At WPS, your privacy is very important to us. PLEASE READ THE FOLLOWING CAREFULLY. If you are under the age of eighteen (18), please read with your parent or guardian.
Statement of Data Privacy
WPS provides psychological assessments and related intervention resources that improve clinical evaluation, inform diagnosis, and guide therapy, thereby serving clinicians, educators, and researchers who use these tests (“test users”). On behalf of its test users , WPS collects certain personal data from test users and their test taking customers, whether those individuals are residents of the United States, the EU, or any other country, or when WPS is provided with test takers’ personal information by test users. WPS may also collect personal information from visitors to our Websites.
This personal information includes, but is not limited to, name, contact information (e.g., postal address, email), demographic information, information proving eligibility for WPS’s services, ADA/accommodations-related information, scheduling information, and testing-related information and results. WPS uses this data to fulfill its assessment services under contracts with our customers and their test takers. We may share personal information in order to securely fulfill assessment services, but we will not provide it, or sell it, to any third party who is unrelated to WPS or its services. This Policy provides an overview of how we obtain, store, and use your personal information. It is intended to provide a general overview and answer questions you may have about specific privacy issues.
The Policy applies to everyone, regardless of where they reside, who has dealings with WPS that results in the collection of personal information. However, please be aware that if you reside in the European Union (“EU”), this explanation and summary of the Policy is specifically designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), which became effective on May 25, 2018. Similarly, if you reside in California, this summary of the Policy is designed to meet the requirements of current California law as well as the California Consumer Privacy Act (“CCPA”) as amended, when it becomes effective in 2020.
Identity of the Data Controller
Under the GDPR, a data controller is the organization who dictates how—and for what purpose—data will be used. A data processor carries out processing of that data on behalf of a data controller. Normally, WPS is not a data controller. However, for certain test taker data that we collect, WPS may be the data controller. In these limited situations, WPS conducts a variety of data analyses and research related to testing outcomes using your anonymous personal information on an aggregated basis. When we conduct these analyses, you are not personally identified and none of your personal information is disclosed.
In most other instances, WPS functions as the data processor or the data collection agent for our customers (i.e., the test users who purchase our assessments/assessment services and administer tests to their clients), who are the actual data controllers. The data controller is responsible for deciding the purposes for which personal information is used and processed, and the means by which such processing is done. Thus, it is the data controller’s responsibility to inform you in advance of the processing of your personal information and to explain your privacy rights. You should make any inquiries and/or requests about your data directly to the actual data controller, if you have that information. In order to facilitate your contacting the actual data controller, if you request it, WPS will pass along your inquiries and/or requests to the relevant data controller. As a data processor, WPS will follow the instructions we receive from our data controller customers in responding to your request.
You may contact WPS by writing to WPS at the address shown in the Contact section of this Policy, or by sending an email to firstname.lastname@example.org.
What are your rights?
Your rights in relation to your personal information are to: (1) be informed about its use; (2) have access to your information; (3) correct your personal information; (4) have your personal information deleted in certain situations; and (5) restrict how we use your personal information.
In addition, you have the right to be forgotten, but this right is limited in a testing environment. In most situations, previous test results are exempt from this right because they may be necessary to establish, exercise, or defend legal claims, or they are required by test users to exercise various business obligations/rights they have related to your purchasing assessments/assessment services or other similar business purposes.
You also have the right to have your personal information transferred to others; however, because WPS’s use of your personal information is limited to fulfilling the education and assessment services for which you contracted with our customers, it is usually not technically feasible for WPS to honor such a request because we are not able to exchange that information with another entity with which we have no direct interface or where WPS has no existing business reason to exchange data (e.g., another testing organization that requires the test users or test takers to register directly with it).
You are also entitled to know if WPS is using any automated decision-making (including profiling). WPS does not use any such automated technologies in its processing of your personal information.
Exercising your rights regarding the collection and use of your personal information
You have the right to withdraw your consent at any time during or subsequent to your use of our Websites by emailing WPS at email@example.com. However, any data processing performed by WPS prior to your withdrawal of consent cannot be undone. In situations where the data controller is another entity, you will need to exercise your rights directly with that entity, who will notify WPS of its handling of your request so that we can follow its instructions.
You also have the right to object to WPS’s collection and/or use of your personal information, to request access to your information, and to request that we correct any information we have or to remove you from our records. If your personal information changes (e.g., phone, email, or postal address), you can change any online, physical contact, and/or other personal information by contacting WPS as shown above. If you wish to correct/update/delete information or no longer desire to receive information from WPS, you can notify us by using any of the information in the Contact section of this Policy. We will respond to your request without undue delay, within a maximum of 30 calendar days.
You may file a complaint with WPS by emailing us at firstname.lastname@example.org, and WPS will respond without undue delay, within a maximum of 30 calendar days, unless we inform you that additional time will be required. In addition, you have the right to file a complaint with your relevant Supervisory Authority (i.e., Data Protection Authority) or other enforcement entity.
WPS’s legitimate interests for collecting/using your personal information
We collect and use your information because you have contracted with and/or given your affirmative consent to a test user and/or directly to WPS. We use the information given to us by you and/or the test user you are dealing with to fulfill the assessment service(s) that you contracted to receive. These services can include: scoring a test you took at the request of a test user; conveying your test results to you or the test user, and aggregating anonymous testing statistics pooled from many test takers to help ensure that the assessments we market are properly constructed, valid, and reliable.
How does WPS obtain your consent?
At the end of this Policy, you will be asked to indicate your affirmative consent by agreeing to its terms and conditions, and thereby allowing WPS to collect and use your personal information. In other situations, WPS relies on the consent you have given the test user with whom you are working, or the contractual rights that test user has with you. In other situations, WPS has other legitimate bases (e.g., legal contract) for collecting and using your personal information; we will notify you of those alternative bases.
WEBSITE COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION
WPS recognizes the importance of protecting the privacy of visitors to our Websites. As you interact with our Websites, we may collect certain types of personal information about you. Personal information may be used by WPS to fulfill its assessment services, to process online purchases, to inform about products and services, to improve the products and services we offer, and otherwise to better meet the needs and preferences of WPS customers.
WPS reserves the right to monitor your use of the Websites to determine if you are complying with our terms and the right, in its sole discretion, to terminate your access to the Websites.
CALIFORNIA PRIVACY RIGHTS
Residents of the State of California, under California law, have the right to request in writing from companies conducting business in California, a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. WPS does not disclose personal information to any third parties for direct marketing purposes.
Additionally, California law requires that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is an online procedure that is currently under development. Because this Website feature is not yet finalized, we adhere to the procedures set out in this Policy and do not monitor or follow any “Do Not Track” browser requests. However, WPS may provide follow-up notifications to our customers. You may request withdrawal from such communications by writing to us at the address provided in the Contact section.
Under the newly enacted California Consumer Privacy Act (“CCPA”) which becomes effective in 2020, California residents will be allowed to: (1) see what data companies collect on them; (2) request that it be deleted; (3) know what third-party companies their data has been sold to; and (4) direct businesses to stop selling that information. If you desire to make a request under the CCPA or applicable California law, you should write to us at the address provided in the Contact section.
Most web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. However, refusing a cookie may, in some cases, preclude you from using the Websites, or negatively impact the display or function of the Websites or certain areas or features of the Websites.
Our server automatically collects data about your server’s Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that’s automatically assigned to your computer by your Internet Service Provider whenever you’re on the Internet. When you request pages from our Websites, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on our Websites; the website you visit after our Websites; the ads you see and/or click on; other information about the type of web browser, computer, platform, related software, and settings you are using; any search terms you have entered on our Websites or a referral site; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our server, and to administer our Websites. Such information may also be used to gather broad demographic information about visitors to our Websites, such as country of origin and Internet Service Provider.
Retention of your personal information
WPS does not retain personal information longer than is necessary, taking into account any legal obligations we have (e.g., to maintain records for tax purposes), as well as any other legal basis our test user customer has or we have for using your personal information (e.g., your consent, performance of services to you and/or our customers, or our legitimate interests in providing assessments/assessment services).
SECURITY OF PERSONAL INFORMATION
In connection with your purchases at www.wpspublish.com, we may use a third party payment service provider to collect your credit card number and related information (e.g., expiration date, card verification code). The third party provider conducts the financial transaction in a secured manner by collecting your payment information through a secured Internet connection via SSL/TLS. The third party payment mechanism will be accessible via a hyperlink from the website and the third party provider will be solely responsible for all financial transactions and the collection, use, and storage of your credit card [or debit card] information. In connection with your purchases, additional personal information may be requested, such as full name, billing and shipping address, e-mail address, and telephone number and any such information that is required to fulfill your order and to communicate with you regarding your order. Our payment service provider will only use your payment information to complete the specific transaction you requested; WPS does not store or retain your personal information after completion of the transaction.
Please remember that no data transmission over the internet, or by other means, can be guaranteed to be 100% secure. Thus, while we strive to protect your personal data, WPS cannot ensure or warrant the security of any information you transmit to us. As noted above, our third party payment provider uses a secured connection for the collection of payment information, but WPS may not use a secured connection for other types of activities. Therefore, you understand, acknowledge, and agree that you transmit certain personal information at your own risk.
Once we receive your data, we use reasonable efforts to ensure the information you provide is secure and not readily available to unauthorized individuals or third parties. Such efforts may include storing your data on encrypted hardware that is only accessible to authorized and limited parties on a need-to-know basis. In securing personal information, WPS utilizes generally-accepted technical and organizational measures to protect personal data against loss, misuse, or alteration throughout collection, transmission, processing, and storage, including the physical security of our facilities.
WPS - Western Psychological Services
625 Alaska Avenue
Torrance, CA 90503-5124
or via email: email@example.com
WPS ADVERTISING AND PROMOTIONAL E-MAILS
WPS only sends advertising and promotional e-mails to those who have consented to receive such communications. You can “opt out” of receiving advertising and promotional email from us in compliance with federal law by following the opt-out instructions in our email messages. To ensure that your opt-out request is honored, you must use the designated method in the email message to notify us of your opt-out request, as we cannot guarantee that other methods of notification will be effective or timely. Please note that even if you choose to opt out of WPS’s marketing, we will continue to send you important service-related communications (e.g., order confirmations).
MONITORING AND USE OF AGGREGATE INFORMATION
We reserve the right to monitor and edit any personal information about our users, including information about the use of website activities and services and the contents of users’ email messages for internal purposes. We will take such measures if we believe it is necessary to protect the security, integrity, and operations of this website or WPS. We may disclose aggregate statistics regarding our users and user behavior as a measure of interest in and use of our Websites, such as overall patterns or demographic reports that do not describe or identify any individual user.
We also may use test results for individual test takers for research purposes. In those instances, ALL individual personal information that could be used to identify you is removed so that the results are anonymous, and then those results are aggregated into a data pool that is used for research. For example, such a database may show how many test takers were male or female and the ages of test takers, but no individual information about you is connected to that database. Among the research uses of such aggregated anonymous data are development of test norms and new test items.
CHANGES TO OUR POLICY
WPS - Western Psychological Services
625 Alaska Avenue
Torrance, CA 90503-5124