Privacy Policy
  1. Introduction
    1. Thanks for choosing IQ Test123 (“the Provider”, “we”, “us”, “our”). We are pleased to present to you first ever IQ certification system, however in order to provide you the services that would live up to your expectations, we will ask you to provide some personal information to us if you choose to buy anything from us or register on our website.
    2. By registering on our site https://www.iqtest123.com and creating you own personal profile and/or purchasing any services from us, you shall be required to get acquainted and express your agreement to the following rules regulating how we use and process your personal data. Please read this Privacy Policy closely prior expressing your agreement. If after close examination of this Privacy Policy you find provisions that does not suite you, please do not use our services or buy from us.
    3. The purpose of this Privacy Policy is to regulate the principles and procedures for collecting, processing and storing personal data of the users, as well as establishing the rights of users, and regulating other related issues.
    4. The terms of this Privacy Policy, as well as all data processing practises used by us are established in accordance to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding General Data Protection Rules; The Federal Trade Commission Act (15 U.S.C. §§41-58) and Children's Online Privacy Protection Act (COPPA) (15 U.S.C. §§6501-6506). However, some of the clauses listed in this Privacy Policy as well as rights and obligations set by applicable laws may be applied differently to residents of European Union Member countries, United States of America or other countries.
    5. We’d like to inform you that information regarding your main rights and how to exercise them can be found in the following sections of this Privacy Policy:
      • Right to be forgotten (Clause 7.6.)
      • Right to be receive your personal data (Clause 7.2. and 7.3.)
      • Right to object to personal data processing (Clause 7.4.)
      • Cookie policy (Clause 9)
      • Right to be informed about data breaches (Clause 12)
    6. If you have any questions about provisions of this Privacy Policy or you wish to inquire about how we handle your personal data, please write to our support team ( [email protected] ) and we will do our best to answer to you as soon as possible.
  2. Terms used in this privacy policy
    1. Unless the context requires otherwise, terms specified below shall have the indicated meanings:
      Data Controller or IQ Test123 – means a limited company incorporated under the laws of the Republic of Lithuania, with its registered address at Laisvės al. 59, LT-44305 Kaunas, Lithuania, contact e-mail: [email protected] ; website: https://www.iqtest123.com .
      Privacy Policy – means these privacy policy rules regulating personal data use and security procedures which Data Controller adheres when carrying out any activities related to use, control, transfer, etc. of any data which is deemed to be personal.
      Personal Data – means any information relating to any natural person which would allow the person to be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
      Processing – means any operation or set of operations which is performed on Personal data such as: collecting, recording, organizing, storing, classifying, grouping, combining, altering (supplementing or correcting), transferring, publishing, using, logical and (or) arithmetical operations, searching, disseminating, destructing or other operation or set of operations.
      Data Processor – means natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
      Profiling – means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person.
      Consent – means freely given, voluntary indication of the Data Subject accepting this Privacy Policy and providing allowance for the Data Controller to Process, Profile and/or use Data Subject’s Personal Data in other ways as described in this Privacy Policy.
      Direct Marketing – means the activity of offering goods or services to Data Subjects by email, post mail, phone or other means of direct contact.
      Services – means recreational services, consisting of various Intelligence Quotient (“IQ”) tests, vision tests, reaction tests, math tests or other similar tests that are specifically designed to determine the Data Subjects’ IQ or other cognitive abilities provided by the Data Controller. Services are
      Cookies – means small files that gather and store information as described in this Privacy Policy. Cookies are downloaded to Data Subject’s computer only if Data Subject has provided a Consent regarding usage of Cookies.
      Data Subject – means a natural person who use the Website and/or buy Services from the Data Controller.
      Website – means an internet site that goes by address of https://www.iqtest123.com .
      Profile – means an individually made profile of Data Subject’s provided Personal Data accessible via special link in the Website.
      Third Party – means natural or legal person who is authorized to perform any Processing actions by Data Controller in accordance to a service agreement entered between the Third Party and Data Controller. Specifically, such Third Party may be providing legal, accounting, hosting or other services that would require revealing any Personal Data to the service provider.
  3. General Provisions
    1. IQ Test123 only Process Personal Data which is provided by the Data Subject in order to provide Services and execute all payment procedures for Services. IQ Test123 does not collect any Personal Data own its own will without prior Consent of the Data Subject.
    2. IQ Test123 Process Personal Data only for the following purposes:
      1. providing Services to Data Subjects in accordance to IQ Test123 Terms of Service;
      2. making Websites content more relevant to Data Subject and ensuring smooth operation of the Website (by using Cookies);
      3. for fulfilment of Data Processor’s duties set by laws;
      4. for contacting Data Subject for Direct Marketing purposes;
    3. IQ Test123 Process Personal Data only if at least one of the preceding conditions exist:
      1. If the Data Subject is buying any type of Services or goods from IQ Test123 ; or
      2. Data Subject has expressed Consent regarding Processing of his/hers Personal Data; or
      3. Personal Data Processing is mandatory by laws applicable to Data Processor.
    4. IQ Test123 Process Personal Data in accordance to the following principles of data processing:
      1. Personal Data shall be collected only for legitimate purposes and as defined in this Privacy Policy;
      2. Personal Data shall be Processed accurately and conscientiously;
      3. Personal Data may be constantly updated;
      4. Personal Data shall not be stored longer than it is necessary;
      5. Personal Data shall only be processed by the employees and Third Parties that were thoroughly introduced with the provisions of this Privacy Policy and duly authorized by Data Processor;
      6. Data Subjects Personal Data shall be considered to be confidential and protected by the Data Processor from unlawful use.
  4. Personal data processing
    1. IQ Test123 Process Personal Data by manual and automated means.
    2. For the purposes established in this Privacy Policy IQ Test123 shall collect, store and Process only the following Personal Data:
      1. name and last name;
      2. E-mail address;
      3. Address;
      4. Telephone number;
      5. Profile picture, if the Data Subject wish to upload;
      6. History of tests conveyed and the results of the tests;
    3. IQ Test123 receive and collect Personal Data in the following ways:
      1. Directly from Data Subjects, when they provide information during their registration on the website or making their first purchase;
      2. Directly from Data Subjects, when Personal Data is captured by Cookies used on the Website;
    4. IQ Test123 Process only such Personal Data which are necessary to Process in order to provide Services and carry out obligations imposed by this Privacy Policy and applicable laws. The Personal Data list specified in Clause 4.2. of this Privacy Policy is an exhaustive list of all Personal Data Processed by IQ Test123, however in individual cases IQ Test123 may choose to Process less Personal Data of a particular Data Subject.
    5. IQ Test123 Process Personal Data only when it is necessary for carrying out its obligations to Data Subject in accordance to the Terms of Service or with the Consent of Data Subject.
    6. IQ Test123 do not Process any Personal Data of Data Subjects who would be under the age of 16. Data Subjects under age of 16 may use the Services and provide their Personal Data to Data Processor only with a written and e-signed Consent of their parents or guardians.
  5. Personal data and third parties
    1. IQ Test123 do not exchange or share any Personal Data with any Third Parties which does not have an establishment in any Member State of European Union, except such Third Parties which are not established in the European Union but carries its activities in the European Union and are fully compliant with the requirements of EU General Data Protection Rules (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).
    2. IQ Test123 transfer Personal Data for Processing only to those Data Processors or Third Parties who are entitled to provide services to IQ Test123 by an agreement signed between the service provider and IQ Test123. In all cases when transferring Personal Data to Third Parties IQ Test123 shall ensure that Data Processor or other subject receiving Personal Data is capable of ensuring appropriate Personal Data protection in accordance to the requirements of applicable laws.
    3. IQ Test123 transfer Personal Data only in such extent which is the least possible scope of Personal Data that is necessary to provide in order to carry out obligations set by service agreements between Data Processors and IQ Test123.
    4. IQ Test123 do not transfer any Personal Data to any Data Processors or Third Parties with whom IQ Test123 do not have a signed agreement which would cover provisions regarding safe Processing of Personal Data compliant with this Privacy Policy.
    5. IQ Test123 may transfer Personal Data to the following groups of Data Processors or Third Parties:
      1. Payment processing subjects (banks; e-payment processors; etc.);
      2. Service providers (server hosting; software development support; data analysts; marketing specialists);
      3. Administrative service providers (lawyers; accountants);
      4. Authorities which have the right to receive Personal Data by law and which have provided a document issued and valid in accordance with the procedures established by laws of the Republic of Lithuania, which undoubtedly confirms the right of the recipient of the data to collect and Process Personal Data.
  6. Terms for storing personal data
    1. IQ Test123 store and Process Personal Data as long as:
      1. Data Subject is using Services provided by IQ Test123 ;
      2. IQ Test123 may exercise their rights or obligations set by laws for which Personal Data is necessary;
      3. Data Subject’s Consent is valid and not canceled by the Data Subject.
    2. In other cases the Personal Data may be stored and Processed for no longer than 24 months after the last purchase of Services; or Data Subject’s activity on the Website; cancelling of Consent. If the Personal Data of the specific Data Subject become irrelevant to IQ Test123 prior the 24 months term specified in this Clause, IQ Test123 may erase the Personal Data before the end of 24 months term.
    3. If Data Subject request IQ Test123 to permanently delete all of it’s Personal Data provided to IQ Test123 (right to be forgotten), such request will be fulfilled within 20 days from receiving and IQ Test123 shall delete all Personal Data of the Data Subject who has provided the request. However, IQ Test123 may hold the execution of such request or refuse to permanently delete all Personal Data, if Personal Data requested to be deleted are necessary for IQ Test123 in order to exercise its’ rights or obligations imposed by laws.
    4. Impersonalized and aggregated Personal Data, i.e. such data that does not allow to identify a specific Data Subject, as well as other data that cannot be linked to any specific person, may for statistical purposes be stored in IQ Test123 database for indefinite term, depending on the needs of IQ Test123 .
  7. Data subjects rights
    1. Data Subjects has the following rights:
      1. To receive full information about Personal Data Processed by IQ Test123 ;
      2. To receive in regular computer readable form all copies of Personal Data which he has provided to IQ Test123 ;
      3. Demand for amendment, deletion or limitation of the scope of Personal Data Processed by IQ Test123 ;
      4. Demand to stop all Processing actions which involve Personal Data of the Data Subject;
      5. Cancel his/hers Consent for Personal Data Processing;
      6. Demand for permanent deletion of all Personal Data Processed by IQ Test123 (right to be forgotten).
    2. Data Subject shall have the right at any time to address IQ Test123 with a request regarding providing the information about Data Subject’s Personal Data being processed. Upon the request of the Data Subject, IQ Test123 , by post mail or e-mail, within 20 calendar days provide the Data Subject with Personal Data he requested and which is in IQ Test123 possession.
    3. Data Subject when exercising his right to receive all Personal Data provided by him to IQ Test123 , shall be provided with the Personal Data in a systematized, regular and widely used computer-readable format (pdf). This data shall be provided to the Data subject free of charge once in 6 months. If Data Subject requests for information more frequently, such request may be subject to additional charges.
    4. Data Subject shall have the right to claim the rectification of false, incomplete and/or inaccurate Personal Data of his and/or suspend Processing of such data, provided that the Data Subject determines that his Personal Data is false, incomplete and/or inaccurate and Data Subject cannot rectify such data himself, or if he determines that Personal Data is processed unlawfully and not in a good faith.
    5. Data subject shall have the right to object to Personal Data Processing for the purposes of Direct Marketing. The right to object can be exercised by notifying IQ Test123 by e-mail or in the preferences of Data Subject’s Profile.
    6. Data Subject has the right to object the Personal Data processing and/or to request the erasure of Personal data (the right to be forgotten). Once received the request of the Data subject for the erasure of all of his Personal data IQ Test123 shall within 20 calendar days destroy all Personal Data of the Data subject and delete the Data Subject’s Profile on the Website.
    7. IQ Test123 has the right to refuse to comply with Data Subject’s request for the erasure of the Personal Data or restriction of Processing of Personal Data, if it cannot terminate Personal Data Processing and erase Personal Data due to obligations set in the applicable laws or due to lawful instructions of relevant authorities.
    8. Data Subject can exercise all of his rights established in these Rules by notifying IQ Test123 via regular post mail or email (by post: Laisvės al. 59, LT-44305 Kaunas, Lithuania; or by e-mail: [email protected] ). Data Subject together with his request should provide a copy of personal identity document which would allow IQ Test123 to identify the Data Subject. If Data Subject does not provide his personal identity document, IQ Test123 may refuse to consider the request. In some cases, requests may be denied if the Personal Data can’t be erased or stopped Processing due to legitimate interests of IQ Test123 and/or specific obligations set to IQ Test123 by applicable laws.
    9. IQ Test123 ensure all other rights, guarantees and interests of the Data Subjects which are provided by applicable laws.
    10. Data Subjects rights specified in Clause 7.2 and 7.3 of this Privacy Policy are only applicable to users who are residents of European Union or are using Services while logging from any European Union countries.
  8. Direct Marketing
    1. IQ Test123 may use Data Subjects email address and phone number for Direct Marketing purposes in form of informational emails and newsletters.
    2. Data Subject may restrict Personal Data use for Direct Marketing by expressing his withdraw of Consent for Personal Data use for Direct Marketing at any time. IQ Test123 stop using Personal Data for Direct Marketing purposes immediately after receiving Data Subjects withdrawal of Consent.
  9. Cookies
    1. IQ Test123 use Cookies on the Website. Cookies are used to improve the functioning of the Website and to optimize the activities on the Website, suiting it to the needs and interests of the Users and Data subjects.
    2. Data subject has the right to object the use of Cookies on his computer, phone, tablet device or other device. Data Subject may at any time disable the use of Cookies by deleting all the Cookies from his browser and refusing to give his Consent for use the Cookies if asked once more. If Data Subject disagree with the use of Cookies, part of the Website’s functions may no longer work properly.
    3. IQ Test123 use following Cookies:
      1. Account related Cookies. If Data Subject create an account or Profile on the Website, then IQ Test123 will use Cookies for the management of the signup process and general administration. These Cookies will usually be deleted when Data Subject log out, however in some cases they may remain afterwards to remember your site preferences when logged out.
      2. Login related Cookies. IQ Test123 use cookies when you are logged in so that the Website can remember this fact. This prevents Data Subject from having to log in every single time he or she visit the Website. These Cookies are typically removed or cleared when Data Subject logs out to ensure that you can only access restricted features and areas when logged in.
      3. Orders processing related cookies. IQ Test123 Website offers e-commerce or payment facilities and some Cookies are essential to ensure that your order is remembered between pages so that IQ Test123 can process it properly.
      4. Forms related Cookies. In order to provide Data Subjects with a great experience on the Website IQ Test123 provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set Cookies so that this information can be called whenever you interact with a page is affected by your preferences.
    4. IQ Test123 may use Cookies provided by trusted Third Parties for collecting and transferring Personal Data. IQ Test123 use Third Party Cookies of the following type:
      1. Google Analytics – this Cookie is an analytic solution for helping IQ Test123 to understand how the Website users use the Website and ways that IQ Test123 could improve user experience;
      2. Google AdSense – this Cookie is used to serve advertising that would be more relevant to Data Subjects across the web and limit the number of times that a given ad is shown to Data Subject.
      3. Affiliate tracking Cookies which allow IQ Test123 to see if a customer have come to the website through one of its affiliate partners sites or links;
      4. OPEND Advertising Technology Cookies – these Cookies allow to send targeted advertising communications to the Data Subjects. However no Personal Data which would allow to indentify a specific Data Subject as a person, is transferred via OPENED Cookies.
  10. Personal data protection implementation measures
    1. IQ Test123 implement appropriate organizational and technical measures in order to protect Personal Data from accidental or unlawful destruction, alteration, disclosure and any other unlawful processing. To ensure Personal Data protection IQ Test123 implement or intend to implement the following Personal data protection measures:
      1. Administrative (secure processing of documents and computer data and their archiving, as well as regulating the organization of work for different areas of activity, introducing personnel to the requirements of Personal data security before and after employment or in similar relations and etc.);
      2. Hardware and software security (administration of servers, information systems and databases, maintenance of working areas and IQ Test123 premises, maintaining the security standards for the servers where databases are stored and etc.);
      3. Communications and computer network protection (common use data, programs, firewalling) and etc.
    2. IQ Test123 store all Personal Data in the data storage servers of “Google Cloud Storage” or other secured remote servers. IQ Test123 ensure that the security of the remote server where Personal Data is stored is secured by the following measures:
      1. Access to data cache where Personal Data is stored is accessible with the use of two-factor authentication technology, where the person logging in has to submit his unique password and additionally confirm his identity by using other device attributed only to him (i.e., electronic signature). Access to server data is granted only to IQ Test123 employees or authorized persons;
      2. All Personal Data kept in servers or data storage devices are encrypted;
      3. Personal Data backups are performed periodically, every 24 hours;
      4. Servers keeps record of all login and data Processing operations history;
      5. IQ Test123 use only those remote server service providers who can ensure appropriate compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding General Data Protection Rules and can provide evidence proving that.
    3. All Personal data processed by IQ Test123 which is in non-digital form (i.e. in the form of material documents), is stored in accordance with the following security rules:
      1. Documents containing Personal Data are handed over only to those IQ Test123 employees who require said documents for carrying out their job functions or carrying out specific tasks that involve the use of Personal Data;
      2. IQ Test123 shall not assign any Processing functions to any employees or persons who are not properly acquainted with this Privacy Policy and other mandatory local legal acts regulating internal data security of IQ Test123 and have not signed the non-disclosure agreement on confidential information;
      3. Documents containing Personal Data in no case can be stored in the premises of IQ Test123 that are intended for common use or premises which have unrestricted access;
      4. IQ Test123 employees or authorized persons may not, in any case, leave the documents containing Personal Data in a single room with other persons who are not mandated by IQ Test123 to perform Personal Data Processing actions;
      5. IQ Test123 employees are not permitted to remove the documents from IQ Test123 premises, which contain Personal Data or copies of such data, unless it is necessary for the proper performance of job functions or for carrying out IQ Test123 obligations set by existing contracts.
    4. IQ Test123 employees who carry out Personal Data Processing functions are required to properly safeguard documents and data files and to avoid making copies of any Personal Data. IQ Test123 document copies containing Personal Data may be made only if it is unavoidable due to security requirements and according to objectives of this Privacy Policy and must be destroyed immediately after the copies of the documents become redundant. Copies or storage devices of the documents must be destroyed in such a way that they would be impossible to restore.
    5. IQ Test123 personnel, who process Personal Data, may only perform Personal Data processing actions using the computers or intelligent devices, which are owned by IQ Test123 and are intended for performing work related tasks, and which have licensed and secure software installed in them. All of the computers or intelligent devices, used for Personal Data Processing by IQ Test123 employees, must be protected by passwords which must be changed at least once in every 3 months and must consist of a combination of at least 8 symbols with lower case and upper case letters and numbers.
    6. IQ Test123 perform testing of managed IT systems, including databases, which test reliability, resistance to overload, resistance to cyber-attack, viruses and other threats to system reliability of IQ Test123 servers and information systems at least once a year. During the testing of IQ Test123 controlled systems, Personal Data of actual Data Subjects are not used.
  11. Personal data of children
    1. The processing of the Personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that Consent is given by the holder of parental responsibility over the child.
    2. IQ Test123 Process the Personal Data of children younger than 16 years old only where the Consent is given by the holder of parental responsibility over the child in an appropriate form, as it is provided under the provisions of applicable laws.
    3. If IQ Test123 determines that the Data Subject, who is under 16 years old, has submitted Personal Data without the Consent of the holder of parental responsibility over the child or by indicating the wrong age, IQ Test123, from the moment that such information is discovered, will take reasonable steps to immediately erase the Personal Data of this Data Subject. In such case, IQ Test123 may delete the Data Subjects Profile.
  12. Data protection incidents
    1. Personal data security breach – means an act or omission that results or may result in undesirable consequences as well as are in conflict with the stipulations provided by the legislation regarding Personal Data security. The degree of impact, damage and the consequences of Personal data protection breach in each case shall be determined by the IQ Test123 or by a commission established by its authorized person.
    2. In the event of Personal data security breach, IQ Test123 shall immediately, but no later than within 48 hours of becoming aware of Personal Data security breach, notify the State data protection inspectorate and the Data Subjects whose Personal Data has been breached. IQ Test123 may not inform Data Subjects about Personal Data security breach if such breach of Personal Data security does not pose any real risk to the rights and freedoms of the Data subjects.
    3. In cases where the breach of Personal Data protection is not due to force majeure cases (lightning, flood, fire and etc.) and is a direct consequence of human action, from the moment IQ Test123 becomes aware of the breach of Personal Data protection, it shall immediately notify the relevant law enforcement authorities regarding possible criminal offence committed.
  13. Final provisions
    1. Compliance monitoring of this Privacy Policy are carried out by the CEO of IQ Test123 or by a person authorized to act as Personal Data Protection Officer. This Privacy Policy shall be renewed and, if necessary, updated at least once a year. The updates or amendments of this Privacy Policy come into effect from the moment of their publication, i.e. from the date they were posted on the Website. In the event that Data Subject does not agree to the amendments of this Privacy Policy, he/she has the right to refuse the Services of IQ Test123 and/or exercise the rights granted by this Privacy Policy and applicable laws.