Our Commitment to Your Privacy
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.
“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:
* Name and contact details (e.g. postal and email address, telephone number)
* Account information (e.g. user name, profile picture or social media account ID)
* Country of residence
* Birth date
* 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
* Preferences (e.g. shopping habits, preferred educational courses)
* Study data
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.
** Online: We collect your Personal Data through the EF Products, for example when you sign up for a newsletter or a brochure, enrol in a product or service. We also collect Personal Data:
*** 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.
*** 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?”
* From our corporate affiliates, business partners, assistance providers or claim handlers. We may receive Personal Data from other parties in conjunction with your course/program, including:
** 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 provide you the services you have signed up for, or a teacher that provides some of the services.
* If you browse our sites
How do we use Personal Data?
* Your Personal Data will be processed by EF LLS for the purposes of providing you with the products and services that you have ordered, 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:
** For statistical purposes, calculating usage levels, and helping diagnose server or application problems with the EF Products 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 allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.
** If you have given your consent:
*** 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 the app store, 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. All such email communication will include a clear unsubscribe link.
How do we share Personal Data?
* We may share your Personal Data with our corporate affiliates, business partners and service providers both within and outside the EEA/Switzerland:
** Our corporate affiliates are for example a local EF company that promotes the sales of our services and offers customer service in your country of residence, or one of the principal companies that is offering another of EF’s program.
** Service providers, such as providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics.
* The EF Hello mobile application is using a crash reporting tool, Instabug, to send us information about bugs and crashes that users experience. The application automatically collects certain information that does not personally identify users of it. This information includes, but is not limited to, information on the device such as device ID, device mode, time of failure and the physical location of a device at the time of a crash.
* We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, including the standard data protection clauses adopted by the European Commission, available at
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection clauses in place, please see the contact section below.
* 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.
On what do we base our right to collect and use Personal Data?
We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services or products that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your personal data, such as for the marketing of products or services similar to the one(s) you have already purchased from that same legal entity.
Please note that we ask you not to disclose any sensitive personal information on or through the site or otherwise to us. To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as marketing of products and services provided by an EF affiliate, we base this on your specific consent.
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 contacting us at firstname.lastname@example.org. 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.
THIRD PARTY SITES
HOW LONG DO WE STORE PERSONAL DATA?
We will only keep your Personal Data for fifteen (15) years after the expiry of your account, in order to be able to provide you the possibility to re-activate your account, should you decide to purchase additional courses from us; or otherwise 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 15 years after your last completed service or delivery of product.
IF YOU ARE UNDER THE AGE OF 16
To use EF Products, you must be at least 16 years old. We are not responsible for checking your age but sometimes we still do verification checks. 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 will delete the information as soon as possible and you will not be able to use EF Products.
We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and products you have ordered). We will make sure that we receive your explicit consent to such processing and treat this information securely.
• Access to Specific Information and Data Portability Rights. California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verified consumer request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing any sales (identifying the personal information categories that each category of recipient purchased) and disclosures for a business purpose (identifying the personal information categories that each category of recipient obtained).
• Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verified consumer request, we will delete (and direct any service providers to delete) your personal information from our records unless an exception applies, which may include but is not limited to information needed: (i) to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) enable solely internal uses that are reasonable aligned with consumer expectations based on your relationship with us; (iv) comply with a legal obligation; and (v) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights above, please submit a verifiable consumer request to us by emailing us at email@example.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verified consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us properly to understand, evaluate, and respond to it. We cannot response to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make a request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without issue. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.
You have a right to contact us and without cost find out which information about you that is being used. You have a right to receive your personal data in a machine readable format and you have a right to transfer your personal data to another data controller.
You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your personal data is restricted or that we shall delete your personal data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct personal data about you that is incorrect, incomplete or misleading.
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 us at the address EF Language Learning Solutions Ltd., Haldenstrasse 4, 6006 Lucerne, Switzerland or firstname.lastname@example.org.
If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.