1. Overview and Data Controller Role
ORVANE provides software infrastructure for travel compliance verification. Depending on how you interact with our platform, the data controller and data processor roles operate as follows:
Candidate Data Managed via Sponsoring Agencies
When a visa agency, employer, or academic institution registers a traveller for a destination program, the sponsoring agency acts as the primary Data Controller. ORVANE acts as Data Processor, handling assessments and issuing credentials under the agency’s lawful instructions.
Direct User and Account Credentials
ORVANE acts as Data Controller for direct agency administrator accounts, system audit logs, and public verification records generated across our platform.
2. Information We Collect
We limit our collection to information directly necessary for authentication, curriculum delivery, assessment scoring, and public credential validation:
A. Candidate and Identity Records
Provided by the sponsoring agency or entered by the traveller:
- Full legal name matching passport documentation;
- Email address and account credentials;
- Passport or government document number (where required for unambiguous credential verification matching);
- Nationality and intended destination country;
- Assigned sponsoring agency identifier.
B. Assessment and Proctoring Telemetry
Generated automatically during assessment participation:
- Timestamps of test initiation, question progression, and completion;
- Strict configured countdown session elapsed duration;
- Category-level scores and final pass/fail determination;
- Window focus events and tab-switching alerts captured during proctoring guards.
C. Verification Query and Technical Telemetry
Logged when public verifiers look up credentials:
- IP address, browser user-agent, and query timestamp;
- Credential serial ID queried and returned result status.
3. Purposes and Legal Bases for Processing
We process personal data under recognized lawful bases:
4. Public Verification Directory and QR Scanning
Transparency Disclosure Regarding Public Credential Lookup
A primary function of ORVANE is enabling third-party verification of completion records by authorized users. It is not a government, airline, or border-authority verification service.
When a completion record is generated, a unique URL may be created. Anyone in possession of the certificate link, certificate serial ID, or physical QR code may view the public verification page at /verify/[certificateId].
The public verification page displays only:
- Whether the submitted record is currently valid;
- The certificate number supplied by the requester.
Sensitive data such as raw question responses, individual missed questions, and account passwords are never displayed on public verification records.
6. Data Security and Cryptographic Protections
ORVANE employs multi-layered technical controls to preserve the confidentiality, integrity, and availability of candidate data:
User authentication credentials are salted and hashed with modern Argon2 algorithms, preventing reverse-engineering from data stores.
Official question bank keys and answer matrices are never transmitted to client browser bundles, eliminating client-side extraction vectors.
Deployment-specific transport, storage encryption, retention, and monitoring controls must be verified for the environment in which ORVANE is operated. This notice does not promise a particular TLS version or storage architecture.
7. Data Retention and Deletion
We retain personal data only as long as necessary to fulfill the operational, legal, and verification purposes for which it was gathered:
- Active Account Credentials: Retained for the duration of the sponsoring agency agreement or until account closure.
- Issued completion records: Retention is configured by the responsible agency and applicable policy; contact the issuing agency for details.
- Proctoring evidence and focus events: Retention and deletion workflows must be confirmed before production use.
8. Candidate Rights and Self-Determination
Depending on your jurisdiction (including rights under the EU/UK General Data Protection Regulation), you hold specific entitlements regarding your personal data:
- Right of AccessRequest a copy of personal information and assessment scores held about you.
- Right to RectificationCorrect inaccurate name, passport, or contact details prior to credential locking.
- Right to PortabilityExport your verifiable credentials for presentation to new agencies or border officials.
- Right to ErasureRequest account deletion, subject to necessary regulatory record preservation.
To exercise your rights, email support@orvane.com with verification of your identity.
9. International Data Transfers
Because international travel compliance inherently involves cross-border mobility, verification data may be accessed from destination nations (such as border points in Japan, the United Kingdom, the European Union, or Australia).
When transferring personal data internationally, we utilize standard contractual clauses (SCCs) and appropriate technical encryption measures to safeguard candidate information across global networks.
10. Contact and Data Protection Inquiries
If you have questions regarding this Privacy Policy, wish to file a subject access request, or need to reach our data protection officer: