Privacy Policy

1. Introduction

ETT EDUCATION & TECHNOLOGY GROUP (“ETT,” “we,” “us,” or “our”) operates the ETT digital test-prep platform and related websites, mobile/desktop applications, APIs, and services (collectively, the “Services”). We respect your privacy and are committed to protecting your personal data in accordance with:

• the EU/UK GDPR,
• the California Consumer Privacy Act and California Privacy Rights Act (collectively “CCPA/CPRA”),
• the Children’s Online Privacy Protection Act (“COPPA”), and
• all other applicable international, federal, and state data-protection laws.

This Policy explains what information we collect, how we use it, with whom we share it, the choices and rights you have, and how to contact us.

2. Scope

This Policy covers personal data we process when you:

• visit or use our Services;
• attend an ETT event or webinar;
• communicate with us by email, phone, or otherwise; or
• interact with our marketing or social-media content.

It does not apply to third-party sites or services that link to or from our Services. Their privacy practices are governed by their own policies.

3. Data We Collect

Category: Examples – Source – Legal Basis (GDPR)

• Account Data: name, email, login credentials – You – Contract; Legitimate Interest
• Educational Data: test scores, question-level responses, progress analytics – You / automated collection – Contract; Legitimate Interest
• Payment Data: cardholder name, last 4 digits, billing address, transaction IDs (processed by our PCI-compliant payment partner) – You / payment processor – Contract; Legal Obligation
• Usage Data: log files, IP address, device ID, browser type, pages visited, time spent – Automated – Legitimate Interest
• Cookies & Similar Tech: session cookies, preference cookies, analytics cookies, advertising pixels – Automated – Consent (where required); Legitimate Interest
• Marketing & Communications: preferences, survey responses, correspondence – You – Consent; Legitimate Interest
• Research Data: de-identified or aggregated performance data – You / automated collection – Legitimate Interest; Consent (if re-identifiable)
• Sensitive Data (only if voluntarily provided): disability accommodations, demographic info for research – You – Explicit Consent

We do not knowingly collect data from children under 13. If we learn we have, we will delete it promptly.

4. How We Use Your Data

We use personal data to:

1. Provide and improve the Services (create accounts, deliver tests, generate score reports, personalize content).
2. Process transactions and manage subscriptions.
3. Respond to inquiries, support tickets, and feedback.
4. Conduct research to enhance learning efficacy and develop new features (results are reported only in aggregate or de-identified form).
5. Send administrative messages (service announcements, security alerts, policy updates).
6. Deliver marketing communications that you may opt out of at any time.
7. Detect and prevent fraud, misuse, or violations of our Terms of Use.
8. Comply with legal obligations and enforce our agreements.

We do not engage in automated decision-making that produces legal or similarly significant effects without human review.

5. Sharing & Disclosure

We never sell personal data. We share it only:

• With service providers (cloud hosting, payment processing, analytics, proctoring, email delivery) bound by strict confidentiality and data-processing agreements.
• With institutional or enterprise customers if you enroll through a school or educational organization, but only for legitimate educational purposes.
• For research & academic studies under written agreements that require results to be published in aggregate form; identifiable data is shared only with your explicit consent.
• During corporate events such as a merger, acquisition, or asset sale, where data transfer is necessary for business continuity (notice will be provided).
• When required by law or to protect rights, safety, or property of ETT, our users, or others.

6. International Data Transfers

ETT is headquartered in New Jersey, USA and operates worldwide. When we transfer personal data outside your country, we rely on:

• Adequacy decisions of the European Commission or UK Government
• Standard Contractual Clauses approved by the EU/UK, or
• Other legally permissible transfer mechanisms.

You may request a copy of current transfer safeguards via the contact details below.

7. Data Retention

We retain personal data only as long as necessary for:

• the purposes described in this Policy;
• legitimate business needs (e.g., maintaining account history);
• legal, accounting, or reporting requirements; or
• to resolve disputes and enforce agreements.

Upon request or account closure, we will delete or anonymize data unless we must keep it for the reasons above.

8. Security

We employ administrative, technical, and physical safeguards—such as TLS encryption, role-based access controls, regular penetration testing, and secure development practices—to protect your data. No system is 100 % secure; please notify us immediately at service@ett-test.com if you suspect unauthorized activity.

9. Your Rights

If you reside in the EEA/UK: you may exercise rights of access, rectification, erasure, restriction, portability, and objection. You also have the right to lodge a complaint with your supervisory authority.

If you are a California resident: you have the right to know, delete, correct, and opt out of “sharing” for cross-context behavioral advertising. To submit a request, email email or call +1-201-266-8882. We will verify your identity before processing.

Marketing Opt-Out: unsubscribe links are included in every promotional email. You may also adjust preferences in your account dashboard.

Research Opt-Out: You may opt out of your de-identified data being included in research studies by emailing us with the subject line “Research Opt-Out.”

We will not discriminate against you for exercising any privacy rights.

10. Cookies & Tracking Technologies

We use first- and third-party cookies and similar technologies to:

• Keep you logged in,
• Remember preferences,
• Analyze site traffic, and
• deliver relevant ads outside the platform.

Where required, we obtain consent via a cookie banner. You can manage cookies through browser settings or our Cookie Settings tool.

11. Third-Party Links

Our Services may contain links to external sites. We are not responsible for their privacy practices. Please review their policies before providing personal data.

12. Changes to This Policy

We may update this Policy periodically. Material changes will be highlighted on our website or emailed to you. Continued use of the Services after the effective date constitutes acceptance of the revised Policy.

13. Contact Us

For any questions, privacy requests, or complaints, please contact: