Update Ets Privacy Policy

This version was recorded after filtering snapshot tosdr/tosback-snapshots@9055a35a45

Ets/Privacy Policy.md

@@ -23,34 +23,16 @@ Educational Testing Service ("ETS") recognizes the importance of protecting your
 
 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.
 
+Privacy Notice
+--------------
+
 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 [etsinfo@ets.org](mailto:etsinfo@ets.org) or by writing to us at the addresses in the Contact section below.
 
 Within this Privacy Notice, you will find information about:
 
-*   [Children](#Children)
-*   [Information We Collect](#Collect)
-*   [How We Use Your Personal Information](#HowWeUse)
-*   [Biometric Identifiers](#biometric)
-*   [Use of Information by ETS Research](#research)
-*   [Disclosure of Your Personal Information](#Disclosure)
-*   [Your Rights and Choices](#OptOut)
-*   [Links to Third-Party Sites](#Links)
-*   [Security and Data Retention](#Security)
-*   [Changes to this Privacy Notice](#Changes)
-*   [International Users and Transfers of Personal Information](#International)
-*   [How to Contact ETS](#Contact)
-*   [Information about Cookies and Other Data Collection Technologies](#Cookies)
-
-*   [Third-Party Advertisers](#Advertisers)
-*   [Social Media Interactions and Interest-based Ads](#Social)
-
-*   [Special Notice to California Residents](#California)
-*   [Special Notice to Residents in the European Economic Area, Switzerland and the U.K.](#European)
-
-Children
---------
+### Children
 
 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](mailto:etsinfo@ets.org) or by calling us at 1-609-921-9000.
 
@@ -62,10 +44,7 @@ ETS anonymizes the information collected by its educational apps and uses the in
 
 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 any questions about how ETS handles children's data may contact ETS by sending us an email at [etsinfo@ets.org](mailto:etsinfo@ets.org) or by calling us at 1-609-921-9000.
 
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-
-Information We Collect
-----------------------
+### Information We Collect
 
 We collect the following types of Personal Information from you when you use our Websites:
 
@@ -83,10 +62,7 @@ In each case, we will only collect and use these types of Personal Information a
 
 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.
 
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-
-How We Use Your Personal Information
-------------------------------------
+### How We Use Your Personal Information
 
 We may use your Personal Information to:
 
@@ -101,28 +77,19 @@ We may use your Personal Information to:
 
 We may also use your Personal Information in other ways, if you consent to those uses.
 
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-
-Biometric Identifiers
----------------------
+### Biometric Identifiers
 
 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 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 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 to [etsinfo@ets.org](mailto:etsinfo@ets.org) or write to us at the addresses in the Contact section below.
 
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-
-Use of Information by ETS Research
-----------------------------------
+### 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 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](http://www.ets.org/research).
 
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-
-Disclosure of Your Personal Information
----------------------------------------
+### Disclosure of Your Personal Information
 
 We will only disclose your Personal Information as follows:
 
@@ -134,10 +101,7 @@ We will only disclose your Personal Information as follows:
 
 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.
 
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-
-Your Rights and Choices
------------------------
+### 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.
 
@@ -147,42 +111,27 @@ If you have signed up for Search Service or otherwise given us permission to sha
 
 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](mailto: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.)
 
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-
-Links to Third-Party Sites
---------------------------
+### 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.
 
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-
-Security and Data Retention
----------------------------
+### 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.
 
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-
-Changes to this Privacy Notice
-------------------------------
+### 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.
 
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-
-International Users and Transfers of Personal Information
----------------------------------------------------------
+### 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.
 
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-
-How to Contact ETS
-------------------
+### 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:
 
@@ -198,10 +147,7 @@ P.O. Box 6666
 Princeton, NJ 08541-6666  
 USA
 
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-
-Information about Cookies and Other Data Collection Technologies
-----------------------------------------------------------------
+### 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.
 
@@ -213,7 +159,7 @@ 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 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](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html). If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain content and product features.
 
@@ -223,8 +169,6 @@ Pixel tags and web beacons are tiny graphic images placed on our Website(s) or i
 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.
 
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-
 ### 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.
@@ -237,8 +181,6 @@ Additional information from the third-party advertising companies that we work w
 
 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](http://www.allaboutdnt.org/).
 
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-
 ### 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.
@@ -247,10 +189,7 @@ For example, we may allow you to sign into ETS Websites and applications using F
 
 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.
 
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-
-Special Notice to California Residents
---------------------------------------
+### Special Notice to California Residents
 
 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.
 
@@ -260,14 +199,11 @@ We have a global privacy program that protects your personal information no matt
 
 If you have any questions or concerns about your privacy, please [Contact Us](mailto:etsinfo@ets.org).
 
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-
-Special Notice to Residents in the European Economic Area, Switzerland and the U.K.
------------------------------------------------------------------------------------
+### 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
+#### Information About ETS
 
 This notice is being given by ETS in the United States, for itself, its EU Representative (ETS Global B.V.) and its other EEA affiliates.
 
@@ -340,24 +276,19 @@ We will retain your Personal Information for as long as the information is neede
 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 [etsinfo@ets.org](mailto:etsinfo@ets.org). You can also reach us via mail at the addresses given above.
 
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-
 Updated to clarify that U.K. data will be handled in accordance with this statement post-Brexit.
 
+Country-specific Privacy Notices/Translations
+---------------------------------------------
+
+\--Select your country-- Brazil
+
 See also:
 ---------
 
 *   [ETS.org Terms of Use](http://www.ets.org/legal/terms/)
 
-Last Updated on May 1, 2020.
-
-Promotional Links
------------------
-
-### Related Links
-
-*   [General Licensing Permission Form](http://www.ets.org/legal/permissions/requests)
-*   [Research Licensing Permission Form](http://www.ets.org/legal/permissions/requests_research)
+Last Updated on March 3, 2021.
 
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