Privacy Policy

ICVC Privacy Policy: How We Protect Your Personal Information

The International Credential Verification Center ("ICVC" or "we") respects your privacy and is committed to protecting it. This Privacy Policy describes the types of information we may collect from you and other parties, and our practices regarding the use, preservation, protection, and disclosure of that information. We collect your information through our website, https://www.icvc.edu.new, and our mobile application (the "App"), including when you request information from us or apply for our credential evaluation and verification services (collectively, our "Services"). Additionally, we collect information about you from other sources when we provide the services you have requested. This policy does not apply to information collected through any external website accessible through our website or App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will handle it. If you do not agree with our policies and practices, you may choose not to use our Services. By accessing or using our website or App, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed acceptance of those changes, so please review this policy periodically for updates.

1. Categories of Personal Data Collected

This policy describes how we collect, use, and protect various types of information about you, including personal information that can directly or indirectly identify you ("Personal Data"). We collect only Personal Data that is reasonably necessary for the purposes for which it is collected. Depending on your interaction with us, we may collect, use, store, disclose, and transfer your Personal Data, including:

• Personal identification information, such as your name, mailing address, email address, telephone number, date of birth, and financial information related to your use of our website or App;

• Professional or employment-related information and other information you submit to us, such as your student identification number, educational documents (degree certificates, diploma supplements, transcripts, institutional certifications, and other similar documents that may vary depending on the country of study), your ICVC reference number, your grade point average (GPA), professional certifications, accreditation type, certificate or credential number, country of residence and education, security questions and answers, and other information that may appear on materials submitted to our Services by you or by an institution on your behalf;

• Internet or other network activity information, such as information about your internet connection, your IP address and location data, the device you use to access our website or App (operating system, mobile device type, and/or browser type), and website or App usage details, including password credentials used to access our website or App.

2. Collection of Personal Data

We generally collect Personal Data directly from you when you browse our website or interact with us directly, to the extent necessary for the purposes described below.

Information You and Third Parties Provide to Us

Under the EU General Data Protection Regulation ("GDPR"), ICVC is the data controller of your Personal Data. We process your Personal Data in accordance with the GDPR, the Personal Information Protection and Electronic Documents Act (Canada), and similar laws such as the CPRA (USA). We collect Personal Data for the provision of our Services from the following sources:

• Forms you complete on our website or App, such as when ordering an ICVC credential evaluation, using ICVC website or App tools, registering for ICVC events, or using other online services;

• Documents you submit to us related to the services you have requested;

• Materials you complete in your application and authorize third parties to provide information to us;

• Correspondence and copies of communications between you and us, or documents submitted to us by third parties on your behalf, such as educational institutions you attended or third-party intermediaries;

• Responses to surveys, focus groups, or user testing studies you are invited to complete for research purposes;

• Details of the services you order from us (including through our website or in or through our App), and information related to our fulfillment of the services you request, including financial information for ordered services.

The Personal Data we collect from you may be necessary for the formation of a service contract with ICVC for the evaluation and verification of your educational credentials. If you refuse to provide such Personal Data or withdraw your consent for our processing, we may not be able to form the contract and fulfill our obligations to you thereunder.

Information We Collect Through Automatic Data Collection Technologies

When you browse and use our website or App, we may use the following automatic data collection technologies to collect certain information about your device, browsing behavior, and patterns:

• Details of your visits to our website or use of our App, including usage data, location data, logs, and other communication data, and the resources you access and use on the website;

• Information about your computer, mobile device, and internet connection, specifically your IP address, operating system, and browser type.

We use these technologies to collect information about your online activities on our website, App, or other online services (behavioral tracking). Certain web browsers and mobile operating systems allow you to signal to websites and online services that you want them to "do not track" your online activities. Currently, we do not respond to such signals and do not adjust our information collection or use practices based on whether such signals are broadcast or received.

Information we collect automatically may include Personal Data we obtain from third parties. This information helps us improve our website and App and provide better, more personalized services by enabling us to:

• Estimate our audience size and usage patterns;

• Store your preferences so we may customize our website or App according to your individual interests;

• Speed up your searches;

• Recognize you when you return to our website or App.

Technologies we use for this automatic data collection include:

• Cookies (or browser cookies). A cookie is a small file stored on your computer's hard drive. We only store cookies on your hard drive with your consent. You can refuse to accept browser cookies by enabling the appropriate setting in your browser or mobile operating system. However, if you select this setting, you may be unable to access certain parts of our website or App, including those related to logging into your account for credential evaluation. You can learn more about cookies at https://www.allaboutcookies.org and https://youronlinechoices.eu.

• Web beacons. Our website pages, App interfaces, and emails may contain small electronic files called web beacons (also known as clear GIFs, pixel tags, or single-pixel GIFs) that allow ICVC to count users who have visited those pages, accessed corresponding interfaces, or opened emails, and for other related website and App statistics (e.g., recording popularity of specific website and App content and verifying system and server integrity).

We may also collect information you share about ICVC on social media platforms such as Facebook and Twitter.

3. How We Use Your Personal Data

We generally use your Personal Data in the ordinary course of our business to provide products and services to you through our website and App, and for purposes supporting our business, research and development, marketing, or other purposes, subject to obtaining your prior consent or to the extent permitted or required by law.

General Business Purposes

We use information we collect about you, including your Personal Data, for the following legitimate purposes:

• To present our website or App and their contents to you;

• To provide you with the information and services you request from us;

• To verify information and credentials submitted for evaluation;

• To enable you to update or upgrade certificate services in the future, or to provide you with additional copies of existing credential evaluations;

• For any other purpose for which you provide the information;

• To provide you with notices about your account;

• To fulfill our obligations and exercise our rights under any contract between you and us, including for billing and collection;

• For research material compilation;

• To notify you of changes to our website, App, or any products or services offered through them;

• In any other way we may describe when you provide the information;

• To comply with our legal and regulatory obligations;

• For any other purpose with your consent.

With your consent, we may also use your information to contact you about our own and third-party goods and services that may be of interest to you. If you agree to this use, please check the appropriate box on the form where we collect your data. If you no longer wish to receive such communications, please let us know through our Contact Us page. For more information, see Choices About How We Use and Disclose Your Information.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or resources on this website and App are provided by third parties. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly via the links provided on their website. For information on how to opt out of targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Legal Basis for Processing Your Personal Data

If you are located in the EU or Canada, processing of your Personal Data is lawful only to the extent permitted by applicable data protection laws. We have a legal basis for processing your Personal Data (unless an exception below applies):

• Consent. By using our Services and agreeing to this Privacy Policy, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our website or App. If you reside in Canada, you hereby consent to the collection, use, and disclosure of your Personal Data in accordance with this Privacy Policy.

• Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Specifically, our legitimate interests include: facilitating communication between ICVC and you; continuously improving our website or App by evaluating your usage and potential issues; improving our products and services by analyzing statistical trends of you and other users; using your email or other contact information to contact you for business promotion; logging your IP address for intrusion detection purposes to protect our IT infrastructure and intellectual property; detecting and preventing fraud and other criminal activities and conducting risk assessments. Our legitimate interests will be weighed against your rights and freedoms; if your rights and freedoms override our legitimate interests, we will not process your Personal Data. If you reside in Canada, except for protecting our IT infrastructure and intellectual property and for detecting and preventing fraud and other criminal activities, we process your Personal Data only on the basis of consent as described above.

• For performance of our contractual obligations to you. We process your Personal Data to provide services to you under a contract with you, to evaluate and verify your credentials, and to compile your evaluation report. If you reside in Canada, we access, use, or disclose your Personal Data only on the basis of consent as described above.

• As required by law. We may also process your Personal Data where required or permitted by law; to cooperate with government inspections, audits, and other valid requests from government or other public authorities; and to respond to legal processes such as subpoenas; or where necessary for us to protect our interests or exercise our rights and remedies under law (e.g., where necessary to prevent or detect fraud, attacks on our network, or other criminal and harmful activities, to respond to litigation, and to handle complaints or claims). If you reside in Canada, we may process your Personal Data in certain circumstances: when we have reasonable grounds to believe the information could assist in investigating a violation of federal, provincial, or local law; and in connection with collecting debts owed to WES; to comply with a subpoena, warrant, or court order from a court or other competent authority; or to provide to a government agency that has requested the information. For all other uses of your Personal Data described in this Privacy Policy, we access, use, or disclose your Personal Data only with the consent described above.

Processing of Sensitive Personal Data

ICVC does not request any Personal Data classified as special categories of personal data under the GDPR ("Sensitive Personal Data"). Please do not provide any information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, health status, sex life or sexual orientation, or any other personal information not expressly requested in the WES online application form.

Automated Decision-Making

ICVC does not use Personal Data for any automated decision-making processes that may have a legal effect on you.

4. Disclosure of Your Personal Data

We do not share, sell, or otherwise disclose your Personal Data for any purpose other than those described in this Privacy Policy or as otherwise authorized by law. However, we may disclose aggregated information about our users and information that does not identify any individual without restriction. We may disclose Personal Data we collect or you provide as described in this Privacy Policy:

• To contractors, service providers, and other third parties we use to support our business, all of whom are contractually obligated to keep Personal Data confidential and use it only for the purposes for which we disclose it. Specifically, these entities include:

• IT and infrastructure support service providers related to the management and maintenance of our IT infrastructure;

• Courier and mailing service providers for sending information to you.

• To educational institutions you list in your credential evaluation application and educational authorities that issued your credential documents or may have information about you, and their third-party service providers, for the purpose of verifying your educational credentials;

• To licensing authorities and relevant authorities that have issued a license to you or may have information about you, and their third-party service providers, for purposes related to license verification or related information;

• To third parties you have authorized us to send your credential evaluation report to, to fulfill your request;

• In the event of a merger, reorganization, restructuring, dissolution, or sale or transfer of part or all of WES's assets, Personal Data held by WES about our customers may be among the transferred assets;

• Where you have consented to the disclosure, we may provide your Personal Data to third parties to enable them to market their products or services to you and to assist us in marketing our services to you. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it. For more information, see Choices About How We Use and Disclose Your Information;

• To fulfill the purpose for which you provide it;

• For any other purpose we disclose when you provide the information; and

• With your consent.

We may also disclose your Personal Data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes; and

• If we believe disclosure is necessary or appropriate to protect the rights, property, security, or reputation of WES, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

5. Your Choices and Privacy Rights

Choices About How We Use and Disclose Your Personal Data

We do not control the collection and use of your Personal Data by the recipients you designate or the third parties described above. These third parties may provide you with ways to opt out of the collection or use of information through the links above. Where possible, these entities are contractually obligated to use Personal Data only to provide necessary services to us and to keep such information strictly confidential. However, these third parties may aggregate information they collect with information about their other customers for their own purposes.

Additionally, we are committed to providing you with choices regarding the Personal Data you provide to us. We provide the following mechanisms for you to exercise control over your Personal Data:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the WES website or App, particularly those related to logging into your created account, may be inaccessible or not function properly.

• Targeted Advertising and Promotional Offers from ICVC. We participate in interest-based advertising, and we or third parties may use information about you to show you or allow you to see specific advertisements related to your interests, search behavior, information you provide, and your activities on our website or other websites. We will use your Personal Data to market our own products and services only with your consent. If you wish to consent to such use, you may check the appropriate box on the form where we collect your Personal Data, or your consent may be otherwise solicited. If you wish to change your choices, you may adjust your user preferences in any promotional email we send, or send us a reply indicating your preferences. You can also contact us through our Contact Us page. This opt-out does not apply to information provided to the company as a result of our providing services you request, warranty registration, product service, or other transactions.

Your Rights of Access and Correction of Personal Data

Applicable data protection laws may grant you certain rights regarding our processing of your Personal Data.

• Access and Correction. You can review and modify some of your Personal Data by logging into the website or App and accessing the "My Account" page or interface. You can also notify us of any changes or errors in your Personal Data we hold through the contact information below, to ensure it is complete, accurate, and as current as possible. Please note that if you request access to your Personal Data through channels other than this website or App, a fee may be charged, but no more than the maximum permitted by applicable law. Additionally, we may not be able to accommodate your request if we believe it would violate any law or legal requirement, or cause the information to be incorrect.

• Restriction. In certain circumstances, you have the right to request that we restrict the processing of your Personal Data. In particular, you may request that we restrict the use of your Personal Data when you contest the accuracy of the Personal Data, the processing is considered unlawful, or we no longer need your Personal Data for processing but it is required for legal reasons.

• Portability. To the extent that Personal Data you provide to ICVC is processed based on your consent, you have the right to request that we provide you with a copy of all or part of your Personal Data in a structured, commonly used, and machine-readable format, or allow you to access such Personal Data. You also have the right to request that we transmit this Personal Data to another controller, where technically feasible. Please note that we cannot return any documents you provide to us.

• Withdrawal of Consent. For users of our website, App, and marketing tools, if our processing of your Personal Data is based solely on your consent, you may withdraw that consent at any time. However, withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal, nor will it affect our ability to continue processing your Personal Data based on other lawful processing grounds.

If you have entered into an evaluation service agreement with ICVC, under our Terms and Conditions, you have the right to withdraw your application (subject to cancellation fees). Unless we receive verified information regarding fraud, ICVC will no longer contact you regarding your evaluation; in such cases, we will notify you and the relevant authorities.

• Right to be Forgotten. For users of our website, App, and marketing tools, you have the right to request that we delete all your Personal Data. If you have registered an account and applied for our education evaluation and verification services, you have the right to cancel your profile (subject to cancellation fees).

You have the right to be forgotten where we have no lawful basis to refuse the request. Personal Data you provide to WES will be retained in accordance with our data retention policy. We may not be able to accommodate your request to correct information if we believe it would violate any law or legal requirement, or cause the information to be incorrect. Additionally, we cannot completely delete your Personal Data, as some data may remain in previous backups. These backups will be retained for the period specified in our disaster recovery policy.

• Complaints. You have the right to lodge a complaint with the relevant supervisory authority in the country where you reside, work, or where you believe your rights under applicable data protection laws have been violated. Before doing so, we kindly ask that you contact us directly so we have the opportunity to address your privacy concerns directly with you.

• How to Exercise Your Rights. You can exercise any of the above rights by contacting us through the contact information below. If you contact us to exercise any of the foregoing rights, we may require additional information to verify your identity. We reserve the right to limit or deny your request if you fail to provide sufficient information to verify your identity or meet our legal and business requirements.

Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"), provides you with the following rights regarding your Personal Information:

• You have the right to know what Personal Information we have collected, used, disclosed, and sold about you, including the categories of Personal Information, the categories of sources from which the Personal Information was collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom ICVC discloses Personal Information, and the specific pieces of Personal Information ICVC has collected about you.

• You have the right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of processing.

• You have the right to request that we delete any Personal Information we hold about you.

• You have the right to opt out of the sharing of your Personal Information. You may exercise this right through our Contact Form on our website, or by modifying your privacy preference settings such as the Global Privacy Control, which can be enabled through certain internet browsers and extensions to signal your desire to opt out. Please note that clearing your cookies at any time will remove your selected privacy preferences.

To submit any of the above requests, you may contact us by email at ADMIN@ICVC.EDU.NEW. If making a request by email, please include "CCPA Request" in the subject line. You may also designate an authorized agent to make a request on your behalf. When you exercise these rights and submit a request to know, correct, or delete, we will verify your identity by requesting additional information from you, such as your email address or the last four digits of the credit or debit card used for purchases. We may also engage a third-party verification provider to verify your identity. We will endeavor to respond unless the request conflicts with certain statutory exemptions under the CCPA. Please note that you may only make two requests to know within a 12‑month period.

We will not discriminate against California residents who exercise any of the rights set forth in this Privacy Policy. Your exercise of these rights will not adversely affect the price and quality of our goods or services.

Additionally, as set forth below, California law requires us to disclose information about you that we may have "sold" or "shared" in the 12 months preceding the effective date of this Privacy Policy. During the 12 months preceding the effective date of this Privacy Policy, ICVC did not sell any Personal Information of its customers. During the 12 months preceding the effective date of this Privacy Policy, ICVC only shared Personal Information of its customers in the manner described above. ICVC does not use or disclose Sensitive Personal Information, as defined under applicable law, for purposes other than those permitted by applicable law.

Opt-Out Preference Signals: We are working to implement the Global Privacy Control (GPC) as an additional option for you to submit a request to opt out of the sale and sharing of your Personal Information through browsers and/or browser extensions that support such signals. Until then, you may opt out of personalized advertising using third-party cookies as described above.

California Civil Code Section 1798.83, also known as California's "Shine the Light" law, allows users of our website or App who are California residents and who have provided Personal Data in connection with obtaining products or services for personal, family, or household use to request information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of all businesses with which we shared your Personal Data in the immediately preceding calendar year (e.g., a request made in 2023 would receive information regarding activities in 2022). You may request this information once per year. To make such a request, please contact us using the contact information below. If you make this request by email, please include "California Shine the Light Request" in the subject line.

6. Data Security

We have implemented physical, organizational, contractual, and technical measures designed to protect your Personal Data from accidental loss and unauthorized access, use, modification, and disclosure. All browser and other network connections between our App and our website and our servers are encrypted using SSL technology. All credit card transactions are processed by third-party payment gateways compliant with the Payment Card Industry Data Security Standard (PCI-DSS). Any information sent to WES in physical form, such as paper, will be scanned into electronic format, and the physical copy will be securely destroyed. All electronic information is securely stored using industry-standard access controls and data protection mechanisms. WES has deployed multiple security measures to protect the integrity of our systems, including intrusion prevention and detection systems.

The security and protection of your information also depend on you. Where we have provided you with (or you have chosen) a password for access to certain parts of our website or App, you are responsible for keeping that password confidential. We ask you to use a unique password for this website and never to disclose your password to anyone. To protect your account, we may periodically prompt you to change your password. In accordance with best security practices, ICVC stores only encrypted hashes of your passwords, not plain-text passwords. If you forget your password, we can help you reset your account and set a new password, but we cannot retrieve your old password.

Unfortunately, transmission of information over the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our website or App. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our App, website, or servers accessed through the App.

7. Cross-Border Transfer of Personal Data

If you are a resident of the European Economic Area ("EEA") or Canada, we may transfer and store your Personal Data outside the EEA and Canada, including to the United States, to provide our Services. Therefore, your Personal Data may be transferred to countries outside your country of residence, including those that may not or do not yet have adequate levels of protection for your Personal Data. Your information may be processed and stored in the United States and other jurisdictions where federal, state, and local governments, courts, law enforcement, or regulatory agencies may be able to disclose your information under local law. By using our Services, you acknowledge that you have read and understood the foregoing and agree to the storage and processing of your Personal Data provided to the Service outside the EEA and Canada, including, but not limited to, the United States.

Where applicable, your Personal Data will only be transferred by WES to other countries where required or permitted by applicable data protection laws, and where appropriate safeguards are in place to protect your Personal Data. To ensure that your Personal Data (excluding Personal Data you provide directly to services located outside the EEA) is processed in accordance with this Privacy Policy, WES has entered into data protection agreements with all other data recipients that include, where applicable, the standard contractual clauses adopted by the European Commission ("Standard Contractual Clauses"). The European Commission has determined that transfers of Personal Data under the Standard Contractual Clauses provide adequate protection for your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data had not been transferred to such third parties. You may request a copy of the data protection agreement by contacting us through the contact information below.

8. Data Retention Policy

Data from users of our website, App, and marketing tools will be retained:

• For as long as necessary to fulfill the purposes for which the data was collected, or to comply with any legal requirements;

• For as long as necessary to establish your identity and prevent fraud;

• In our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;

• For as long as necessary to protect our legitimate interests or exercise our legal rights and remedies; and

• Indefinitely for materials that have been aggregated or otherwise anonymized such that you can no longer be identified.

Criteria we use to determine retention periods include: (a) the length of time we have an ongoing relationship with you and provide services to you; (b) whether we have a legal obligation to do so; and (c) whether retention is advisable in light of our legal position (such as applicable statutes of limitations, litigation, or regulatory investigations).

9. Personal Data of Minors (Children Under 16)

WES can only provide services to children if their parent or legal guardian provides us with their Personal Information. If you are under 16, please do not register on this website or App, or provide any information to our Services, including your name, address, telephone number, email address, or any nickname or username you may use. If we discover that we have collected or received information from a child under 16 without verification of parental or guardian consent, we will delete that information. If you believe we may have any information from or about a child under 16, please contact us through the contact information below. Minors under 18 may request deletion of their Personal Information provided to us through this website by emailing ADMIN@ICVC.EDU.NEW. We do not have actual knowledge that we sell or share Personal Information of consumers under 16.

10. Changes to Our Privacy Policy

We may modify this Privacy Policy at any time. It is our policy to post any changes we make to this Privacy Policy on this page and to notify users that the Privacy Policy has been updated through a notice on the WES Important Notices page and in our App. If we make material changes to how we treat our users' Personal Data, we will notify you through the email address specified in your account and/or through a notice on the website home page and the App main interface. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you and for periodically visiting our website or logging into the App and reviewing this Privacy Policy to stay informed of any changes.

11. Contact Information

ICVC has appointed a Data Protection Officer under the GDPR and has established a representative in the EU. If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy, or if you have any request regarding your Personal Data under applicable law, or otherwise need to contact us, please reach out to us through the contact information below or through the Contact Us page on our website and App.