Privacy Policy

Effective Date: 25 July 2026

This Privacy Policy explains how Vertex Dynamics, a company incorporated in the British Virgin Islands under BVI Company No. 2158720, trading as Exam Terminator (“Exam Terminator,” “we,” “us,” or “our”), collects, uses, stores, discloses, and protects personal information.

This Privacy Policy applies when individuals visit the Exam Terminator website, create an account, communicate with us, purchase or access our services, submit educational or examination-related information, or otherwise interact with Exam Terminator.

Vertex Dynamics is the organisation responsible for controlling and processing personal information collected through Exam Terminator. We are committed to protecting personal information in accordance with the Virgin Islands Data Protection Act, 2021, and any other applicable data-protection requirements.

1. Information We Collect

Depending on how an individual interacts with ET, we may collect:

Identity and contact information, including names, email addresses, telephone numbers, residential addresses and other identification details.

Student and assessment information, including educational background, course or examination registrations, attendance records, assessment results, identification documents, academic records and communications concerning educational services.

Payment and billing information, including billing addresses, transaction records, payment status and limited payment-related information required to process or verify a transaction. Complete payment-card details may be processed directly by an authorised payment-service provider rather than stored by ET.

Website and technical information, including IP addresses, browser type, device information, website activity, referral sources, cookies and analytics information.

Communications, including enquiries, application forms, correspondence, feedback and records of communications with ET.

Where accommodations or additional support are requested, ET may receive information relating to health or accessibility requirements. Such information will be treated as sensitive personal data and processed only where necessary and permitted by law.

2. How We Collect Information

We may collect personal information:

  • directly from individuals or their parents, guardians or authorised representatives;

  • through website forms, registrations, applications and enquiries;

  • during the provision of educational, assessment or support services;

  • through payment and booking systems;

  • through cookies and website-analytics technologies; and

  • from authorised institutions or service providers where necessary to provide a requested service.

3. How We Use Personal Information

ET may process personal information to:

  • respond to enquiries and communicate with users;

  • register individuals for courses, assessments or related services;

  • verify identity, eligibility and registration information;

  • administer educational and assessment activities;

  • provide student support and admissions-related services;

  • process payments, refunds and invoices;

  • maintain operational, financial and compliance records;

  • protect the security and integrity of ET’s systems and services;

  • improve our website, services and user experience;

  • comply with legal, regulatory or contractual obligations; and

  • send service-related or promotional communications where consent has been provided or where otherwise permitted by law.

ET will only collect and process information that is reasonably necessary and directly related to a legitimate and lawful purpose.

4. Legal Grounds for Processing

Depending on the circumstances, ET may process personal information:

  • with the individual’s express consent;

  • where necessary to provide a requested service or perform a contract;

  • to take steps requested before entering into a contract;

  • to comply with a legal or regulatory obligation;

  • to protect the vital interests of an individual; or

  • where processing is otherwise authorised under applicable law.

Where processing is based on consent, that consent may be withdrawn at any time. Withdrawal will not affect processing that lawfully occurred before consent was withdrawn.

5. Access to Personal Information

Access to personal information within ET is restricted to authorised staff members who require it to perform their duties.

ET does not sell, rent or trade personal information.

Limited information may be processed by carefully selected technical service providers, such as website-hosting, payment-processing, communication, cloud-storage or analytics providers, where this is necessary to operate our services. Such providers may only process information for the relevant service and must maintain appropriate confidentiality and security protections.

Information may also be disclosed where:

  • the individual has consented;

  • disclosure is necessary to provide a requested service;

  • ET is legally required to disclose it;

  • disclosure is required to protect legal rights or prevent fraud or misuse; or

  • disclosure is required by a court, regulator or competent public authority.

6. International Data Transfers

Because ET may provide services internationally and use technology providers located in different jurisdictions, personal information may be stored or processed outside the British Virgin Islands.

Where personal information is transferred outside the British Virgin Islands, ET will seek to ensure that adequate data-protection safeguards are in place or obtain the individual’s consent where required by law.

7. Data Security

ET takes reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, accidental disclosure, alteration or destruction.

These measures may include:

  • access restrictions and staff confidentiality requirements;

  • password-protected systems;

  • secure storage and transmission controls;

  • limited access based on operational responsibilities;

  • periodic review of stored information; and

  • reasonable security requirements for external processors.

No electronic storage or transmission system is completely secure. ET therefore cannot guarantee absolute security, but we will take practical and proportionate measures appropriate to the nature of the information being processed. BVI law requires controllers to consider the nature and location of the data, the potential harm from misuse and the reliability of personnel and processors with access.

8. Data Retention

ET will retain personal information only for as long as reasonably necessary to:

  • provide the relevant service;

  • maintain required educational, assessment, financial or operational records;

  • resolve disputes;

  • establish or defend legal rights; and

  • comply with applicable legal, regulatory or contractual requirements.

When information is no longer required, ET will take reasonable steps to securely delete, destroy or anonymise it.

9. Cookies and Analytics

ET’s website may use cookies and similar technologies to:

  • enable essential website functions;

  • remember user preferences;

  • understand website traffic and usage;

  • improve website performance; and

  • measure the effectiveness of communications or campaigns.

Users may control or disable cookies through their browser settings. Disabling certain cookies may affect the operation of parts of the website.

Where a cookie-management tool is available, users may use it to manage their preferences concerning non-essential cookies.

10. Children and Students

Some ET services may be used by individuals under the age of 18.

Where appropriate, ET may require a parent, guardian or authorised representative to provide information, give consent, complete registration or communicate on behalf of a minor.

ET will limit the collection of children’s personal information to what is reasonably necessary to provide the relevant educational or assessment service and will apply additional care when storing and accessing such information.

11. Individual Rights

Subject to the Virgin Islands Data Protection Act, 2021, individuals may have the right to:

  • ask whether ET processes their personal information;

  • request access to personal information held about them;

  • request correction of inaccurate, incomplete, misleading or outdated information;

  • withdraw consent where processing is based on consent;

  • request that ET stop using their information for direct marketing;

  • raise a concern or complaint about the processing of their information; and

  • complain to the Information Commissioner or pursue other remedies available under BVI law.

ET may request reasonable proof of identity before responding to a request. Access requests will ordinarily be addressed within the period required by applicable law, subject to any lawful extension or exception. The BVI Act provides access and correction rights and generally requires an access decision within 30 days.

12. Marketing Communications

ET may send information about relevant courses, assessments, services or events where an individual has consented or where communication is otherwise permitted by law.

Recipients may unsubscribe at any time by:

  • selecting the unsubscribe option in the communication; or

  • contacting ET using the details below.

Service-related messages concerning an active registration, payment, booking or enquiry may still be sent where necessary.

13. External Websites

The ET website may contain links to external websites or services. ET is not responsible for the privacy practices, content or security of independently operated external websites. Users should review the privacy policies of those websites before providing personal information.

14. Changes to This Policy

ET may update this Privacy Policy from time to time to reflect changes in its services, systems, operational practices or legal obligations.

The updated version will be published on the website with a revised effective date. Material changes may also be communicated through another appropriate method.

15. Contacting ET

Questions, requests or complaints concerning this Privacy Policy or the processing of personal information may be submitted to:

Vertex Dynamics
Email: examterminator@proton.me

16. Governing Law

This Privacy Policy and ET’s processing of personal information are governed by the laws of the British Virgin Islands, including the Virgin Islands Data Protection Act, 2021, subject to any other mandatory data-protection laws that may apply to a particular individual or service.