Privacy, plainly stated.

Who this policy covers

This Privacy Policy applies to test takers, instructors, invigilators, and administrators using the AI-Proctor website, iOS and other mobile applications, desktop applications, browser-based examination tools, and integrations with learning-management systems.

AI-Proctor is operated by TechiBees Inc.

Educational institutions, instructors, or authorized examination creators configure examinations and determine which proctoring features are required. They may determine whether the examination requires identity verification, face matching, photo-ID submission, camera or microphone access, screen recording, room scanning, mobile-camera monitoring, browser or application controls, or other examination-integrity features.

The institution or authorized examination creator also determines which instructors, invigilators, administrators, or other authorized personnel may view, download, review, or delete examination information, subject to the permissions available in the AI-Proctor platform and the institution's policies.

Test takers should also review any privacy information provided by their institution.

Who controls examination information

The educational institution, instructor, or authorized examination creator determines the examination settings, the categories of information collected from each test taker, the purposes for which the information is used, and the personnel who may access the examination information.

Depending on the applicable agreement and law, the educational institution may act as the data controller or equivalent responsible party for examination information. TechiBees Inc. provides and operates the AI-Proctor platform on behalf of the educational institution and processes examination information according to the institution's instructions, the applicable service agreement, and applicable law.

The institution is responsible for selecting appropriate examination settings, informing test takers about the examination requirements, managing user permissions, and ensuring that the examination process provides any legally required alternatives or accommodations.

Where the European Union's General Data Protection Regulation (GDPR) applies, a controller determines why and how personal information is processed; a processor processes it on the controller's behalf. These roles depend on the actual processing activity, not only on the titles used in an agreement. The responsibilities described above do not remove TechiBees' own obligations under applicable law.

Applicable legal basis

The legal basis for processing examination information may depend on the educational institution, the test taker's location, the examination arrangement, and applicable law. This Privacy Policy does not assume that consent is the legal basis for every processing activity. Where consent is the applicable legal basis, a test taker may withdraw that consent, subject to the consequences and process described below.

For processing covered by the GDPR, the responsible controller must identify an applicable legal basis under Article 6 and explain it to test takers. The institution's examination privacy information should identify the responsible controller, its contact details, the enabled processing, and the legal basis for that examination. Accepting this policy or the institution's service agreement does not, by itself, establish a lawful basis for every use of a test taker's information.

Information needed to deliver an examination

AI-Proctor may collect the following information when providing the service. The examination settings and functions used determine which examination-specific categories apply:

• Test-taker name, email address, student number, institution identifier, and examination identifier.
• IP address, device and operating-system information, application version, timestamps, and connection information.
• Photo-ID and face-verification information described in the Face and Identity Data section below.
• Camera, microphone, screen, and room-scan information when those features are enabled.
• Running-program, connected-device, browser-navigation, and examination-integrity events.
• Examination answers, including text responses, uploaded response files, and recorded audio or video answers; scores, grades, and communications with an instructor.
• For coding questions, source code, selected programming language, test input, program output, and test-case results.
• When automated grading is enabled, the question, model answer or grading context, rubric, test-taker answer, and generated score or feedback.
• Invitation and notification information, including recipient details, message content, delivery status, and invitation-link click events.
• Learning-management-system integration information, including examination and event codes, quiz links, student identifiers, session information, and examination start or end status.
• Technical and security logs, which may contain IP addresses, identifiers, request timestamps or data, file paths, errors, and service-provider responses.

AI-Proctor collects only the categories required by the institution's examination settings and the functions used by the test taker.

What face data is processed

Identity-verification settings

The educational institution or its authorized instructor chooses the identity-verification setting for each examination. The available settings are:

• Face Match: the test taker takes a live face image when entering the examination, and AI-Proctor checks during the session whether the same person remains present.
• Face + ID Scan: the test taker takes a live face image and submits a photo ID. AI-Proctor compares the two images and continues checking whether the same person remains present during the examination.
• None: the identity check is skipped, so no face image or photo ID is collected for identity verification.

For Face + ID Scan, the instructor also chooses what happens when an automatic match is not confirmed: the test taker may be allowed to enter and flagged for review, or may be held until an authorized instructor or invigilator approves or denies entry.

Identity verification, camera monitoring, and session recording are separate settings. Selecting no identity check does not by itself disable camera monitoring or recording if the institution has enabled those features for the examination. AI-Proctor only processes the face data associated with the settings that apply to the examination and test taker.

Depending on those settings, AI-Proctor may process:

• A live selfie and the portrait appearing on the test taker's photo ID.
• A combined image showing the submitted photo ID and live selfie.
• Facial bounds, landmarks, pose information, and a mathematical facial embedding generated from an image.
• A face-comparison outcome, including a match or non-match result.
• Face-presence information, including no-face and multiple-face detections.
• Camera images, face-incident images and videos, and examination camera recordings containing the test taker's face.
• Manual-admission images provided when automatic verification does not produce an accepted match.
• The student, examination, timestamp, and incident classification associated with the material.

The submitted photo-ID image may contain more than the portrait. Depending on the document supplied, it may also show a name, date of birth, identity-document number, and other printed personal information. Those visible details are included in the combined ID/selfie image uploaded to AI-Proctor; this is distinct from the temporary facial embedding and landmarks described below.

On-device processing and server uploads

Face detection, facial landmarks, pose information, the facial embedding, and the numerical face comparison are processed temporarily on the test taker's device. The facial embedding and landmarks are never uploaded to or retained by AI-Proctor's server or its service providers. They are discarded immediately after the local processing for which they were generated is complete.

In Face Match mode, the live face-verification image is uploaded to AI-Proctor. In Face + ID Scan mode, the combined ID/selfie image and match or non-match result are uploaded. Match or non-match results are uploaded where the selected verification process produces them. After successful upload, AI-Proctor's temporary device copies of the submitted face and ID verification images are deleted. When examination monitoring is enabled, camera images, face-incident evidence, and camera recordings may also be uploaded during the examination.

Biometric information under the GDPR

A photograph is not automatically special-category biometric data under the GDPR. However, technical processing of facial characteristics to uniquely identify or authenticate a person may fall within Article 9. Where that provision applies, the responsible controller must establish an applicable Article 9 condition as well as an Article 6 legal basis before enabling the processing. Temporary, on-device processing does not by itself remove those requirements. Where explicit consent is relied on, it must meet the applicable requirements for freely given, specific, informed consent.

Purposes

AI-Proctor uses face data only to:

• Compare a live selfie with the portrait on a submitted photo ID.
• Determine whether identity verification produced a match or non-match result.
• Hold or flag a test taker for review by an authorized instructor or invigilator.
• Help confirm that the same person remains present during the examination.
• Detect no face, multiple people, or a possible different person.
• Notify authorized proctors about face-related examination incidents.
• Create examination-integrity evidence and reports.
• Operate, secure, troubleshoot, and support these examination functions.

Other information processed during an examination

The educational institution or its authorized instructor configures the monitoring requirements for each examination. Depending on the examination, the instructor may enable or disable audio-cheating detection, screen and camera recording, mobile companion-camera monitoring, room scans, and related automatic proctoring actions. Open Book mode disables application and browser-lockdown controls, but identity verification, audio detection, recording, and mobile-camera controls remain separate choices.

Based on the settings that apply to the examination and test taker, AI-Proctor may process:

• Screen images or recordings.
• Webcam, connected-camera, or mobile companion-camera images and recordings.
• Audio captured by the device microphone.
• Room-scan recordings.
• Programs running during the examination.
• Websites opened during the examination.
• Connected-device and examination-session events.

These categories are used to administer the examination, allow live or later review by authorized proctors, and document potential examination-integrity incidents. AI-Proctor processes monitoring information only for administering, securing, supporting, and reviewing the applicable examination, subject to the institution's configuration and applicable law.

If a test taker does not have an available camera, microphone, or required mobile companion device, the test taker may submit an exception request for that examination. An authorized instructor may approve or deny the request for that specific test taker. If approved, the test taker may proceed without supplying data through the unavailable device; all other examination settings still apply. AI-Proctor records the request and the instructor's decision as part of the examination record.

Purposes of processing

AI-Proctor uses examination information according to the settings selected by the educational institution or authorized examination creator. Depending on those settings, the information is used to:

• Deliver and administer the applicable examination.
• Verify a test taker's identity and help confirm that the same person remains present during the examination.
• Operate the enabled camera, microphone, screen, room-scan, mobile-camera, browser, application, and connected-device monitoring features.
• Identify and document potential examination-integrity incidents.
• Allow authorized instructors, invigilators, and administrators to conduct live or later review.
• Create examination-integrity evidence and reports and notify authorized proctors about examination incidents.
• Record and apply instructor decisions concerning identity review and device-exception requests.
• Execute and assess coding answers and, where enabled, provide automated grading or code-quality assistance for authorized instructor review.
• Send examination invitations and notifications and monitor their delivery and invitation-link engagement.
• Connect an examination with the TechiBees-hosted Moodle system where that integration is used.
• Operate, secure, troubleshoot, and support the examination functions described in this policy.

How automated detections support review

AI-Proctor uses automated systems to perform enabled functions such as face comparison and to identify potential examination-integrity events. These systems may produce match or non-match results, detect face-presence events such as no face or multiple faces, and flag other activity associated with the monitoring features selected for the examination.

Automated detections, comparison results, and incident flags are intended to assist authorized instructors, invigilators, and administrators in reviewing examination activity. These outputs are not themselves final academic-misconduct decisions. The educational institution and its authorized examination personnel use the available examination information under the institution's policies when making academic-integrity decisions.

For Face + ID Scan, an unsuccessful automatic match is handled according to the examination configuration selected by the instructor. The test taker may be allowed to enter and be flagged for review, or may be held until an authorized instructor or invigilator approves or denies entry.

Where automated essay grading or code-quality grading is enabled, AI systems may analyze the applicable answer and grading context and produce a proposed score, feedback, or code-quality assessment. These outputs support the examination and grading workflow; the educational institution determines how they are used and which authorized personnel may review them.

Where the GDPR applies, Article 22 restricts decisions based solely on automated processing that produce legal or similarly significant effects, subject to its exceptions and safeguards. Automated detection is not necessarily such a decision. The institution must assess how automated outputs are used in its examination process and provide any legally required safeguards, including human intervention or an opportunity to contest a decision where applicable. Test takers should contact their institution about the decision-making arrangements for their examination.

Who may receive examination information

AI-Proctor may share examination information for the purposes described in this policy. Recipients receive different categories of information according to their role or the function used; inclusion in this list does not mean that every recipient receives face images, photo IDs, or recordings.

AI-Proctor, the institution, and legally required recipients

• TechiBees Inc., through personnel authorized to operate, secure, or support AI-Proctor.
• The educational institution, including authorized instructors, assigned invigilators, administrators, and other authorized personnel responsible for the examination.
• Public authorities when disclosure is required by applicable law or a valid legal request.

Hosting, real-time communication, and learning-management integration

• DigitalOcean: hosts the production application, PostgreSQL database, and active uploaded examination media in Singapore.
• AWS IoT Core: processes associated student or examination identifiers, incident information, session or device state, and media URLs needed to provide real-time proctoring notifications. The active configuration is in Singapore.
• TechiBees-hosted Moodle: the active Moodle integration is hosted by TechiBees in Singapore and exchanges event codes, student information, and examination or session information with AI-Proctor. Moodle retains its own quiz answers.

Email, code execution, and automated grading

• SendGrid: processes recipient details, email content, message identifiers, delivery information, and intentionally enabled click-tracking events when AI-Proctor sends invitations or notifications.
• Judge0 through RapidAPI: receives source code, the selected language identifier, and applicable input when a coding answer is executed.
• OpenAI: receives the applicable problem statement and student code when code-quality grading is used, and applicable answer and grading context when its essay-grading workflow is used.
• Anthropic: receives applicable answer and grading context when its essay-grading workflow is used.

SendGrid, Judge0/RapidAPI, OpenAI, and Anthropic receive information only when the corresponding email, coding, or grading function is used.

TechiBees does not itself train models using student data. The OpenAI and Anthropic account arrangements used by TechiBees permit those providers to use submitted answers, code, and grading content for model training. This provider-side use is separate from AI-Proctor's on-device face processing; facial embeddings and landmarks are not transmitted to those providers.

AI-Proctor's face-detection and comparison technology operates locally on the device. AI-Proctor does not transmit the generated facial embedding or facial landmarks to its service providers or its server.

Processor and subprocessor responsibilities

For processing covered by the GDPR, Article 28 requires an appropriate controller-processor agreement. Where a provider acts as a subprocessor, the applicable authorization and contractual protections must also be established. These requirements are distinct from the provider list above; listing a company in this policy does not by itself establish that a particular GDPR agreement or transfer safeguard is in place.

Equal protection requirement

AI-Proctor requires every third party receiving personal information, including face data, to provide the same or equivalent protection described in this Privacy Policy. Applicable provider agreements or service terms must restrict use to the disclosed and authorized purposes, limit access to authorized personnel, and address deletion or return under the applicable retention requirements. Providers acting as processors must also follow the applicable processing instructions, and relevant subprocessors must be subject to equivalent protections.

Institutions may download examination reports and evidence. Institutions are required to protect and delete copies under their control according to the same or equivalent protections and the applicable retention and deletion requirements.

If AI-Proctor's service providers or subprocessors change, this list may be revised to reflect the change.

Where information may be processed

AI-Proctor's production application, database, active uploaded examination media, active AWS IoT Core configuration, and TechiBees-hosted Moodle system are currently located in Singapore. Authorized TechiBees personnel, including personnel in Egypt, may access examination information when necessary to operate, secure, troubleshoot, or support the service.

Other service providers listed above may process information in countries determined by their applicable standard service terms and account configuration. Where applicable law requires a particular cross-border-transfer mechanism or safeguard, TechiBees and the relevant institution must identify and put that arrangement in place. AI-Proctor does not represent that all examination information is stored or processed only within the European Union.

For international transfers covered by the GDPR, Singapore and Egypt do not currently have an EU adequacy decision. The applicable transfer arrangement must therefore be assessed under Chapter V. This may require appropriate safeguards, such as applicable Standard Contractual Clauses, an assessment of the destination's laws and practices, and additional measures where necessary. These arrangements must be established before the relevant transfer; Singapore hosting alone neither establishes nor rules out GDPR compliance.

How long face and proctoring data is kept

For media covered by automatic retention, AI-Proctor calculates the six-month deadline using the examination's configured timezone and records it in Coordinated Universal Time (UTC). Creating a report copy does not restart the retention period; the copy follows the deadline of the original incident evidence. When the deadline is reached, the media file and its tracked report copies are deleted. The associated incident record, flagged time, incident type, result, classification, and other non-file details remain available as part of the examination record, and the interface indicates that the evidence file expired under the six-month media-retention policy.

The six-month period applies to both new and older proctoring media, including camera and screen recordings created by combining captured images into video. The longer-retention exceptions described below still apply.

If an instructor or authorized examination creator never deletes an examination, its retained incident details, match results, face-related classifications, and other examination records do not currently receive a separate automatic expiry date. They remain with the examination unless an approved deletion request, institutional instruction, contractual requirement, or applicable law requires deletion. Educational institutions and authorized examination creators are responsible for deleting examinations and associated records when they are no longer required under the institution's policies and applicable law.

The six-month media period is AI-Proctor's retention rule, not a period prescribed by the GDPR. Where the GDPR applies, personal information must not be kept longer than necessary for its stated purposes. Retaining examination details without an automatic expiry does not authorize indefinite retention: the responsible controller must justify the continuing need, review retention, and arrange deletion when that need ends, subject to applicable legal requirements.

An educational institution may request a specified longer retention period for media that would otherwise be deleted after six months. AI-Proctor may also retain applicable media longer when necessary for an active academic-integrity dispute or when required by law or a valid legal request. Any extended retention is associated with the applicable institutional, contractual, dispute-related, or legal requirement; it is not an unlimited extension. Access remains restricted during an extension, and the applicable media is deleted when the extension, dispute, or legal requirement ends, unless another stated retention requirement applies.

Information processed by SendGrid, Judge0/RapidAPI, OpenAI, or Anthropic is also subject to the applicable provider's standard service terms and the account settings used by TechiBees. TechiBees does not currently use an enterprise or zero-data-retention arrangement or a TechiBees-selected processing or data-residency region for those providers.

Privacy choices and requests

Depending on applicable law, a person's location, and the circumstances of the examination, a test taker may have rights concerning their personal information. Not every right applies in every jurisdiction or circumstance, and a request may be subject to applicable legal conditions or exceptions.

Where applicable, these rights may include:

• Access to personal information.
• Correction of inaccurate personal information.
• Deletion of personal information.
• Restriction of processing.
• Objection to processing.
• Data portability where applicable.
• Withdrawal of consent where consent is the applicable legal basis.
• The ability to complain to an appropriate privacy or data-protection authority.

Because an educational institution may act as the data controller or equivalent responsible party, a test taker may need to exercise these rights through their institution. The institution may need to verify the request and determine how applicable law and its academic-record responsibilities apply.

Requests covered by the GDPR

Where the GDPR applies, the rights above are subject to their respective legal conditions; deletion is not an absolute right, and portability does not apply to every processing activity. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Test takers may also complain to a competent supervisory authority without first completing AI-Proctor's request process.

The responsible controller must respond without undue delay and normally within one calendar month of receiving a GDPR rights request. The GDPR permits an extension of up to two further months where necessary because of the complexity or number of requests, with notice and reasons within the first month. The seven-day acknowledgement and normal 30-day deletion commitments below do not replace applicable statutory deadlines; institutional forwarding or approval must not be used to restart them or override applicable rights.

Face-data deletion requests

A test taker may request deletion of face data through their educational institution or by emailing support@ai-proctor.com directly. Where consent is the applicable legal basis, either channel may also be used to request withdrawal. For requests made through the institution, the institution verifies the test taker's identity and forwards the verified request to TechiBees. For direct requests, TechiBees coordinates any necessary identity verification, institutional instructions, and academic-record requirements with the institution, subject to applicable law.

The request should include:

• Full name and student number or institution identifier.
• Email address, if available.
• Institution name.
• Examination name or code and approximate examination date.
• Whether the request concerns withdrawal of consent, deletion of face data, or both.

TechiBees acknowledges a verified request within seven days and normally completes deletion within 30 days after receiving it. Deletion covers the applicable identity-verification material, face images and recordings, match results, face-related classifications, and copies controlled by AI-Proctor.

Academic answers, including uploaded files and recorded audio or video answers, scores, grades, and other academic records are separate from identity-verification and proctoring evidence. They are not automatically deleted by a request limited to that face data. A recorded answer may itself contain a person's face or voice. If a request also concerns an academic answer or recording, the test taker should identify that material explicitly in the request so it can be assessed under applicable law and the institution's academic-record responsibilities. This distinction does not exclude those recordings from applicable privacy rights.

Declining processing and withdrawing consent

• Before capture: a test taker may decline face-data processing. No face data is collected. If face verification or monitoring is required, the test taker should contact the institution about an alternative arrangement.
• During an examination: where consent is the applicable legal basis, the test taker may request withdrawal by emailing support@ai-proctor.com. The examination session is ended when withdrawal is requested, stopping further consent-based monitoring and face-data collection. Previously collected face data is handled through the deletion-request process, subject to applicable legal requirements.
• After an examination: where consent is the applicable legal basis, withdrawal is treated as a request to delete previously collected face data. The request may be sent through the institution or directly to support@ai-proctor.com, with any necessary identity verification coordinated with the institution.

Deletion may be deferred only for an active academic-integrity dispute or a legal requirement. The test taker will be informed of a delay unless notification is legally prohibited. The retained face data will be deleted when the applicable exception ends.

Where active data and recovery copies are kept

AI-Proctor stores active examination data with DigitalOcean in Singapore. Uploaded face images, uploaded answer files, and examination recordings are not included in AI-Proctor's database backups.

TechiBees maintains one restricted offline PostgreSQL database backup in Egypt for disaster recovery. The backup is not connected to the Internet. Access is limited to one authorized person for restoration. Only the latest backup is kept; the previous backup is deleted when a replacement is created. Uploaded examination media is not included in this database backup. No additional DigitalOcean automatic backups or snapshots are enabled.

When examination or class deletion, or an approved deletion request, removes database records, the retained backup is replaced with a version that no longer contains those deleted records, and the previous backup is removed. A replacement backup is also created after major system changes.

How access is limited

AI-Proctor uses access controls intended to limit examination information to authorized institution personnel and TechiBees personnel whose work requires access. Stored report evidence, proctoring evidence, monitoring images, and recorded student answers are delivered through authentication and examination-scoped permission checks or securely time-limited access links, depending on the delivery method. Media links communicated through AWS IoT Core are subject to these access controls or time limits. The retained database backup is kept offline with access limited to one authorized person, as described above.

Where the GDPR applies, TechiBees and the responsible institution must implement technical and organizational measures appropriate to the risks under Article 32, taking account of the nature and sensitivity of the information and the processing involved.

AI-Proctor reviews and updates its safeguards as the service changes. No method of storage, transmission, or access control can be guaranteed to be completely secure.

If a test taker believes their information has been accessed improperly, they should contact their institution and support@ai-proctor.com.

Examinations involving minors

If an educational institution provides AI-Proctor for an examination involving a minor, the institution is responsible for determining and satisfying any applicable authorization, notice, parental or guardian consent, accommodation, or other legal requirements associated with that examination. The requirements may vary by jurisdiction and examination arrangement.

Cookies

AI-Proctor may use cookies and similar technologies that are necessary to operate the website, maintain security, authenticate users, remember preferences, and support the examination session.

If AI-Proctor uses non-essential cookies, consent will be requested where required by applicable law. Where a cookie-consent mechanism is provided or required, test takers may respond through the choices made available in that mechanism.

Accepting or using website cookies does not by itself provide permission to collect examination recordings, face data, screen information, microphone data, photo-ID information, or other examination information. Those categories are processed only when enabled for the applicable examination and accepted or otherwise authorized through the examination process and applicable arrangements.

Updates to this policy

AI-Proctor may update this policy when its products, service providers, or legal obligations change. The current version will remain available at https://ai-proctor.com/privacy/.

Where required by applicable law, notice of a material revision may be provided through AI-Proctor or through the relevant educational institution.