Privacy Policy

EF Education First (“EF”),is committed to protecting the privacy of our potential and existing customers. The EF privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “EF Products”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

The EF company that is the controller for the processing of your Personal Data as set out in this Privacy Policy can be found here and will depend on which EF product(s) you are interested in or have engaged with. Being the controller means that this company is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.

“Personal Data”is information or pieces of information that could allow you to be identified. We may collect, store and use the following information about you:

• Name and contact details (e.g. postal and email address, telephone number
• Account information or user ID (e.g. user name, profile picture or social media account ID
• Country of residence or citizenship
• Birth date
• Gender
• Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data, page views and website navigation
• Preferences (e.g. language, preferred educational courses)
• Company or school name and address, teacher name and email, occupation, academic record, language proficiency
• Credit and debit card number, payment data or bank account details
• Medical condition (e.g. allergies or illness), dietary needs, smoking habits, immunization
• Travel details, passport copy, visa information
• Insurance data
• Name and contact details of family members
• Other information you provide during a phone-or video call or a chat, and recordings and/or transcripts of such calls or chats.
• Photos or video recordings of you
• Study progress and attendance scores

How do we collect Personal Data?

We collect Personal Data in a variety of ways:

• Directly from you: Information is collected directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:
• Offline: We collect Personal Data from you offline, for example when you contact customer service, enrol in a product or service or provide information to us in writing, or during a phone or video call.
• Online: We collect your Personal Data through the EF Products, for example when you sign up for a newsletter or a brochure, use our chatbot, enrol in a product or service. We also collect Personal Data:
• Through cookies.Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.
• Through your use of a mobile application.When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number as well as statistics on malfunctions and crashes that the users experience.
• Through your device. . Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”

• Our corporate affiliates, such as the local EF company that promotes the sales of our services and offers customer service in your country of residence and provides us with the Personal Data that is needed to come to an agreement with you on your order, or the school in your country of destination that provides some of the services that you have ordered, or the Swiss principal company that is located in Switzerland and is responsible for the performance of the contract with you for any of EF’s offers.
• Business partners, such as local sales agents that promote the sales of our services in your country of residence.
• Claims handlers who receive information about your insurance claims in case of an insurance situation.

How do we use Personal Data?

We will use your Personal Data for the following purposes:

• Your Personal Data will be processed by EF for the purposes of completing your booking, providing you with the products and services that you have ordered (including travel insurance coverage), for customer service, administrative services or as otherwise necessary to perform the contract between you and us or as further described in this policy.
• We may also use Personal Data:
• To establish the appropriate language level, analyse your skills and suggest improvements
• For statistical purposes, system maintenance, backup, calculating usage levels, and helping diagnose server problems with the EF Products, for business development as well as to ensure that the EF Products function properly.
• To allow you to contact and be contacted by other users through the EF Products, as permitted by the applicable product.
• To provide customer service or send service related information, via various channels such as SMS, messenger services like WhatsApp, Facebook Messenger, chat bots or email.
• To allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.
• Where relevant, to establish, exercise or defend legal claims, or for debt collection.
• To detect, investigate or prevent information security incidents, fraud, misrepresentation, security incidents or crime;
• To meet applicable legal, regulatory and compliance requirements, including but not limited to sanctions laws.
• To enable you to report a concern through our whistleblower channels.
• If you have signed a photo release form: photos or video recordings of you may be used in marketing material to promote EF’s products.
• To train our sales staff and to protect our staff from threats during phone- or video calls
• If you have given your consent to processing for marketing purposes:
• To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the EF Products experience and content based on your past activities on the EF Products. For example, depending on what EF Product you have searched for on our website, or in previous browsing, the offer presented to you on the EF Products may be limited to a specific language, course length or budget.
• To provide you with personalized location-based services and content through the use of your device’s physical location. For example, you will be redirected to the local EF website in your language if your device indicates that you are browsing from that country, or you may be suggested the nearest EF office to your location for visits or information.
• To market our products and services, including special promotions based on your interests, for example through email marketing solutions such as Salesforce Marketing Cloud’s management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward, or through other channels such as SMS, other instant messenger services or chat bots, telephone calls with operator (so-called telemarketing) or traditional mail. All such communication will include a clear unsubscribe link or offer another opt-out function.
• For the transmission and communication to third-party companies or other EF companies for their marketing purposes, including direct marketing activities and telemarketing.
• We may offer a possibility to pay for the EF Products via payment solutions, including but not limited to, Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm (“Klarna”). In order to offer you Klarna’s payment methods, we might share your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

How do we share Personal Data?

• We share your Personal Data as described below and in this Privacy Policy, and as permitted by applicable law:

• Corporate affiliates

  Our corporate affiliates include, for example, a local EF company that promotes the sales of our services and offers customer service in your country of residence, or the school in your destination country that provides some of the services that you have ordered, or EF companies that provide internal service functions such as IT, legal or other shared services. If we have obtained your consent, we may also share your Personal Data with our EF corporate affiliates for their own marketing purposes. A list of those affiliates can be found here, as well as International Care Ltd, Selnaustrasse 30, 8001 Zürich

• Third party service providers

  We share Personal Data with third parties in connection with the delivery of services to you and the operation of our business. For example, we may share Personal Data to providers of IT systems in order to manage customer relations, process credit cards or other payment solutions, schedule classes or store learning results; or to providers of software and services for digital marketing automation and analytics; to advertising platforms in order to serve you with advertising tailored to your interests; to other third parties to provide customer service, business analytics, fraud prevention and compliance services and to visa processing agencies. If you have not paid your bills to us in time, we may transfer some of your data to a debt collection provider, Intrum. This includes your name, your date of birth and your contact details and, if applicable, your debt collection number. Intrum is an international company with many group companies and operations in different countries. The Intrum company that would process your personal data is responsible for protecting your data as a data controller. Information about processing activities can be found in the respective language on the Intrum website in the respective country on the Internet.

  Personal Data collected under a photo release form may be shared with the photographer/production company.

  Where we offer the use of a chatbot on the EF Products through the latest AI technology, the questions that you ask the chatbot will be transferred to and temporarily stored by the AI technology provider, but will not be used to train or improve their AI models. No personal data will be transferred, unless you include personal data in your questions. You can read more here: https://openai.com/policies/api-data-usage-policie

• Travel suppliers

  We share Personal Data with travel related suppliers, including hotels, airlines, bus or train service providers, as well as course leaders, activity leaders or other contractors in connection with the management of our programs; or a travel insurance company that prepares the travel insurance for you. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.

• Business partners

  We may share your Personal Data with business partners. This may happen, for example, when we promote a program or offer a service or product in conjunction with a third-party business partner or when we use local sales agents to promote our services in your country of residence. In most cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice.

• Other third parties

  If you log in to an EF product/service by using a single sign-on through a third party app or platform, you will share certain information with that social media platform, such as the fact that you have visited or interacted with us.

• Corporate transactions

  In the event that our business is directly or indirectly sold or combined with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and may be transferred to the new owners of the business.

• Legal rights and obligations

  We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

International Data Transfers

EF has business activities in several different countries, and your Personal Data may be shared with affiliates of EF or other recipients as described above that have a need to receive such data for the purpose of performing the services you have requested, or according to this policy. Such recipients may be located outside your own country, including countries that do not ensure the same level of protection as the country where you are domiciled, including to the destination country of your program (please see all destinations on our website here on www.ef.com/pg/) or to any of EF’s service providers located in USA, within EU or in India. Unless the European Commission or the equivalent authority in your home country has decided that a country ensures an adequate level of protection for personal data, EF will use contracts based on the European Commission’s or the relevant local authority’s standard data protection clauses for international transfers of personal data to ensure compliance with applicable law. You have a right to ask us for a copy of the standard data protection clauses (by contacting us as set out in the Contact Us section below).

On what do we base our right to collect and use Personal Data?

We have documented the lawful bases for our processing activities in Annex 1.

On some occasions, we process your Personal Data on the basis of your consent (for example, when you agree that we may set cookies other than those that are strictly necessary). To the extent we use sensitive Personal Data, we base this on your explicit consent, unless the processing is otherwise permitted under applicable data protection laws. Sensitive data can for example be information about health, ethnicity or religious beliefs - read more under “Sensitive data”. Where we process data based on consent, your consent is revocable at any time.

The processing of some of your Personal Data is necessary in order to provide services to you pursuant to the agreement that you enter into with us. Without this information, we would not be able to provide certain services to you.

On other occasions, we process your data when we are required by law (for example, if we are required by court order or any applicable law to process data).

We also process your Personal Data when it is in our, or a third party’s, legitimate interests to do so, provided that your data protection rights do not override these interests. This may be to market products or services similar to the one(s) you have already purchased from that same legal entity. Where we are not relying on consent, legal requirements or contractual necessity, we process your Personal Data based on legitimate interests as described in this Policy.

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties to which you directly provide Personal Data, including any third party operating any site to which the EF Product contain a link. The inclusion of a link on EF Products does not imply endorsement of the linked site by us or by our affiliates.

Additionally, we may provide you with access to third-party functionality that permits you to share your activities on EF Products to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.

We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.

If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both understand them. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we may need to delete the information as soon as possible and you will not be able to use EF Products.

We may need to collect sensitive personal data (such as information about health, religious beliefs or sexual orientation) in order to administrate the travel, accommodation placement, insurance coverage and to safeguard your wellbeing throughout the course.

Participation in our courses and travel requires students to be in good physical and mental health. Therefore, we may require you to disclose all serious pre-existing medical conditions and current medications prior to departure. We may also request proof of vaccination and doctors’ certificates. You must also continuously notify us any new developments in your physical or mental health until departure.

If you become ill or incapacitated during the course, we may take any action we deem necessary for your safety and well-being, including securing medical treatment and transporting you home. If that happens, EF may contact the your emergency contact(s) with regard to the health issues that have occurred.

We will store and share any sensitive personal data that we collect about you in an encrypted environment and will only provide access to those who have a need to know the information. The data will be kept only for as long as necessary to achieve the purposes it was collected for, or for longer if required to meet local statutory limitation periods for bringing legal claims. We will make sure that we receive your explicit consent to such processing, unless an exception applies under the applicable data protection laws.

Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.

We respect your rights to access and control your information and will respond to requests in accordance with applicable privacy and data protection legislation. We may ask you to verify your identity and to provide other details to help us to respond to your request.

Depending on the lawful basis for processing upon which we rely, you have a right to:

1. request access to your Personal Data;
2. request that we correct or complete Personal Data that is inaccurate or incomplete;
3. request that we erase your Personal Data, which we will do where required by applicable privacy and data protection legislation;
4. restrict our processing of your Personal Data, in certain circumstances;
5. request that we provide you with copies of your Personal Data in a machine-readable format or transfer it across different services;
6. object to certain types of processing, including where we process your Personal Data on the basis of our legitimate interests and for direct marketing purposes; and
7. where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations under applicable privacy and data protection legislation – for example, where we can demonstrate that we are under a legal obligation or have other legitimate grounds to process your data.

If you wish to exercise these rights, please contact us using the contact details below. We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.

If you have given your consent to marketing, EF may collect Personal Data for the purpose of profiling in order to serve promotional information tailored to your interests, for example to analyse or predict aspects concerning that your economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. This type of profiling does not produce legal effects on you.

We may also use a machine learning powered tool to record your language during the lessons, in order to analyse your skills and suggest improvements. This type of processing does not produce any legal effects on you.

We may also record and analyse sales calls with you with help of machine learning technology, for the purpose of quality control and to improve the sales performance, as well as to train our language models. Information from such calls, for example tone and key words are also combined with other personal data we have collected in connection with our communications with you, such as meeting attendance, and meeting notes. This type of processing does not produce any legal effects on you.

If you would like to have a copy of the information EF holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact one of our locations or click here.

If you have complaints about our handling of your Personal Data, please first contact our contact our DPO by clicking here