question us about the processing of your data and to effectively exercise your rights through the following means:

primarily by contacting your data controller who will transfer the requests to us for all activities related to our platform.
by sending us a request to the email address privacy@testwe.eu or by sending us a letter to the following address: TestWe, GDPR Service, 6 rue de Notre Dame de Nazareth, 75003 Paris.

In this regard, we may need to ask you for specific information to help us confirm your identity and ensure your right of access to this information (or exercise of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to a person who does not have the right to receive it.

In accordance with the recommendations of the Commission Informatique et Libertés (« CNIL« ) which is the competent supervisory authority for data protection for TestWe, the processing of your request will be done within short deadlines (1 month to 3 months maximum, depending on the cases).

Any request of this type will be examined within the deadlines provided for by the applicable law. Please note, however, that certain Personal Data may be exempt from such requests in certain circumstances, particularly if TestWe needs to continue processing your Personal Data for its legitimate interests or to comply with a legal obligation.

The exercise of your right of access (or any other right) is free. Sometimes, we will not be able to respond to your request if it is manifestly unfounded or excessive.

Furthermore, if you are not satisfied with our response to your complaint or if you believe that the processing of your Personal Data is not in compliance with applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority (the CNIL: https://www.cnil.fr/) and/or to obtain a right to compensation before the competent courts if you consider that your rights are not respected.

11. HOW IS YOUR DATA SECURED?

TestWe ensures that Personal Data is processed securely and confidentially, including when certain operations are carried out by technical providers. To this end, appropriate technical and organizational measures are implemented to prevent unauthorized access and disclosure, accidental loss, misuse, alteration, damage and accidental or unlawful deletion of your Personal Data. These measures are adapted according to the level of sensitivity of the data processed and the level of risk presented by the processing or its implementation. We have implemented procedures to handle any suspected data breach and we will notify you, as well as any competent supervisory authority, of any suspected breach when we are legally required to do so.

TestWe uses for example (i) a secure https connection, (ii) two-factor authentication by password and SMS validation (iii) IP filtering for certain sensitive services (iv) differentiated technical accounts and (v) key monitoring.

To do this, we require our staff and technical providers to comply with strict rules regarding security and information protection (e.g. confidentiality obligation, implementation of physical security measures, etc.).

Finally, we inform you that your Personal Data is stored on servers located in France or in European Union member countries.

Unfortunately, the security of data transmissions over the Internet or data storage systems cannot be guaranteed 100%. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of an account you hold with us has been compromised), please notify us immediately by contacting us at the coordinates mentioned in section 14 of the Privacy Policy.

12. THIRD-PARTY WEBSITES

The Site may contain links to other websites operated by third parties. Please note that this Privacy Policy only applies to personal data collected by TestWe. We are not responsible for Personal Data that third parties may collect, store and use on their own websites or applications. We recommend that you carefully read the Privacy Policy of each website and/or application you visit.

13. COOKIES

13.1 What is a « cookie »?

« Cookies » are small text files, often containing unique identifiers, that are sent by web servers to web browsers and can then be sent back to the server each time the browser requests a page from the server.

Cookies are very useful and allow a website to recognize you, identify you when you visit a particular page, provide a secure connection to a website and improve your user experience by improving your browsing experience and/or adapting the content of a page to your interests.

13.2 How are cookies used?

When prior consent is required for their use, the validity period of consent to the deposit of cookies is 6 months. At the end of this period, we will ask for your consent again.

The cookies we deposit as operators of our Site are called « internal cookies ». Cookies that third parties have deposited for us on our Site are called « third-party cookies ». Third-party cookies allow us to provide third-party features or functionality on or through a website (for example, advertising, interactive content and analytics). The people who create these third-party cookies may collect some of your personal data, recognize your computer when you visit the website in question and when you visit other websites.

The retention period of an audience measurement cookie that does not require consent is 13 months. However, the information collected through these cookies is retained by us for a maximum period of 25 months, in accordance with applicable regulations.

The types of cookies used on our site are as follows:

Technical cookies:
These cookies allow you to navigate our Site and use its features more effectively. These cookies also allow our site to remember your previous actions during the same browsing session.
Functionality cookies:
These cookies allow our Site to remember the choices you made during your visit in order to offer you improved and more personalized features.
Social media cookies:
These cookies allow you to display or share our content with other people, particularly on social networks such as Facebook, Twitter, Instagram, LinkedIn, etc. Even if you do not use these sharing buttons or applications, social networks may track your browsing on the Site if your account or session is active on your computer at that time.
Analytics cookies:
These cookies are used by us or by third-party service providers to analyze the use and performance of our Site. We use Google Analytics cookies to obtain web analytics data. Google Analytics collects information about your interaction with our site, including information about the pages you visit and the duration of your visit to our site.

Google Analytics

Google Analytics is a web analytics service provided by Google that allows you to track and report on website traffic. Google uses the collected data to track and control the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize ads in its own advertising network.

You can refuse to make your activity on the service available to Google Analytics by installing the browser add-on to disable Google Analytics. This add-on prevents Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visitor site activity.

For more information about Google’s privacy practices, please visit Google’s privacy policy web page: https://policies.google.com/privacy?hl=en.

Statistical cookies:

These cookies allow us to establish statistics and volumes of traffic and use of the various elements composing our Site (sections and content visited, journey, time spent on the Site), which allows us to improve the interest and ergonomics of our Services.

Advertising cookies:

These are cookies used to show you advertisements or send you information adapted to your interests in the context of your use of the Site when you browse the Internet outside the Site. They are particularly used to limit the number of times you see an advertisement and to help measure the effectiveness of an advertising campaign. These cookies depend mainly on advertising agencies and we do not always control their use.

13.3 How to block the use of cookies?

There are two ways to refuse the use of cookies.

During your first visit to our Site, you will be asked to consent to the use of your data by cookies through an information banner that will be prominently displayed at the bottom of the page.

Thanks to the « Accept All » and « Refuse All » buttons, you can globally accept or refuse that we can deposit cookies on your computer or device (cookies related to targeted advertising operations, certain audience measurement cookies, social media cookies generated in particular by their sharing buttons when they collect personal data). However, a third « Customize » button present on this banner will allow you to obtain the details of the categories of cookies used and thus choose to consent or not by purpose.

However, if you want to refuse the use of any type of cookies on a website, you can do so by modifying your browser settings to block the use of cookies. Please note that if you block the use of cookies through this browser setting, you may not be able to use or view all or part of the website concerned, including our site.

Each web browser offers different ways to configure cookie management. In general, they are described in the help menu of each browser.

Firefox

https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent

Click on the menu button and select « Options ».
Select the « Privacy & Security » panel.
Set the « History » menu to « Use custom settings for history ».
Uncheck the « Accept cookies » box.
Changes made will be automatically saved.
Changes made will be automatically saved.
Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
Click the « Tools » button, then « Internet Options ».
Click the « Privacy » tab, then under « Settings », move the slider up to block all cookies or down to allow them, then click OK.

Google Chrome

https://support.google.com/chrome/answer/95647?hl=fr

Select the Chrome menu icon.
Select « Settings ».
At the bottom of the page, select « Show advanced settings ».
In the « Privacy » section, select « Content settings ».
Select « Block all sites from storing data ».
Select OK.

Safari

https://www.apple.com/legal/privacy/fr-ww/cookies

Click « Settings » > « Safari » > « Privacy » > « Cookies and website data ».
Then select « Always block ».

Please note that if you block the use of cookies through this browser setting, you may not be able to use or view all or part of the website, including our site.

In addition, if you want to block the use of analytics cookies and/or advertising and retargeting cookies, both provided by our third-party service providers, please access the following URL to refuse the use of these cookies.

Google Analytics: cookie deactivation

Description of cookies and their purpose:

Google Analytics _ga;

Google Analytics _gid. These cookies are used to distinguish users. [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage];

Google Analytics _gat. These cookies are used to reduce the number of requests. However, if Google Analytics is deployed via Google Tag Manager, these cookies will be named: _dcgtm. [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage].

Google Analytics is a web analytics service provided by Google LLC (« Google »). The information generated by cookies about your use of the website is generally transmitted to a Google server in the United States and stored there.

Google will use this information on our behalf to analyze your use of the site, compile reports on site activity and provide us with other services related to site use and the Internet in general. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can object to the use of data generated by cookies in the context of using our website (in particular your IP address) and the processing of this data by Google by downloading and installing the plug-in available on your browser at the following address: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

14. CONTACT INFORMATION

If you have any other questions or comments regarding our Privacy Policy, please contact us at privacy@testwe.eu or by mail at the following address: TestWe, GDPR Service, 6 rue de Notre Dame de Nazareth, 75003 Paris.

15. CONTACT INFORMATION

TestWe may modify this Privacy Policy from time to time to reflect the evolution of its privacy practices. When we modify this privacy policy, we also modify the « last updated » date at the top of the first page. We encourage you to regularly consult this Privacy Policy to be informed of how TestWe protects your personal data.