Privacy policy
How the CertBara exam system and the CertBara Companion app process the personal data of candidates, examiners, assessors and certification centre staff.
1. Who is responsible
The controller of the exam data is the organiser of the exam – the exam centre that runs it or the certification body for which it is held. The organiser decides who takes part, what records are kept about the exam and for how long. You will find their contact details in your exam invitation or receive them on site.
The system is operated by SAFE TREES, s.r.o. It processes exam data for the organisers as a processor under Article 28 GDPR – only on their instructions and only for their exams. It acts as a controller only for the data needed to run and secure the system: exam centre and administrator accounts and security records of sign-ins.
SAFE TREES, s.r.o.Kyselkova 285/4, 612 00 Brno, Czech Republic
Company ID 26935287
E-mail: kolarik@safetrees.cz · phone +420 546 412 793
2. What data we process
| Category | Details | Whom it concerns |
|---|---|---|
| Identity and contact | first name and surname, e-mail, form of address (Mr/Ms – for the correct wording of letters), certification registration numbers (e.g. EAC ID, ČCA ID), vest number at the exam, and where applicable the number of the ID document you show at the exam | candidates, examiners, assessors |
| Application and entry requirements | certification level, type of attempt (first attempt, retake), previously recognised parts and the dates they were passed, whether entry requirements are met and the fee is paid (yes/no), checks of documents and equipment (status, issue and expiry date, who checked them) | candidates |
| Exam progress and results | answers in tests, texts of professional reports, sketches, points and assessments of each part, examiners' notes, the result, result sheets and result letters | candidates; assessments also carry the examiner's name |
| Recordings, photos, scans | audio recordings of practical and oral parts, photos of reports, worksheets and trees, scans of paper tests, videos and files taken in the Companion app; for ETW also supervisor recordings with a transcript and translation. Photos and videos may also show a person performing a task. | candidates, examiners |
| Integrity of the electronic test | leaving the test window or switching to another app, leaving full-screen mode, copy and paste, printing, reloading the page and the time spent away | candidates who take the test on a tablet |
| Audit trail | who did what, when and in which role (e.g. saved an assessment, opened or closed the exam) | all users |
| Technical and security data | a random device identifier and when the device was first and last used, a fingerprint of the IP address created with a secret key (the IP address itself cannot be derived from it) and the browser type at sign-in or PIN verification; PINs and access links are stored only as irreversible hashes | all users |
| Centre and administrator accounts | e-mail, user name, role, access validity, time of last sign-in; for administrators also the second sign-in factor | centre staff, administrators |
What we do not process: date of birth, national identification number, postal address or phone number. The system does not store medical or other documents or copies of them – it only records whether a document was shown, when it was issued, until when it is valid and who checked it.
Device location is used only to show your position on the exam site map, on the device itself. It is not sent to the server; only the coordinates of the trees and the exam site placed on the map by an examiner or the centre are stored.
3. Why we process data and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Organising and running the exam, assessment, results and result documents | performance of the certification contract the candidate entered into by applying (Art. 6(1)(b)); for examiners and assessors their contract or agreement with the organiser |
| Recordings, photos and scans as evidence of the assessment; handling objections and appeals | the organiser's legitimate interest in fair and verifiable assessment (Art. 6(1)(f)) and the rules of the certification scheme |
| Test integrity records and the audit trail | the organiser's legitimate interest in a properly conducted exam (Art. 6(1)(f)) |
| Keeping results to verify certification and for recertification | the rules of the certification scheme and the organiser's legitimate interest (Art. 6(1)(f)), or a legal obligation (Art. 6(1)(c)) |
| Sign-in, access protection and system security | legitimate interest in securing the system and the data (Art. 6(1)(f)) |
There is no automated decision-making. The system adds up points according to the certification rules, but the result of the exam is decided by the examiners and the certification body. Test integrity events are only recorded; an examiner assesses them. We do not use the data for profiling, advertising or any purpose other than the exam.
4. Who can access the data
- The exam organiser: authorised staff of the exam centre and the certification body. Examiners and assessors see the candidates and exam parts assigned to them. Every exam is kept separate in the system; people working on one exam cannot see the data of others.
- An external reviewer, if the centre gives them access to specific materials (for example in an appeal), only for a limited time and with a PIN.
- The information screen at the centre may show the names of candidates and examiners and the state of the exam during the exam.
- The system operator SAFE TREES, only as far as needed for operation, support and fixing errors.
- Authorities only where the law requires it.
The system is provided with the help of these service providers (sub-processors):
| Provider | Purpose | Where data is processed |
|---|---|---|
| Supabase, Inc. | database, file storage (recordings, photos, scans), sign-in of centre and administrator accounts | data centre in Paris (France, EU) |
| Vercel Inc. | hosting of the web application and the server functions through which communication with the database passes | content is delivered from European network nodes; the server functions run in Paris (France, EU) |
| ČÚZK, Esri, OpenStreetMap Foundation | map tiles when the exam site map is shown; they receive only the request for a map area and the device's IP address | Czech Republic, USA, United Kingdom |
| Anthropic, PBC (ETW only, if enabled) | machine translation of speech on the ETW supervisor tablet when the device has no built-in translation; only a segment of the speech transcript is sent | USA |
| Browser speech recognition (Google, Apple) | live transcription of speech on the ETW supervisor tablet; speech is processed by the service of the browser the tablet uses | depending on the browser provider, also outside the EU |
The system uses no advertising, analytics or third-party tracking tools, and we do not sell any data. The system does not send e-mails itself.
5. Transfers outside the EU
The database, file storage and server functions run in the EU (Paris). However, the providers Supabase and Vercel are companies based in the USA, and Esri maps and, where used, Anthropic, Google and Apple process data in the USA. Transfers rely on the European Commission's standard contractual clauses or, where the recipient is certified, the EU–U.S. Data Privacy Framework. The United Kingdom has an adequacy decision of the European Commission.
6. How long data is kept
- Exam data (roster, assessments, results, recordings, scans) is kept for the period set by the organiser under the certification rules – usually as long as needed to handle appeals, prove certification and for recertification. Closing an exam does not delete data; the organiser can delete it, or the operator does so on the organiser's instruction. When our cooperation with an organiser ends, we delete the data of their exams or hand it over to them.
- Centre and administrator accounts last until they are cancelled; when access expires the account is not deleted, it just stops working.
- Security records of sign-ins are kept as long as needed to keep the system secure.
- Data on your device stays until you delete it (see Cookies and data on your device).
7. Security
- all communication is encrypted (HTTPS),
- candidates and examiners get access through personal links; the system stores only a hash of the link, not the link itself,
- a further device is verified with a PIN, stored only as an irreversible hash; repeated wrong entries lock the PIN,
- administrators sign in with two-factor authentication,
- only the CertBara server accesses the database; files are kept in non-public storage and download links are valid for one hour,
- exams are kept separate from each other and every action is written to the audit trail.
8. Cookies and data on your device
CertBara does not use cookies or tracking technologies. So that the exam works even with a weak signal, the application stores in the browser or tablet the data it needs to work: the sign-in, a random device identifier, unfinished answers and assessments, recordings and photos before they are sent, and the queue of data waiting to be sent. This storage is strictly necessary and needs no consent.
Data on the device is not deleted automatically after sending, so that nothing disappears before the server confirms it. You can delete it by clearing the site data in your browser; the centre's tablets have a Tablet check page that shows the stored data and lets you delete data older than 7 days. Delete data only after you have checked that it was sent.
This information website uses no cookies and no analytics.
9. The CertBara Companion app
The app opens the CertBara workspaces with a QR code from the centre and reliably stores and sends recordings, photos, videos and files for the exam. It contains the same workspaces as the web, so everything above applies to it. In addition:
- Permissions: camera (reading QR codes, photos and videos), microphone (recording the exam, also with the screen locked until you stop recording), photo library (picking files to send), local network (connection to the centre's computer) and location (only on the exam site map while it is open). You can withdraw any permission in the device settings.
- On the device the app stores access links and sessions, the list of candidates to choose from for a recording, the files taken and a random device identifier. It sends files only to the CertBara server that issued the access QR code.
- Deleting: nothing is deleted until the server confirms receipt. You delete confirmed files in the Queue with Uvolnit místo (Free up space), and everything else by uninstalling the app.
- The app contains no advertising, analytics or crash-tracking tools.
10. Your rights
You have the right of access to your data, rectification, erasure, restriction of processing and data portability. You may object to processing based on legitimate interest (recordings, test integrity records, security records).
Please send requests about an exam – including results and recordings – to the exam organiser, who decides on them. If you cannot reach them, write to us at kolarik@safetrees.cz; we will forward your request and help to handle it. We handle requests about centre accounts and the operation of the system directly. We reply within one month at the latest and may need to verify your identity.
You can lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, uoou.gov.cz, or with the supervisory authority in the country where you live or work.
11. Changes to this policy
We update this policy when the system or its providers change. The current version is always on this page with the date of the last change.
Last updated: 17 October 2026