Website Privacy Policy

Data Protection Officer: Michal Mazanek, CEO, Mobile Testing Solutions Ltd (MTS).

How we use your information: for administrative and business purposes particularly to contact you and provide our services to you, to improve our business and website, to fulfil our contractual obligations, to advertise our services, to analyse your use of our website, and in connection with our legal rights and obligations.

Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers to fulfil any contracts we enter into with you, or where required by law or to enforce our legal rights.

Do we sell your information to third parties?: No.

How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes). Test-taker data are typically kept securely on file by us for a maximum period of 3 years, in order to facilitate potential future enquiries or disputes.

How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, SSL encryption for data transfers and payments, and access controls. We have in place various technical and organisational measures to minimise the risk of loss, corruption, damage and unauthorised access.

Use of cookies and similar technologies: we use cookies and a similar information-gathering technology called Facebook Pixel on our website. These cookies are mostly Functional and Analytical cookies. For more details, see our Cookies Policy.

Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law. Where we do so, we will ensure appropriate safeguards are in place.

Use of automated decision making and profiling: we do not use automated decision making or profiling.

The Data Protection Officer in respect of our websites is Michal Mazanek, CEO, Mobile Testing Solutions Ltd (MTS).

MTS is a limited liability company incorporated in England and Wales (company number 8706098).

You can contact the data controller by writing to: CEO, MTS Ltd, 65 Westcroft Square, London, W6 0TA. Or you can email at GDPR@mtsglobal.uk.com.

Web Server Log Information

We use a third party server to host our website. The third party is called UKFast.Net Limited (“UKFast”), the privacy policy of which is available here: UKFast Privacy Policy. The website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website, and your browser version and operating system.

The website server is located in the United Kingdom in a secure ISO-certified, tier 3 data centre, owned and managed directly by UKFast.

Use of website server log information for IT security purposes

Our third party hosting provider UKFast collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks.

We do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals.

Legal basis for processing: our and UKFast's legitimate interests (Article 6(1)(f) of the GDPR).

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. We may use the information gathered from the analysis of this information to improve our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR).

Legitimate interest: improving our website for our website users and getting to know our website users' preferences so our website can better meet their needs.

Email

When you send an email to any of the email addresses displayed on our websites we collect your email address and any other information you provide in that email.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR) or necessary to perform a contract (Article 6(1)(b) of the GDPR).

Transfer and storage of your information: We use a third party email provider to store emails you send us. Our third party email provider is Gmail, a service provided by Google. Emails you send us could be stored within or outside the European Economic Area on Google server data centers, which are located all over the world.

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation. We do not record phone calls.

Transfer and storage: Information about your call is processed by our third party telephone service provider, Onebyte, in the UK. Their privacy policy is available here: Onebyte Privacy Policy.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Registering and ordering on our websites

When you book a test or any of our other products on our website, we may collect the following information: Name, date of birth, gender, address, phone number, email address, identification document type, identification document number (e.g. passport number), details of any access/special requirements, card payment details.

For some tests, we may also ask for additional information for monitoring purposes: Nationality, first language, occupation sector, occupation level, reason for taking the test, intended destination country, where you are studying currently, level of education, years spent studying.

Legal basis: necessary to perform a contract (Article 6(1)(b) of the GDPR).

Processing your payment

In order to process your payment we use third party payment processors PayPal and FirstData. These organisations collect, use and process your information, including payment information, in accordance with their privacy policies:

• PayPal Privacy Policy
• FirstData Privacy Policy

In order to fulfil certain tests that we provide with testing authorities (e.g., IELTS from the British Council and some Cambridge tests from the University of Cambridge) we may send information about you to these third parties. We may also receive information about you from these third parties.

Any data sharing is governed by specific data protection and data sharing contracts, and data is handled and stored securely, according to the GDPR.

Where we receive information about you in error: If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Disclosure of your information to service providers

We share your information with service providers to run our business efficiently. These include:

• Onebyte (Telephone & IT support): Onebyte Privacy
• Google (Gmail & Analytics): Google Privacy
• UKFast (Website hosting): UKFast Privacy
• PayPal & FirstData (Payment processors)
• British Council, Cambridge Assessment English, Cambridge Testing (Test Providers & Exam Boards)
• Zoom (Videoconferencing): Zoom Privacy
• Facebook, Reputation Stacker (Personalisation & Marketing)

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, such as in connection with website analytics (Google Analytics), running our business (accountants Alpha Accountants based in London, business partners, independent contractors), in the event of a major business transaction, or for legal reasons (police, legal disputes, ongoing compliance with laws).

We retain customer details for as long as they are needed for the relevant purposes.

We take appropriate technical and organisational measures to secure your information and protect it against unauthorised or unlawful use and accidental loss or destruction:

• minimising access to information to the minimum extent necessary;
• using secure servers;
• verifying identities of access requestors;
• securing digital records on MTS’s Content Management System (ISEVA) or British Council's ORS;
• securing physical records (paper, audio recordings, fingerprint scans) via locked doors, key cabinets with 4-digit coded locks, padlocks, and CCTV in the secure storage room.

In the majority of cases, your information is stored in the United Kingdom and Ireland. In some cases, information may be transferred and stored outside the EEA, such as Google (Gmail/Analytics), PayPal, Facebook, and Zoom located in the United States, utilizing safeguards such as the EU-U.S. Privacy Shield.

Subject to certain limitations, you have the right to request access, correction, deletion, restriction, portability, objection, and withdrawal of consent in relation to your information by writing to: MTS, 65 Westcroft Square, London, W6 0TA or emailing GDPR@mtsglobal.uk.com.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO): ICO Contact Page.

You have the right to object to us using or processing your information where we use or process it for our legitimate interests or for direct marketing purposes (including profiling). You can object by emailing GDPR@mtsglobal.uk.com with the words “OPT OUT” or clicking the unsubscribe link in emails.

‘Personal & Sensitive information’ is information revealing racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data, health information, or sexual orientation.

MTS may hold medical information (for special arrangements or refunds), biometric finger scan data (retained as BLOB for IELTS tests), and country of origin/nationality.

In accordance with MTS's Safeguarding Policy, online course sessions are digitally recorded (audio-only) and securely stored to protect children and vulnerable adults.

We update and amend our Website Privacy Policy from time to time. Minor changes will update the effective date. Major changes will be notified via email or a notice on our website.