“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)
- Company or school name and address
- Credit and debit card number
- Medical condition (e.g. allergies or illness)
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 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?
- 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:
- For statistical purposes, calculating usage levels, and helping diagnose server 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 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 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 the school in your destination country that provides some of the services that you have ordered, or one of the principal companies that is offering another of EF’s program.
- Business partners are for example local sales agents that promote the sales of our services in your country of residence; transportation or accommodation providers in your destination country; or course leaders, activity leaders or other contractors for management of any of our programs; or a travel insurance company that prepares the travel insurance for you.
- 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.
- 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.
To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”.
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.