Privacy and Security

In most cases, we do not knowingly collect Personal Information directly from children under the age of 16 on our Websites. Parents and schools may use our Websites 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 etsinfo@ets.org or by calling us at 1-609-921-9000.

ETS does provide parents and teachers with the ability to download certain apps that they and their children or students can use for educational purposes, such as to improve reading fluency. Some of these apps are intended for use by children under 13.

When children use these apps, ETS may collect the child's first name or nickname, age or grade in school, audio recordings of the child's voice when the child reads passages (or a transcript of the recording), the child's responses to questions that test skills such as reading comprehension and other data relating to the child's use of the app, such as how long the child spends using the app. Our apps do not collect any other Personal Information and they do not use cookies or other data-collection technologies.

ETS anonymizes the information collected by its educational apps and uses the information for research purposes. ETS does not maintain identifiable data about children, and children cannot make their own data publicly available via the apps. ETS does not (and will not permit any third party to) associate identifying information with research data.

Parents and teachers can review and delete the child's information at any time in the app. Parents and teachers can restrict ETS's collection of additional information at any time by deleting the app. Parents or teachers who have questions about how ETS handles children's data may contact ETS by sending us an email at etsinfo@ets.org or by calling us at 1-609-921-9000.

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, this may include information about your relationship with your test center and the tests you administer. If you use our platforms, such as GradConnect, we may collect additional relationship information to help match you with educational programs, fellowships, scholarships and similar offerings.
• 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 test center administrator 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 data, such as your voiceprint and writing samples. Additionally, if you test in a test center, we may collect your photograph and fingerprint. If you test online, we may collect and analyze your behavioral characteristics during the test, such as keystroke patterns when you complete writing portions of a test. 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 request 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.

When you visit and interact with our Website, we may also collect information that uses cookies and other data-collection technologies. Please see the section on Cookies below to learn more. This Privacy Notice governs us when we associate the information we collect using cookies and other technology with 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 interests and educational goals and to manage your communications preferences.
• Understand how you and others use our products and platforms, for analytics and modeling and to create recommendations and insights and to understand educational trends.
• Deliver messages and sponsored content to you from educational institutions and other partners via platforms, such as GradConnect.
• 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 collects and uses biometric identifiers 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 and to templates created from your government-issued identification documents.

ETS also collects and uses behavioral biometrics for test security in connection with online tests. For example, when you complete written portions of an online test, we may analyze keystroke patterns and other behavioral characteristics to help verify your identity and authenticate you based on these patterns. 

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 or who provide support for the biometric program. Biometric identifiers are retained for the duration of your score report (generally three years), unless a shorter period is required by law. To receive a copy of our Biometric Information Privacy Policy, please contact us via email at etsinfo@ets.org or write to us at the address in the “How to Contact ETS” section below.

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 Relay Reader™, 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.

Learn more about ETS Research.

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 disclose your Personal Information with your consent. For example, if you choose to participate in our Search Services or similar programs, we will share your information with participating schools and organizations so they can communicate with you about their programs.
• 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.

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.

If you have signed up for Search Service or otherwise given us permission to share your Personal Information with schools and other organizations, you can opt out at any time by contacting us via email at etsinfo@ets.org.

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 etsinfo@ets.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.)

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.

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.

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.

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 that 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.

If you have any questions or concerns about this Privacy Notice or our privacy or security practices, you may contact us by:                           

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.

Cookies
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.

Flash Cookies
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. 

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™ Service: 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.

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, birthdays, 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.

The California Consumer Privacy Act (or "CCPA") provides California residents with specific privacy rights, including the right to receive a privacy notice and to tell companies not to sell your Personal Information.

As a nonprofit, ETS is not directly subject to the CCPA. However, we are deeply committed to protecting the privacy and security of all the Personal Information that is entrusted to us. We do not sell Personal Information.

We have a global privacy program that protects your Personal Information no matter how or where it is collected, used or stored. We also comply with the privacy and security laws that are applicable to us. Our Privacy and Security Statement describes our privacy and security practices in detail.

If you have any questions or concerns about your privacy, please email us at etsinfo@ets.org.

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).