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Privacy Notice – EF host families and independent contractors


Our Commitment to Your Privacy

EF Education First (“EF”) is committed to protecting the privacy of our potential and existing business partners, including EF host families. 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.

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to enter into a contract with you or provide you with the information 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 part of EF you 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

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

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 EF for service (e.g. service during your host family assignment), apply to become a host family or supplier, enter into a contract with us, or provide information to us in writing.
  • Online: We collect your Personal Data for example when you sign up for a newsletter, apply to become a host family or supplier, enter into a contract with us, or contact EF for service (e.g. service during your host family assignment). 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. To learn more about cookies, please visit http://www.allaboutcookies.org/. 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.
    • 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. We may receive Personal Data from other parties in conjunction with your contract with us or business relationship with us, including from our corporate affiliates, such as EF affiliate companies, or the Swiss principal company that is located in Switzerland that is responsible for the performance of the contract with our students.
  • From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Facebook, Instagram, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; 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 website account, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.
  • If you browse our sites
    We may also collect information about your use of our services through your browser to trace activity on our sites, 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 and service provider. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit an EF website, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so. You can read more about collection of your IP address and other browsing data in our cookie policy.

How do we use Personal Data?

  • Your Personal Data will be processed by EF for the purposes of performing the contract with you, for host family customer service, administrative services or otherwise necessary as further described in this Privacy Policy.
  • We may also use Personal Data:
    • For statistical purposes, calculating usage levels, and helping diagnose server problems with the EF websites as well as to ensure that the EF websites function properly.
    • To allow you to contact or be contacted by other EF corporate affiliates as necessary to perform the contract with you.
    • 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 experience and content based on your past activities on EF website or in your contacts with EF. For example, depending on what you have searched for on our website, or in previous browsing, the offer presented to you may be limited to a specific language, location and time of year.
      • 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 inform about opportunities to collaborate with EF, including hosting students or providing other services. This can be done through email marketing solutions that maintain mailing lists and schedules and modified 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 EF’s services and offers customer service in our students’ country of residence, or the Swiss principal company that is located in Switzerland that is responsible for the performance of the contract with our students.
    • Business partners are for example local sales agents that promote the sales of EF’s services in our students’ country of residence; transportation or accommodation providers; or course leaders, activity leaders or other contractors for management of any of our host family programs.
    • Service providers, such as providers of IT systems, for example for managing supplier relations or payments, providers of software and services for digital marketing automation and analytics or transportation and accommodation suppliers.
  • 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 Us” section below.
  • We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with a legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence (d) as required by academic accreditation bodies in relation to EF’s schools, such as Eaquals or (i) the British Council and the UK Independent School Inspectorate if you reside in the United Kingdom, (ii) Acels if you reside in Ireland, (iii) Label Qualité Français Langue Etrangère if you reside in France, (iv) Fachverband für Deutsch als Fremdsprache and TELC (the European Language Certificates) if you reside in Germany, (v) CILS and CELI if you reside in Italy, (vi) FELTOM and Malta Standards Authority if you reside in Malta, or (vii) Cervantes, ASELE and SIELE if you reside in Spain; (e) to enforce the terms and conditions of our contract; (f) to protect our operations or those of any of our affiliates; (g) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (h) 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 ground of performance of a contract between us in order to perform the agreed service, or when there is a legitimate interest for us to use your Personal Data, such as for the marketing of opportunities to perform services to us similar to the one(s) you have already performed or showed interest in 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 the “Sensitive Data” section below.

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 opportunities, products and services provided by an EF affiliate, we base this on your specific consent.

SECURITY

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.

UNSUBSCRIBE

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.

THIRD PARTY SITES

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 the EF websites contain a link. The inclusion of a link on EF’s websites 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 websites 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.

HOW LONG DO WE STORE PERSONAL DATA?

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 engagement with us.

SENSITIVE DATA

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 carry out a background check of you to assess if you are eligible to become an EF host family or supplier to EF). We will make sure that we receive your explicit consent to any processing of sensitive data and will treat this information securely.

UPDATES TO THIS PRIVACY POLICY

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.

YOUR RIGHTS

You have a right to contact us at any time to find out which information about you that is being used (once per year free of charge). You have a right to receive your Personal Data in a machine readable format and you have a right to transfer your personal to another data controller.

You have the right to, at any time, withdraw any consent you have provided to us or object to us using your Personal Data, e.g. 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 perform the contract with you, provide you with information, services or offers as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.

CONTACT US

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 Schools Ltd
Hill House, 1 Little New Street, London, EC4A 3TR, United Kingdom. or click here

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.

DATA CONTROLLER

Your country of residence Data Controller Address
United Kingdom EF Language Schools Ltd Hill House, 1 Little New Street, London, EC4A 3TR, United Kingdom
Spain EF Servicios de Soporte SA Calle Balmes 155-157, 08008 Barcelona, Spain
Germany EF Privates Sprachinstitut GmbH Sternstrasse 5, 80538 Munich, Deutschland
Italy Ef Centro Linguistico srl Via del Teatro Valle, 20, 00186 Roma RM, Italia
Ireland EF Education First Ltd Haldenstrasse 4, 6006 Lucerne, Switzerland
Malta EF Language Travel Limited The Mayfair Complex, St. George´s Bay, St. Julians STJ 3311, Malta