“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
- 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. shopping habits, 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, immunizations
- Travel details, passport copy, visa information
- Insurance data
- Name and contact details of family members
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 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?”
- 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?
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:
- 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;
- To detect, investigate or prevent information security incidents, fraud, misrepresentation, security incidents or crime;
- To meet applicable legal, regulatory and compliance requirements
- 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, 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?
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; and to other third parties to provide customer service, business analytics, and fraud prevention and compliance services to serve you with advertising tailored to your interests [and to visa processing agencies.
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 any 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.
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 the sales of our services in your country of residence. In most of those 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.
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 outside the EEA/Switzerland that do not ensure the same level of protection as the country where you are domiciled. Unless the European Commission has decided that a country ensures an adequate level of protection for personal data, EF will use contracts based on the European Commission’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. 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.