Privacy Policy

Last Updated: January 1, 2025  |  Effective Date: January 1, 2025

This Privacy Policy describes how Provora ("Provora," "we," "us," or "our") collects, uses, discloses, and protects personal information about you when you use the Provora learning management platform and related services (collectively, the "Platform"). This policy applies to all users of the Platform, including Customers (organizations that purchase access to the Platform) and Learners (individuals who use the Platform to complete training).

By using the Platform, you consent to the data practices described in this Privacy Policy. If you do not agree with this policy, please do not use the Platform.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you provide when you register for an account, complete a contact form, or otherwise interact with us. This includes:

• Name, email address, phone number, and job title;
• Company or organization name and size;
• Billing information (processed securely through our payment processor — we do not store full credit card numbers);
• Course content, quiz questions, and other materials you upload to the Platform;
• Communications you send to us, including support requests and demo enquiries.

1.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical information, including:

• IP address, browser type, operating system, and device identifiers;
• Pages visited, features used, and time spent on the Platform;
• Log data, including access times and error logs;
• Cookie and similar tracking technology data (see our Cookie Policy for details).

1.3 Learner Activity Data

For Learners using the Platform, we collect:

• Course enrollment and completion status;
• Video watch-time and progress data (verified server-side);
• Quiz responses and scores;
• Points earned and leaderboard rankings;
• Certificate issuance records.

1.4 Biometric and Proctoring Data

If the Customer has enabled the Identity & Proctoring features, we may collect:

• Photographs of the Learner captured during identity verification checks and assessment monitoring sessions;
• Identity verification evidence generated during the verification process;
• Timestamps and session metadata associated with proctoring events.

This biometric data is collected only when the Identity & Proctoring features are enabled by the Customer, and only after the Learner has been informed of and consented to the collection. The Customer is responsible for obtaining valid consent from Learners in accordance with applicable law. Proctoring data is stored securely and linked to the Learner's certificate record as part of the append-only audit trail. It is retained for the period specified in the Customer's data retention settings and is not used for any purpose other than identity verification and audit trail maintenance.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Platform: To operate, maintain, and improve the Platform and its features;
• Account Management: To create and manage your account, process payments, and provide customer support;
• Communications: To send you service-related notices, updates, and, where you have opted in, marketing communications;
• Security and Integrity: To detect and prevent fraud, unauthorized access, and other harmful activities;
• Analytics and Improvement: To analyze usage patterns and improve the Platform's performance and user experience;
• Legal Compliance: To comply with applicable laws, regulations, and legal processes;
• Identity & Proctoring: To verify Learner identity and monitor assessment integrity before and during quiz sessions, as described in Section 1.4.

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: We share information with trusted third-party service providers who assist us in operating the Platform (such as cloud hosting providers, payment processors, and analytics services). These providers are contractually obligated to protect your information and use it only as directed by us.
• Customer Administrators: Learner activity data, including quiz scores, completion records, and proctoring evidence, is accessible to the Customer's authorized administrators within their tenant.
• Legal Requirements: We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Provora, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

4. Data Retention

We retain personal information for as long as necessary to provide the Platform services and fulfill the purposes described in this policy, unless a longer retention period is required by law. Customers can configure data retention settings within their tenant, including the retention period for Learner activity data and proctoring images. Upon account termination, we will delete or anonymize your data within ninety (90) days, unless we are required to retain it for legal or regulatory purposes.

5. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, regular security audits, and isolated per-tenant data storage. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: The right to request a copy of the personal information we hold about you;
• Correction: The right to request correction of inaccurate or incomplete personal information;
• Deletion: The right to request deletion of your personal information, subject to certain exceptions;
• Portability: The right to receive your personal information in a structured, machine-readable format;
• Objection: The right to object to certain processing of your personal information;
• Withdrawal of Consent: Where processing is based on consent, the right to withdraw consent at any time.

To exercise any of these rights, please contact us at privacy@provora.com. We will respond to your request within thirty (30) days.

7. International Data Transfers

Provora operates globally and may transfer your personal information to countries outside your home country, including countries that may not provide the same level of data protection as your home country. When we transfer personal information internationally, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, to ensure that your information is protected in accordance with applicable law.

8. Children's Privacy

The Platform is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child under 16 has provided us with personal information, please contact us at privacy@provora.com and we will take steps to delete such information.

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt out of the sale of your personal information. We do not sell personal information. To exercise your CCPA rights, please contact us at privacy@provora.com.

10. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) and applicable national data protection laws. Our legal bases for processing your personal information include: (a) performance of a contract with you; (b) our legitimate interests in operating and improving the Platform; (c) compliance with legal obligations; and (d) your consent, where applicable. To exercise your GDPR rights or to contact our Data Protection Officer, please email privacy@provora.com.

11. Cookies

We use cookies and similar tracking technologies to operate and improve the Platform. For detailed information about the cookies we use and your choices regarding cookies, please see our Cookie Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting the updated policy on our website and, where practicable, by sending notice to the email address associated with your account. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Provora — Privacy Team
Email: privacy@provora.com
Website: Contact Form