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 (collectively “ EF Digital Products”) or through other channels online and offline as further described below. If you do not agree with any of the terms of this Privacy Policy, please do not use EF Digital Products or submit any Personal Data to EF. However, 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.EF processes your Personal Data in compliance with applicable privacy and data protection legislation.

“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 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)

- Company or school name and address

- Credit and debit card numberMedical condition (e.g. allergies or illness)

How do we collect Personal Data?

We may collect Personal Data in a variety of ways:

Directly from you: Information may be 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 may collect Personal Data from you offline, for example when you contact customer service, enroll in a product or service or provide information to us in writing.

Online: We may collect your Personal Data through EF EFEKTA English for Adults Digital Products, for example when you sign up for a newsletter or a brochure, enroll in a product or service.

We may 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 allow you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/.

- Through your use of a mobile application. When you download and use a mobile application, we may track and collect mobile application usage data, such as the date and time the mobile application on your device accesses 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 may collect the physical location of it to provide you with personalized location-based services and content.

- From our corporate affiliates, business partners, assistance providers or claim handlers. Our corporate affiliates, business partners, assistance providers or claims handlers may provide us with Personal Data in conjunction with your program.

- From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your EF EFEKTA English for Adults Digital Products account, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your profile.

We may also collect certain non-personally identifiable information about your use of our services through your browser, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the EF EFEKTA English for Adults Digital Products you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit EF EFEKTA English for Adults Digital Products, along with the time of the visit and the page(s) that were visited. These data are not related to any identified or identifiable person unless you have submitted personal information to EF EFEKTA English for Adults and in connection with that have accepted this Privacy Policy.

How do we use Personal Data?

Your Personal Data will be processed by EF EFEKTA English for Adults 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. EF EFEKTA English for Adults may also use your Personal Data, combined with information about you obtained from third party sources, to market our products and services, including special promotions based on your interests.

We may also use Personal Data:

- For statistical purposes, calculating usage levels, and helping diagnose server problems as well as to ensure that EF EFEKTA English for Adults Digital Products function properly.

- To allow you to contact and be contacted by other users through the EF Digital 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.

- To analyze and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the EF Digital Products experience and content based on your past activities on EF EFEKTA English for Adults Digital Products.

- To provide you with personalized location-based services and content through the use of your device’s physical location.

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 China.

We may 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; (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

If you have taken part of a language test, such as EFSET, or a language course, we may share some of your Personal Data (date of birth, nationality and your Member ID) together with your test or learning results with our affiliates and University of Cambridge and Harvard University for research, statistical and audit purposes. Below follows more information about consent to such testing and learning services:

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 China.

We may 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; (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.

If you have taken part of a language test, such as EFSET, or a language course, we may share some of your Personal Data (date of birth, nationality and your Member ID) together with your test or learning results with our affiliates and University of Cambridge and Harvard University for research, statistical and audit purposes. Below follows more information about consent to such testing and learning services:

Informed Consent from EF students for Research at the Department of Theoretical and Applied Linguistics at the University of Cambridge

The EF EFEKTA English for Adults Education First Research Lab for Applied Language Learning (formerly the Education First Research Unit) at the Department of Theoretical and Applied Linguistics at the University of Cambridge (“DTAL at Cambridge”) was launched in February 2010 to advance research in the second language learning and teaching of the English language.

The EF EFEKTA English for Adults Education First Research Lab for Applied Language Learning is sponsored by EF Education First. As part of EF EFEKTA English for Adults Education First’s investment in research, EF Education First has partnered with the DTAL at Cambridge and has agreed to gather the written and spoken examination scripts/course assignments of learners of English to help the DTAL at Cambridge create a rich database for language research studies, known as the EF EFEKTA English for Adults Cambridge Open Language Database (“EFCAMDAT”). All examination scripts/course assignments entered in the EFCAMDAT contain the Personal Data of EF EFEKTA English for Adults students. The EFCAMDAT database is available to researchers worldwide investigating the learning of English as a foreign language.

When you register to use any of the EF EFEKTA English for Adults testing or learning services, EF collects information about you, including your Personal Data, and your examination scripts/assignments. To assist the DTAL at Cambridge in its research, by enrolling in an EF EFEKTA English for Adults testing or learning service, you or, if applicable, your parent or legal guardian on your behalf as agreed with EF EFEKTA English for Adults, hereby agree and give consent to EF to reproduce and transfer to the DTAL at Cambridge and enter into the EFCAMDAT database any material/information that you author or create during EF EFEKTA English for Adults testing and learning services courses or activities such as your examination scripts/course assignments (written and/or spoken) and any EF teacher markings and/or corrections. This includes use by the DTAL at Cambridge of your materials in their original and transcribed form in all media and for their full term of copyright. For this purpose, the following Personal Data will be transferred by EF EFEKTA English for Adults to the DTAL at Cambridge:

1. Your Unique Identification Number (Member ID). This does not include your name and contact details. Your Member ID will be used only to confirm your enrolment and agreement to the EF testing and learning service ‘Terms and Conditions of Use’ and ‘Privacy and Security Policy’. Your Member ID shall be removed prior to entry of your examination scripts/course assignments in the DTAL at Cambridge EFCAMDAT database

2. .Your date of birth (only to establish the age group you are in)

3. Your nationality

4. Your examination scripts/course assignments, the level/unit/exercise, and any EF teacher markings and corrections.

The personal information noted above will only be accessed by authorised personnel involved in the research project at the DTAL at Cambridge. The information will be retained by the University of Cambridge, shall be securely stored and will only be used for the purpose of research, statistical and audit purposes. The information will be processed by the University of Cambridge in accordance with the provisions of the UK Data Protection Act 1998. All examination scripts/course assignments entered in the EFCAMDAT database shall not contain Personal Data or contact details traceable to its authors.

The 'Data Controller' for the processing of data received by the DTAL EF EFEKTA English for Adults Research Unit is the University of Cambridge, University Data Protection Officer, The Old Schools, Trinity Lane, Cambridge, UK CB2 1TN, tel. +44 1223 332320, fax +44 1223 332332, email: [email protected] queries you may have about the EF Research Unit programme of research at the DTAL at Cambridge and its use of your EF EFEKTA English for Adults testing and learning services assignments and Personal Data should be addressed in the first instance to:

Department of Theoretical and Applied Linguistics (DTAL)

EF EFEKTA English for Adults Education First Research Lab for Applied Language Learning

University of Cambridge9 West Road

Cambridge, United Kingdom

CB3 9DA

tel. +44 1223 767384

Dr Dora Alexopoulou, Principal Research Associate, DTAL–

email: [email protected]

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 unauthorized 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 endeavor to comply with your request(s) as soon as reasonably practicable and in no event later than 30 days after we received your request.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which EF EFEKTA English for Adults Digital Products contain a link. The inclusion of a link on EF EFEKTA English for Adults Digital 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 EFEKTA English for Adults Digital 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 the 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 defense of legal claims or unless a specific time period has been communicated.
We will keep your Personal Data for marketing purposes until you withdraw your consent.

If you are under the age of 18, you should review the terms of this Privacy Policy with your parent or guardian to make sure you both understand them. Although we are not responsible for determining the age of our users, we may carry out verification checks. If we learn that we have collected Personal Data from an individual under the age of 16 without parental or legal guardians’ consent, we will delete that data as soon as possible and may disable that individual’s access to EF EFEKTA English for Adults Digital Products or take any other appropriate actions as we deem necessary.

We do not generally seek to collect any sensitive Personal Data (such as 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 (e.g. in order to provide you with the services and products you have ordered and in relation to your insurance). We will make sure that we receive your explicit consent to such processing and treat this information securely.

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, if the changes are significant, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.

You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes or otherwise by contacting us as set out below or click.

If we are unable to satisfactorily resolve your concerns about our handling of your Personal Data, you can contact the supervisory authority in the country where you live.