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 – Contract; Legitimate Interest
• Payment Data: cardholder name, last 4 digits, billing address, transaction IDs – You / processor – Contract; Legal Obligation
• Usage Data: log files, IP address, device ID, browser type – Automated – Legitimate Interest
• Cookies & Tech: session, preference, analytics cookies – Automated – Consent; Legitimate Interest
• Marketing: preferences, surveys, correspondence – You – Consent; Legitimate Interest
• Research Data: de-identified performance data – You / automated – Legitimate Interest; Consent (if re-identifiable)
• Sensitive Data (optional): disability, demographics – 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

• Provide and improve the Services
• Process transactions and manage subscriptions
• Respond to inquiries and feedback
• Conduct research (aggregate/de-identified results)
• Send service messages and policy updates
• Send marketing communications (opt-out available)
• Detect/prevent fraud or misuse
• Comply with legal obligations

We do not engage in automated decision-making with legal effects without human review.

5. Sharing & Disclosure

We never sell personal data. We share it only:

• With service providers under strict agreements
• With institutions if you enroll through one
• For research (aggregated, with consent if identifiable)
• During corporate changes (e.g., acquisition)
• As legally required or to protect rights/safety

6. International Data Transfers

We operate worldwide. Data transfers are based on:

• EU/UK adequacy decisions
• Standard Contractual Clauses (SCCs)
• Other legal mechanisms

You may request transfer safeguards via our contact info.

7. Data Retention

We retain data only as long as needed for:

• Policy-described purposes
• Business/legal obligations
• Dispute resolution and enforcement

We will delete/anonymize data upon request or closure unless exceptions apply.

8. Security

We use safeguards like TLS encryption, role-based access, penetration testing, and secure development to protect your data. No system is 100% secure; report concerns to service@ett-test.com.

9. Your Rights

EEA/UK Residents: Rights to access, rectify, erase, restrict, port, and object; lodge a complaint.

California Residents: Rights to know, delete, correct, and opt out of sharing for behavioral ads.

Submit requests via email or call +1-201-266-8882. We verify identity before processing.

Marketing Opt-Out: Use unsubscribe links or adjust account settings.

Research Opt-Out: Email with subject "Research Opt-Out".

We do not discriminate for exercising rights.

10. Cookies & Tracking Technologies

We use cookies to:

• Keep you logged in
• Remember preferences
• Analyze traffic
• Serve ads off-platform

Consent is obtained where required. Manage via browser or Cookie Settings tool.

11. Third-Party Links

Our Services may link to external sites. Their privacy practices are independent. Review their policies before use.

12. Changes to This Policy

We may update this Policy. Material changes will be highlighted on our site or emailed. Continued use means acceptance.

13. Contact Us