Educational Testing Service ("ETS") recognizes the importance of protecting your privacy. This Privacy Notice describes our practices related to personal information privacy and security.
ETS has a global privacy program to protect all "Personal Information." Personal Information is any information that we can use to identify you (such as your name, username or identification number) or contact you (such as your email address or telephone number). Personal Information includes other types of information (such as test scores or demographic data) when that information is associated with your Personal Information.
This Privacy Notice describes our practices with respect to Personal Information we collect via "Websites." The term "Website" includes all ETS websites, platforms and applications that collect personal information from you. It also describes our practices with respect to Personal Information collected in other ways, such as when you register for and take ETS tests, or when we receive information from a school or test center administrator. If you are a test taker, additional information about privacy and security is included in many of the ETS Test Bulletins.
By using an ETS Website or otherwise providing us with Personal Information, you agree to our privacy terms. You can contact us at any time with questions or concerns about privacy by sending an email to firstname.lastname@example.org or by writing to us at the addresses in the Contact section below.
Within this Privacy Notice, you will find information about:
- Information We Collect
- How We Use Your Personal Information
- Biometric Identifiers
- Use of Information by ETS Research
- Disclosure of Your Personal Information
- Your Rights and Choices
- Links to Third-Party Sites
- Security and Data Retention
- Changes to this Privacy Notice
- International Users and Transfers of Personal Information
- How to Contact ETS
- Information about Cookies and Other Data Collection Technologies
- Special Notice to California Residents
- Special Notice to Residents in the European Economic Area, Switzerland and the U.K.
Last Updated on July 26, 2019.
We do not knowingly collect Personal Information on our Websites directly from children under the age of 16. Parents and schools may use our Website to create accounts for children, such as registering them for tests. We encourage parents and teachers to spend time online with children and to monitor their online activities.
If you believe that a child has created an account on our Website, please contact us to have the account deactivated by sending us an email at email@example.com or by calling us at 1-609-921-9000.
Information We Collect
We collect the following types of Personal Information from you when you use our Websites:
- Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
- Relationship Information that helps us do business with you. For test takers, this may include the types of tests that you want to take, your school affiliation, expected degree and graduation date, and similar information that can help us offer you personalized content. It may also include demographic data, such as language(s) spoken, which helps support ETS Research. For professionals, this may include your professional credentials and affiliations and the products and services that may interest you or your school. For test center administrators, they may include information about your relationship with your test center and the tests you administer.
- Transaction Information about your activities with ETS, including your test registration records, test administration records, purchase history, order information about your use of our content (such as if you access your scores online, use test prep material or complete surveys), customer or TCA account information (such as if you email us for support) and payment card information as needed to process your payments.
In some cases, we may need to collect additional sensitive information from test takers and test center administrators in order to administer tests securely or to fulfill other requests that you may make. In particular:
- As permitted by law, we collect biometric samples at the test center such as your photograph, fingerprint, voiceprint and/or writing samples. Please see the section on Biometric Identifiers below to learn more.
- We may collect audio and video recordings in our test centers (including from premises monitoring equipment).
- If you request an accommodation from us regarding test arrangements for medical or religious reasons, we may collect Personal Information relevant to your request. Similarly, if you request a fee waiver, fee reduction or scholarship, we may collect Personal Information about your financial situation. Providing Personal Information about your religion, disability or medical condition, and/or financial status is optional, but if you are requesting an accommodation from ETS, you must provide the information so that we can process your request.
In each case, we will only collect and use these types of Personal Information as permitted by law and as needed for ETS's legitimate business purposes, such as maintaining the integrity and security of our tests or processing your accommodation request.
How We Use Your Personal Information
We may use your Personal Information to:
- Provide you with the products, content or services selected by you, such as to register you for and deliver tests, and send you service-related communications, such as identity verification, score delivery, customer service and account management.
- Subject to your choices, provide you with marketing communications, surveys and offers for products and services from ETS and our partners, including personalized offers based on your usage of our products and to manage your communications preferences.
- Improve our products and services (including for test usability and design, security and research), and to identify, develop and offer new or expanded products and services.
- Understand how you use our products, content and services, including associating you with different devices that you may use to access our content, to help personalize your experience on the Website, and customize the content and/or format of the pages you visit.
- Manage our everyday business needs, such as payment processing and financial account management, test center management, contract management, Website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.
- Generate aggregate statistical studies and conduct research ourselves or jointly with others related to our products and services and the use of our Website.
We may also use your Personal Information in other ways, if you consent to those uses.
Where permitted by law, ETS uses biometric data to identify and authenticate test takers and test center administrators. ETS collects digital photographs and digital voice recordings, and coverts these samples into mathematical representations called templates, which can be compared to the templates previously collected by ETS. ETS uses these templates solely to support test security and integrity and for related purposes (such prosecution of fraud or intellectual property theft). Biometric templates are securely stored and only accessible to those individuals and entities who reasonably need access to the data in connection with investigations, compliance and security.
Use of Information by ETS Research
ETS uses anonymized and pseudonymized information for various research initiatives. For example, ETS may consider how certain types of test takers (such as nonnative English speakers) respond to specific test questions. Similarly, educational apps, such as MyTurnToRead, collect data to help ETS understand and improve reading skills. ETS's research initiatives reflect our commitment to fairness and equity in testing, helping to ensure that our tests are accessible and free from bias. They also seek to improve teaching, learning and assessment.
ETS may process Personal Information as needed to create de-identified datasets for research. ETS will not (and will not permit any third party to) associate identifying information with research data. Our research results do not contain any identifiable data, and research data are not used to target or profile individuals.
Disclosure of Your Personal Information
We will only disclose your Personal Information as follows:
- We may disclose your Personal Information to our affiliates, who will only use your Personal Information for the purposes listed above.
- We may disclose your Personal Information to third parties that provide services to us. For example, when you register for a test, we will provide certain registration information to third parties that administer the tests in your area. We use service providers for other functions as well, including data hosting and other business activities such as printing, mailing and/or payment processing. We require such third-party processors to use your Personal Information in accordance with our instructions, and they may not use your Personal Information for their own purposes.
- We may disclose your Personal Information as needed to provide services to you. For example, you may instruct us to disclose your test scores to schools and others. We may also share your Personal Information with our partners, but only to the extent that you have a relationship with such partner or you authorize the sharing. For example, we may share information with test prep providers, if you elect to use the materials or as needed to validate referrals and operate the platforms.
- We may also disclose Personal Information in accordance with applicable law, in connection with any sale or transfer of our business or assets, to assert or defend our rights and property, or to prevent harm to others. For example, we may disclose Personal Information to third parties when we investigate claims of misconduct or other incidents that may occur in our test centers. We will also always disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated and statistical data. These reports do not contain any Personal Information.
Your Rights and Choices
When you register for a test online or create an account, we ask you to provide your contact details, including email address, telephone and mobile phone details. We use this information so that we can quickly provide you with information regarding the products and services you have requested.
If we have your consent (or if you have not objected), we may send other communications to you, such as surveys and information about other testing products and services. You can limit these communications at any time. To opt out of emails, simply click the link labeled "Unsubscribe" at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message. Remember, however, that we may still send emails or call you in order to provide the testing services you have purchased or otherwise requested from us.
We also respect your right to reasonably access and correct your Personal Information, and ETS complies with all laws regarding access, correction and deletion. If you have an online account, you can log into your account at any time to access and update the information you have provided to us (with the exception of your name, gender, birthdate or Social Security number, if provided). If you need assistance updating your Personal Information or if you would like to request that we delete your information, please contact us via email at firstname.lastname@example.org. Please understand that we will have to verify your identity prior to fulfilling these requests. Additionally, to help ensure the accuracy of our data, we may require appropriate evidence prior to making a change. (For example, if you wish to change your name, we will require proof that your name has been changed legally, such as a marriage certificate or court decree.)
Links to Third-Party Sites
This Website may contain links to other third-party websites. In particular, the Website may contain links to third parties that provide test preparation materials (such as Amazon® and EdX®) as well as to social media platforms, such as Facebook®, Instagram®, LinkedIn® and Twitter®. ETS does not control the privacy policies or practices of these third-party sites. You should review those policies before providing any information, including on a social media page for ETS. ETS is not responsible for the content or practices of any third-party sites, and we provide these links solely for the convenience and information of our visitors.
Security and Data Retention
ETS has established safeguards to help prevent unauthorized access to or misuse of your Personal Information. These safeguards include physical, technical, organizational and administrative controls.
If you register for a Website account, you will be asked to select a password to help protect your information. These passwords help us verify your identity before granting access or making corrections to any of your Personal Information. You should never disclose your password to anyone. ETS will never ask you for your password in an unsolicited phone call or email. If you believe that your password or your account has been compromised, please contact us as soon as possible.
ETS also has an established records retention program. We retain Personal Information as needed for the purposes listed above and for any additional period of time that may be required by law. Unless the data are being retained in connection with a specific investigation, biometric templates are retained for a maximum of three years.
Changes to this Privacy Notice
ETS reserves the right to update this Privacy Notice, including to respond to new laws, regulations, or technology, or for other business reasons. Please check this Website from time to time to review any such changes. Changes will become effective when posted on the Website for all Personal Information collected after the date of the change. If the changes will materially affect the way we use or disclose previously collected Personal Information, we will notify you about the change by sending a notice to the primary email address associated with your account.
International Users and Transfers of Personal Information
ETS, its Website, and its servers are located in the United States. Therefore, your information, including Personal Information, will be transferred from your location to the United States. It may also be transferred to other countries who provide processing services to ETS at the direction of ETS. However, regardless of where your Personal Information is transferred, we will protect it in accordance with this Privacy Notice.
How to Contact ETS
If you have any questions or concerns about this Privacy Notice or our privacy or security practices, you may contact us by:
P.O. Box 6666
Princeton, NJ 08541-6666
Information about Cookies and Other Data Collection Technologies
When you visit our Website, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our Websites and to understand website traffic patterns.
In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Notice governs how we use that information when we associate it with your Personal Information.
When you visit our Website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected devices to uniquely identify your browser or to store information or settings in your browser. We use both temporary (session) cookies and persistent cookies, which allow us to recognize you when you return. Cookies help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the "Help" section of your browser to learn about cookie preferences and other privacy settings that may be available.
We may use Flash cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe® Flash technology.The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.
We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe's website. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain content and product features.
Pixel Tags and Web Beacons
Pixel tags and web beacons are tiny graphic images placed on our Website(s) or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
Server Logs and Other Technologies
We collect many different types of information from server logs and other technologies. For example, we may collect information from the device you use to access our Website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to ETS and the website you visit after you leave our site.
Third-Party Advertisers and Browser Tracking Information
We have relationships with third-party advertising companies to place advertisements on this Website and other websites, and to perform tracking and reporting functions for this Website and other websites. These third-party advertising companies may place cookies on your computer when you visit our Website or other websites so that they can display targeted advertisements to you.
These third-party advertising companies do not collect Personal Information in this process, and we do not give any personal information to them as part of this process. However, this Privacy Notice does not cover the collection methods or use of the information collected by these companies. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) website. You can opt out of being targeted by many third-party advertising companies by visiting NAI's Opt-Out page or the TrustArc® website.
Additional information from the third-party advertising companies that we work with:
- Google Analytics™: For information on how Google Analytics uses data, please visit How Google uses data when you use our partners' sites or apps
Although our Websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer our customers choices to manage their cookie preferences as described in the previous section. To learn more about browser tracking signals and the Do Not Track browser setting, please visit All About Do Not Track.
Social Media Interactions and Interest-based Ads
Our Websites may enable you to interact with us and others via social media platforms, such as Facebook®, LinkedIn®, Twitter®, Pinterest® and Instagram®. While we respect each social media platform's privacy policies, we may collect Personal Information about you and your friends/connections if you choose to use these tools.
For example, we may allow you to sign into ETS Websites and applications using Facebook Connect. If you choose to do this, we may collect information necessary to facilitate social interactions such as friend lists, birthday, check-ins, basic profile information and your profile picture but only if the privacy settings you and your friends set within Facebook allow it. We will use the information to facilitate an interactive social experience.
We may display interest-based ads to you when you are using platforms such as Facebook and Google®. These platforms allow us to personalize the ads that we display to you. We do not share any of your Personal Information with these platforms, although we may convert your email address into a unique number which can be matched by the platform with its user to allow delivery of the advertising. Although we do not provide any personal information to these platforms, they may gain insights about individuals who respond to the ads we serve.
Special Notice to California Residents
ETS does not sell any California consumer personal information.
Special Notice to Residents in the European Economic Area, Switzerland and the U.K.
ETS is providing this supplemental privacy notice to give individuals in the European Economic Area (EEA) the additional information required by the EU General Data Protection Regulation. These provisions, together with the statements in the ETS Privacy Notice, explain our practices with regard to EEA personal data. These statements also apply to personal data collected in Switzerland and the United Kingdom (post-Brexit).
Information About ETS
This notice is being given by ETS in the United States, for itself, its EU Representative (ETS Global BV) and its other EEA affiliates.
- U.S. Mail:
- Educational Testing Service (ETS)
660 Rosedale Road
Princeton, NJ 08541 USA
- EU Mail:
- ETS Global BV
Academic & Business Assessments
1077 XX Amsterdam – The Netherlands
The Purposes and Legal Basis for Processing, Including Legitimate Interests
The Privacy Notice explains the reasons why we process your Personal Information. We only process Personal Information when we have a legal basis for the processing, such as:
- To fulfill a contract with you, such as to provide you with an ETS test or a test offered by another company through ETS.
- For closely related purposes, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.
- With your consent (or provided you have not objected, as may be applicable), such to provide you with marketing communications or to send your scores to your designated recipients.
We may also process your Personal Information for the purposes of our legitimate interests, provided that such processing shall not outweigh your rights and freedoms. In particular, we may process your Personal Information as needed to:
- Protect you, us or others from threats (such as security threats or test fraud)
- Improve ETS's tests and support ETS Research Initiatives
- Comply with the laws that are applicable to us around the world
- Enable or administer our business, such as for quality control, consolidated reporting and customer service
- Manage corporate transactions, such as mergers or acquisitions
- Understand and improve our business, improve test integrity and for research purposes
Automated Decision Making and Profiling
ETS may use automated processes in connection with scoring tests and for similar purposes as needed to provide the test services that you have requested. All such decisions are subject to human review. We will not make automated decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology. You can learn more about test scoring by reading the information posted on our Website about each of our tests.
In some cases, we use certain elements of personal data for ETS Research. For example, we may consider how certain types of test takers (such as nonnative English speakers) respond to specific test questions. Our research initiatives reflect our commitment to fairness and equity in testing, helping to ensure that are our tests are accessible and free from bias. They also seek to improve teaching, learning and assessment. Our research results do not contain any identifiable data, and are not used to target or profile individuals. Learn more about ETS Research.
When You Are Required to Provide Personal Information to ETS
In most cases, you are not required by law to provide any Personal Information to ETS. You are required to provide certain Personal Information to enable us to enter into a contract with you so that you can use our products and services. Our registration forms indicate which data elements are required for our contracts. If you do not provide these data elements, we cannot do business with you.
If you request an accommodation from ETS, such as special testing conditions needed because of a health condition or disability, you may be required to submit additional Personal Information (including special categories of data) as needed for us to evaluate and respond to your request.
As stated in the Privacy Notice, you always have the right to object to our marketing communications. To opt out of emails, simply click the link labeled "Unsubscribe" at the bottom of any email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message.
ETS also respects the rights of EEA, Swiss and U.K. residents to access, correct and request erasure or restriction of their personal information as required by law. This means:
- You generally have a right to know whether or not ETS maintains your Personal Information. If we do have your Personal Information, we will provide you with a copy (subject to the rights of others). If your information is incorrect or incomplete, you have the right to ask us to update it.
- You have the right to object to our processing of your Personal Information.
- You may also ask us to delete or restrict your Personal Information.
To exercise these rights, please contact us via email at email@example.com or write us at the U.S. address above, and a member of our Privacy Team will assist you. Please understand that we may need to verify your identify before we can process your request. Additionally, our ability to delete Personal Information will be limited in those cases where we are required to retain records, such as in connection with score reports and test security processes.
If you believe that we have processed your Personal Information in violation of applicable law, you may file a complaint with the ETS Office of the General Counsel or with a supervisory authority.
As stated in the Privacy Notice, your Personal Information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws.
We generally use approved Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the EEA, U.K. or Switzerland, but we may also make transfers to recipients with approved Binding Corporate Rules or to recipients in the United States who have certified to the EU-U.S. and/or Swiss-U.S. Privacy Shield Framework.
Please contact us via email at firstname.lastname@example.org if you would like more information about cross-border transfers or to obtain a copy of the Standard Contractual Clauses.
We will retain your Personal Information for as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law. You may request that we delete your Personal Information by contacting us via email at email@example.com. Unless we are required by law or have a legitimate interest to retain your information, we will delete it within 30 days of your request.
How to Contact Us
Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice. You can always reach us via email at firstname.lastname@example.org. You can also reach us via mail at the addresses given above.
Effective Date: July 26, 2019
Updated to clarify that U.K. data will be handled in accordance with this statement post-Brexit.