privacy policy and disclosures

Privacy Policy and Disclosures

Effective July 27, 2022

The policies below include our refund policies, and describes the types of information we may collect from you or that you may provide when you visit the websites erblearn.org, erb.education, iseetest.org, admission.erblearn.org, iseeonline.erblearn.org and others that may be created by ERB (our "websites"), as well as our practices for collecting, using, maintaining, protecting and disclosing that information. ERB is based in the United States, and as such all of the information collected from our websites is collected, used, processed, and maintained within the United States.

Refund Policies

Refund policies are product specific. Please see below for details.

Disclosures

Certain ERB Member and family programs are provided by third parties, not by ERB. Some providers pay a royalty fee to ERB for the use of its intellectual property. These fees are reinvested in new program development and to provide greater access to ERB's assessments for at-need families. Some provider offers are subject to change and may have restrictions.

Mobile Terms and Conditions

Receive testing alerts and promotional messages regarding products or services from ERB through your mobile device. Opt-in by Web (iseeonline.erblearn.org, www.erblearn.org)  or] Text  ERB, ISEE, RESULTS, ENROLL, PREP, WRITING, ADMISSIONS, BENCHMARK, MILESTONES, APPLY, REGISTER, LEARN, ANALYTICS, DATA, or REPORTS  to  68312. Message frequency Varies.  Message and data rates may apply.
By opting in to this service, you consent to receive mobile text alerts using an automatic telephone dialing system. Consent to receive marketing text messages is not required as a condition of purchasing any goods or services.
By signing up, you are confirming you are over the age of 13.

STOP Information

Text STOP to 68312 to stop receiving alerts and messages from ERB (you will receive a confirmation text).

HELP Information

For additional information, text HELP to 68312 or contact (800) 989-3721.

Supported Carriers

AT&T, Sprint, T-Mobile®, Verizon Wireless, Boost, Cricket, MetroPCS, U.S. Cellular, Virgin Mobile, Google Voice, ACS Wireless, Advantage Cellular (DTC Wireless), Appalachian Wireless, Atlantic Tele-Network International (ATN), Bandwidth, Bluegrass Cellular, Buffalo Wireless, CableVision, Carolina West Wireless, Cellcom, Copper Valley, C-Spire Wireless (formerly Cellsouth), Cellular One of East Central Illinois, Chariton Valley Cellular, Cross (dba Sprocket), Duet IP, Element Mobile, EpicTouch, GCI Communications, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri Cellular), i Wireless (IOWA Wireless), Illinois Valley Cellular, Immix (Keystone Wireless / PC Management), Inland Cellular, Mobi PCS (Coral Wireless LLC), Mosaic, MTA Communications, MTPCS / Cellular One (Cellone Nation), Nex-Tech Wireless, Panhandle Telecommunications, Peoples Wireless, Pine Belt Wireless, Pine Cellular, Pioneer, Plateau, Revol Wireless, RINA, SI Wireless/Mobile Nation, SouthernLinc, SRT Wireless, Thumb Cellular, Union Wireless, United, Viaero Wireless, West Central Wireless, Leaco, Nemont/Sagebrush. T-Mobile is not liable for delayed or undelivered messages.
We take your privacy seriously. Please continue reading to review additional privacy policies.

Privacy Policy

ERB ("Company" or "We" or “us”) respects your privacy and We are committed to protecting it through our compliance with this policy. The Effective Date of this policy is February 7, 2022. We have updated this policy to reflect our privacy practices related to our websites, current assessments, products, services, and recent test preparation partnership. Previous policies can be found here.
This policy describes the types of information, including personal information, we may collect from you or that you may provide when you visit our websites, including from erblearn.org, erb.education, iseetest.org, admission.erblearn.org, iseeonline.erblearn.org, and others that may be created by ERB (our "websites"), as well as our practices for collecting, using, retaining, protecting and disclosing that personal information.
We also include information about your choices regarding our use of information; and accessing and correcting your information. We also include a notice for California residents and individuals located in the European Union. For purposes of this privacy policy, “personal information” means information that identifies you such as your name, email address, phone number, and school name. Please understand that ERB is based in the United States, and as a result all of the information collected from our websites is collected, used, processed, and stored within the United States.
ERB assessment data and other data from our products and services used by schools are collected, used, processed, and stored under agreements with ERB Member schools. We only use student information as authorized by the school for legitimate educational purposes. We may use anonymized or deidentified student information for educational research, assessment and product improvement but we cannot identify and do not allow any trusted third party to identify any individuals. For more information on how student information is collected, stored, and used, when We work with schools please contact legal@erblearn.org.
This policy applies to information:
  • We collect on these websites.
  • We collect from our assessments, products, surveys, and services
  • In e-mail, text and other electronic messages between you, ERB and these websites.
  • When you interact with our partners from our sites, including:
    • ERB Writing Practice: educators and parents can register for this writing program from the ERB Sites; however, note that your personal information is provided directly to Writing Practice, not ERB. Their privacy policy governs the use of your information.
    • ERB Pathways to Vocabulary with Word Voyage: schools and parents can purchase Word Voyage vocabulary tools from the ERB Sites; however, note that your personal information is provided directly to Word Voyage, not ERB. Their privacy policy governs the use of your information.
    • Pathways to Interpretation: teachers and administrators can use this tool to extract actionable insights from the CTP, WrAP, ISEE, and school exams. ERB has partnered with Certica Solutions to provide our members with TestWiz, an assessment solution that makes it easy to track student progress, deliver targeted teaching accordingly, and weigh instructional effectiveness. Their privacy policy governs the use of your information.
  • When you interact with our advertising and Pathways Partners on third-party websites and services, if those applications or advertising include links to this policy (as they may be governed by their own privacy policies)

Important Note Regarding Children Under the Age of 13

(COPPA Notice)

We are committed to protecting the privacy of children. To do this we have designed our websites so that only a parent or guardian may create an account, register for our assessments and make any purchases.  Our websites are not intended for children under 13 years of age.  If you are under 13, please do not use our websites or provide any information on our websites or through any of its features/register on the Websites, make any purchases through the websites, use any of the interactive or public comment features of this websites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 that was not provided by a parent or legal guardian, please contact us at legal@erblearn.org.

Information We Collect About You

We collect the following information from and about users of our websites. This information includes personal information (as defined above) and information that doesn’t identify you individually, such as website usage data.
  1. Account information: when a parent or legal guardian creates an account on our websites, they are required to provide the following information for account creation: name, postal address, e-mail address, telephone number (home phone number, or mobile phone number and/or work phone number). A parent or legal guardian may also provide information about their children that are students that they would like to register for an assessment. Only the parent or legal guardian can provide this information and the purpose is to register the student for a test. The information provided includes: first name, middle name, and last name, date of birth, gender, ethnic origin (U.S. students only and optional) and native English speaker (U.S. students only and optional).
  2. Assessment Registrations: When a parent or legal guardian registers their student for an assessment, they must provide the following information (in addition to the student information described above) so that ERB or its service provider can register them for the specific test: current grade, grade applying for and whether the student has attended public schools in the last two years (optional), current school, and selecting a test provider location. A parent or legal guardian also has the option of selecting a school(s) to send their student(s)’ test score and a fee waiver code if applicable.
  3. Test Preparation: you have the option to select test preparation for the ISEE assessment when registering your student, and we will collect information regarding the level of test preparation selected.
  4. Accommodations Requests: If you request accommodations for your student, the parent or legal guardian is required to complete the Accommodations Request Form available on the website and provide the following information: current school statement section with the current school administrator’s name; the student’s name, current school, type of accommodation requested and supporting documentation as further described on the form.
  5. Customer Service: If you contact ERB, we or our service providers may collect information to verify your or your student’s identity and we may also record conversations with you regarding your inquiry.
  6. Order Processing: If you register for an assessment or order a product or service on our website, we (or our service provider) will collect your name and financial information such as a credit card to process the order.
  7. Surveys: If you participate in a survey, we or our service provider will collect your name and email, responses and certain demographic information such as location, school size, school type, relevant to the survey and associated research reports.
  8. Marketing: if you opt in to receive marketing communications from ERB, we will collect your name, email address, your history regarding test registrations and products purchases to communicate with you regarding other tests, products and services that may be of interest to you.
  9. Sweepstakes and Contests: If you enter to participate in an ERB sweepstakes or contest, we will collect your full contact information including name, address, phone number, and email address, or attending an ERB-sponsored session at a participating conference or event, and providing full contact information including name, address, phone number, and email address. If you enter by mail-in entry, we will collect your name, address (including zip code), home and work telephone numbers (including area codes), and email.
  10. User Posts, Submissions and Feedback: You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the websites, or transmitted to other users of the websites or third parties (collectively, "User Contributions"). Your User Contributions are collected by ERB and could be collected by other, un-affiliated third parties that have access to the websites, and you understand that such User Contributions are posted and will be seen by other visitors to our websites.
  11. Video: If you register your student to take an assessment at a test center or online with our service provider, your student will be both monitored by video by a proctor when taking the test and the video will be recorded. Live proctor video monitoring is used at test centers and/or online to better ensure testing fairness and integrity by monitoring for testing irregularities, including cheating and proxy testers. ERB will only have access to the video recording if there is a testing irregularity requiring additional investigation, if there is a government order or if there is a legal action related to the test session. See our Terms for more information about our test incident/irregularity process.
  12. Facial Recognition: We through our service provider(s) during online exams collect facial recognition biometrics in the remote-proctoring platform; they are part of the security feature of the platform that helps verify throughout the exam that the individual who checked-in at the beginning of the exam is the same individual that is present throughout the entirety of the exam. When registering for the exam, we also provide notice about the use of facial recognition and obtain consent from the student’s parent or guardian.
  13. Member Student Surveys: We may periodically send surveys, such as the “Check-In” survey,  through our assessment delivery platform for our Member organizations that are provided to Members’ students; Responses from such students are collected from this platform and stored by ERB, and then aggregated and anonymized for reporting and research purposes. See below for more details about our aggregated and anonymized sharing of these survey results.
  14. From Member School Professionals:
  • Request More Information Form: a member school professional can request more information about becoming an ERB member and fill out our form. On this form, we collect the following information: school or organization name, contact name, email address, phone number, city, state country, how you heard about ERB, ERB Membership status, assessments, products and you can select from a drop-down menu the services you may be interested in receiving more information about.
  • Membership Application: an authorized member school professional can apply for membership for their organization by completing the ERB Membership Application where the following information is collected: contact information for Head of School or President, Superintendent, Principal or Headmaster, Director of Admission, Director of Curriculum or Test Coordinator and Billing and Purchasing. Any of the following: Name of 2 ERB Member Sponsors (you must have their consent to provide their contact information) or the Association of which your organization belongs or Name of Accrediting Agency of your organization.
  • Event Registration and Professional Development: to register for an ERB event, you must provide the following information: name, email address, phone number and school name.
  • ERB Shopping Cart: name, email address, phone number and school name.

Automatic Information We Collect

  • Artificial Intelligence (AI) Use for online proctored exams: ERB's service provider for online proctored exams uses Artificial Intelligence (AI) to detect test taker movement and keystroke activity outside the norm of candidate behavior during the exam. This includes head movement as well as gestures that indicate something out of the norm is occurring during the exam. AI also identifies "wrong face" if the face changes during the exam. Movement and activity that is outside of norms will be flagged to ERB and then ERB staff decides whether or not to take further steps to investigate the behavior. Any serious decisions about a student will be determined by ERB designated staff and not by the use of any AI on its own."
  • Browser lockdown software: if a student is taking an online proctored exam, our service provider may require the download and use of browser lockdown software to ensure that the student cannot access other sites and apps. This browser lockdown is only used by ERB’s service provider to deliver and administer the test to ensure testing fairness and integrity.  You and your student can delete the browser lockdown software once the testing session is finished as instructed by the service provider.
  • Website Usage and Site Activity: As you navigate through and interact with our websites, we use automatic data collection technologies such as session and permanent cookies, web beacons and similar technologies to collect certain information about your equipment, browsing actions and patterns, including:
    • Details of your visits to our websites, including traffic data, location data, log and other communication data and the resources that you access and use on the Websites.
    • Information about your computer and internet connection, including your IP address, operating system and browser type.
We may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).  The information we collect in this manner does not include information that can identify you personally, and is used to help us improve our Websites and to deliver a better and more personalized service, including by enabling us to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our websites according to your individual interests. Speed up your searches.
  • Recognize you when you return to our websites.
Website Analytics:  We use Google Analytics to help us measure traffic and usage trends for the websites and understand more about the demographics of our users. You can opt-out of Google Analytics by following the instructions for the Google Analytics Opt Out Browser Add-On here. You can also visit that page to learn more about Google’s privacy practices.
Social Networks: If you click on a social network button from our website, the social network provider will drop a cookie to allow you to connect and may direct targeted ads to you. These cookies are set by a range of social media services that we have added to the Sites to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

Cookie Policy

Third-party Use of Cookies and Other Tracking Technologies

ERB does not display any third-party ads on the websites. However, we work with service providers to deliver ads on other sites. Some content or applications, including advertisements, on the websites are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies and other tracking technologies to collect information about you when you use our websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Cookie Controls

Most web browsers provide controls that let you block or delete cookies. Generally, you can go to your browser’s Help section and see instructions for blocking or deleting cookies. However, certain features ERB uses on its websites depend on cookies. If you turn off your cookie settings you can still use our site, but your ability to use some features or areas of our site may be limited.

Targeted Advertising

For more information about targeted advertising and how you can opt out from some of it, visit the NAI Consumer Opt Out page or the Digital Advertising Alliance Your Ad Choices site. You can also manage certain advertising cookies by visiting the EU-based Your Online Choices and the Digital Advertising Alliance of Canada site. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt out of some, but not all, interest-based ads served by mobile ad networks by visiting Your Ad App Choices. Please note that opting out of receiving interest-based advertising through NAI's and DAA's online resources will only opt out a user from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on their other devices. You must opt out on each browser or device you use.

YouTube

ERB uses the YouTube service to display videos related to its products and services. YouTube uses tracking technologies, which may be present in the videos embedded on YouTube, which may collect information from your browser when you view the video, including device identifiers and/or cookie IDs. This information is collected directly and automatically by YouTube and its partners; however, ERB does not participate in these data transmissions. ERB does not provide personal information, such as usernames, to YouTube. You can learn more about Google's practices and control your settings on the service at Google Policies.

Legal Bases

For personal information subject to the European Union General Data Processing Regulations (“GDPR”), we rely on several legal bases to process the data. These legal bases include where:
  • The processing is necessary to perform our contractual obligations in our contracts with you (such as to provide a student an assessment or to provide a product or service to you);
  • You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
  • The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
  • The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Service, preventing fraud and cheating, and promoting safety and security as described below.
  • If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact legal@erblearn.org.

How We Use Your Information

ERB uses your information for the following purposes:
  • Account creation and administration
  • Assessment registration and delivery
  • Accommodation Reviews and Administration
  • Score Reporting
  • Customer Service
  • Surveys, Research and Reporting
  • Website Operations and Security
  • To Provide you with information, products or services that you request from us
  • To perform contracts, billing and collections
  • Marketing - To contact you about our own and third parties’ products and services that may be of interest to you if you have opted in to receive these communications from us.
  • Test Security – ERB (or its service providers) may use facial recognition technology, Artificial Intelligence, live proctors, video monitoring, and/or browser lockdowns to verify test takers identity, ensure fairness and testing integrity and detect abnormal testing irregularities during a testing session.
  • Legal Claims, Fraud Prevention and to Protect the rights, property or safety of us, parents, students, our members or others
  • Government Requests: To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Other Uses: In any other way we may describe when you provide the information to us and we have a legal basis to process the information

Aggregated and Deidentified Information

We may use information which has been de-identified and/or aggregated for product development, research, reporting, analytics and other purposes, including for the purpose of analyzing, improving, or marketing ERB assessments, surveys, products, and services.

Marketing

We do not sell your information to any direct marketing associations, third-party affiliates, or any other party. We may use your information to contact you about our own and third-parties' goods and services that may be of interest to you. You can withdraw your consent/unsubscribe from these communications at any time by contacting legal@erblearn.org or by clicking on the unsubscribe link in our emails.

Disclosure of Your Information

ERB is committed to the privacy of your information and only discloses personal information in limited circumstances with your consent, when we have a lawful basis to do so or as required by applicable law; and as more fully described below:
  • Service Providers: To vetted and trusted contractors and service providers that we use to support our business and provide our assessments, products and services to you and your student(s) and to our members; and who are bound by contractual obligations to keep personal information confidential and secure and use it only for the purposes for which we disclose it to them. Service providers include but are not limited to: Internet Testing Systems, Prometric LLC, Measurement Incorporated, Amazon Web Services, Computing Power from Amazon, Salesforce, Inc., Rackspace, and schools and organizations that are testing locations for ERB assessments.
  • To Pathways partners, currently Writing Practice, Word Voyage, and Test Wiz by Certica, to provide their products or services to you if you have requested their services through us. We contractually require these third parties to keep personal information confidential, secure and use it only for the purposes for which we disclose it to them.
  • Testing Locations: To schools and organizations that are test locations
  • Score Reporting: To schools you have designated to receive score reports
  • Test Preparation providers: we currently work with Test Innovators to provide ISEE test preparation and share your and your student personal information with them to allow them to contact you to create an account and provide test preparation services. If you have opted in, we also share information about your student and the ERB assessments, products and services they have taken/used.
  • Customer Service: we use a third party for responding to customer service inquiries.
  • Order Processing: We use a third-party payment service provider to process test registrations and other purchases. We do not collect, use, retain, or store, your financial information except to provide paid services to you that you request.
  • Surveys and Research: we use third parties to help us develop, administer and improve surveys and compile research and reporting related to survey responses and findings.
  • Facial Recognition: our services providers for online proctored exams use facial recognition technology to verify test taker identity. This information may be shared by our service provider with ERB and their subprocessor for contracted purposes, and with others if subject to a government order or legal action.
  • Video: our service providers that assist us with administering tests may use live proctors and record testing sessions at their test centers and during online assessments to detect notable testing irregularities that will be flagged for ERB to review and determine if further investigation is merited. This information may be shared by our service provider with ERB and with others if subject to a government order or legal action.
  • Artificial Intelligence (AI): our service providers may use AI/ML to detect notable testing irregularities that will be flagged for ERB to review and determine if further investigation is merited. This information may be shared by our service provider with ERB and with others if subject to a government order or legal action.
  • Fraud, Security or Technical Issues: we may disclose data to detect, prevent or otherwise address fraud, security or technical issues.
  • Social Media: we may disclose data to the respective social media provider if you click on the social media icons on our website. If you choose do so, your data is sent to them and you are subject to their privacy policies.
  • Government Requests: To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • Membership: To enforce or apply our Membership Terms and Conditions, and other agreements, including for billing and collection purposes.
  • Events: We may disclose information to event and conference coordinators to support your registration and conference experience.
  • Legal Claims: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ERB, our customers or others.

Aggregated and Deidentified Information

We may use information which has been de-identified and/or aggregated for product development, research, reporting, analytics and other purposes, including for the purpose of analyzing, improving, or marketing ERB assessments, surveys, products and services. In certain situations, ERB may share this information with service providers or affiliated third parties to improve our assessments, products, services or offerings. If we disclose information to affiliated third parties or service providers to conduct research or assist in understanding the usage, viewing, and demographic patterns for certain assessments, content, products, services, promotions, surveys and/or functionality on our site, such data will be aggregated and/or anonymized to reasonably avoid identification of a specific individual.  To assist us with these efforts, we may disclose aggregated information about our users, and information that does not identify any individual, to contracted third-parties.
For the “Check-In” survey, that is administered by ERB for its Members and their students, all responses from students will be collected and stored securely by ERB.  ERB will share only aggregated, anonymized survey results with the respective Member and Character Lab, the third party, non-profit educational organization that co-developed the survey questions and will work with Us on any improvements to the survey.

Change of Business

In the event that ERB is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale or transfer of some or all of our assets, your personal information may be transferred or disclosed in connection with such business transaction.

Choices About How We Use and Disclose Your Information

At ERB, we strive to provide you with choices regarding the personal information you provide to us.    We use personal information as needed for the purposes for which it was collected and we have a lawful basis or where you have consented to our use of your personal information. If you discover that personal information or other information pertaining to you or your student is inaccurate, incomplete, or out-of-date, please update your account information or contact us as provided below. Generally, we indicate when you have the option to provide personal information and you can decide if you want to provide that optional information.
Opt out/Unsubscribe for marketing:  If you opted in to receive marketing communications from us, you can opt out at any time by clicking on this link. You can also choose not to receive these emails by clicking the unsubscribe link in any e-mail.  Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages such as those regarding your account, account verification, assessment registrations, purchases, or updates to features of the website, or technical or security notices.

Accessing and Correcting Your Information

You can review your personal information by logging into the websites and visiting your account profile page.
You may also send us an e-mail at legal@erblearn.org to request access to, correct or delete personal information that you have provided to us subject to applicable limitations. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect or where we have a legitimate business purpose for retaining the information.
We may not be able to delete information in all instances, such as information retained in technical support logs and other business records. We will not be required to delete any information which has been aggregated, de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual.

Retention

Unless we receive a deletion request, we will retain your information for as long as your account is active or as is reasonably necessary for our operational purposes. For example, we may retain certain data as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. We may also retain information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.
Generally, we will retain any recorded video from a testing session for 30 days (or as required by applicable law) unless We have legitimate business purpose for retaining the video for a longer period.
For facial recognition biometrics, ERB and its service provider will retain facial recognition data, for the period for which it is needed for test security and identify verification, which is currently 30 days. Facial recognition data will be retained longer in the event of a test related investigation, legal action or valid government requests but it will not be retained longer than 3 years since the student’s last interaction with ERB. ERB will not disclose facial recognition data without your consent except to our service provider administering the online proctored exam, and if ERB is required by law or We receive a valid warrant or subpoena instructing us to retain and disclose the facial recognition data. Our service provider uses reasonable procedures to securely store any facial recognition data.
We generally retain test scores for 10 years.
If you delete your User Contributions from the websites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other websites users.

California Privacy Rights

California Civil Code Section § 1798.83 (“Shine the Light” Law) permits users of our websites that are California residents to opt out of ERB’s disclosure of personal information to third parties for marketing purposes at any time. ERB will not disclose your personal information to third parties for marketing without giving you notice and getting your consent. Please note—this opt-out doesn’t prohibit disclosures for nonmarketing purposes. You can opt out for free by contacting us at: legal@erblearn.org.
Please note that ERB is not subject to the California Consumer Privacy Act (CCPA) as it is nonprofit organization. However, please rest assured that ERB does not sell your personal information and we strive to provide clear notices of our privacy practices at the time of collection.

Rights of Data Subjects in Europe

As a Data Subject as defined by the GDPR, you have the right to obtain confirmation as to whether or not your personal data (as defined in the GDPR) is being processed, and, if it is, to access that personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; and where possible, the period for which the personal data will be retained, or, if not possible, the criteria used to determine that period;
You also have:
  • the right to request rectification of personal data
  • the right to request erasure of personal data when:
  • the right to restriction of processing of personal data, or to object to such processing, when;
  • the right to data portability, which is the ability to receive your personal data in a structured, commonly used and machine-readable format and have you the right to transmit those data to another controller without hindrance from us (or have us transmit that data with your permission).
  • the right to make a complaint to the relevant Supervisory Authority.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law and our lawful bases for processing the personal data. In some instances, our ability to grant these rights to you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested or where we have a lawful purpose for processing. Where this is the case, we will inform you of specific details in response to your request.

Marketing

As described above in this privacy policy, you have the right to withdraw your consent to marketing at any time.

Onward Data Transfers

Personal Information and information of students located outside of the United States will be transferred to ERB, our third-party service providers, the testing location and only member schools your student is applying to in the United States and elsewhere in the world only to facilitate the purpose for which it was collected. ERB, our service providers and our member schools are currently based in the United States. By using this Site and sending information to us, our service provider or member school electronically, you understand and acknowledge the transborder and international transmission of any Personal Information that you may choose to provide to us to any country in the world, including countries without an adequate level of data protection. We request your consent to this data transfer when you register your student for an exam.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology or the then current industry standard encryption.
Where we have given you (or where you have chosen) a password for access to certain parts of our websites, you are responsible for keeping this password confidential. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the websites home page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Websites home page. The effective date the privacy policy was last revised is identified at the top of the policy. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our websites and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:
Legal Counsel’s Office
105 East 34th Street, Suite 146
New York, NY 10016
legal@erblearn.org

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Please note that 360 Access will be unavailable due to scheduled maintenance on Monday, April 1, from 2 p.m. until 10 p.m. ET.