“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. ID, email address, phone 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)

• Occupation

• Company or school name

• Video recordings of classes you’ve attended.

• Study results

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 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 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 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 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.

• 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, service provider, and the name and version of the EF EFEKTA English for Adults Product 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 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 providing you with the products, information, 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:

• To establish the appropriate language level, analyze your skills and suggest improvements.

• For statistical purposes, calculating usage levels, and helping diagnose server problems as well as to ensure that EF EFEKTA English for Adults 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 phone calls, video calls, SMS, messenger services, chat bots or emails.

• To demonstrate an EF EFEKTA English for Adults’ live class (face to face in centers or through online) to potential customers.

• 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.

• 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 EF EFEKTA English for Adults Products.

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

• 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 or offer another opt-out function.

• To help the teacher, the customer success team or the teacher may take notes about your personal information in order to prepare for future classes and improve the learning experience.

• To analyse our interactions to improve our sales process and quality control.

How do we share Personal Data?

We may share your Personal Data as described below and in this Privacy Policy, and as permitted by applicable law:

• Corporate affiliates

• 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, providers of IT systems in order to manage customer relations; providers of software and services for digital marketing automation and analytics; advertising platforms; for customer service, business analytics, and fraud prevention and compliance services; to serve you with advertising tailored to your interests.

The EF English Live mobile application is using a crash reporting tool, Crashlytics, a business division of Google Inc., 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.

Our teachers may take notes about you and your classroom performance for reference when preparing future classes. These notes may also be shared with your future teachers.

• Corporate affiliates & Business partners

We may share your Personal Data with business partners, for example if we are promoting a program or offer a service or product in conjunction with a third-party business partner or when we use local sales agents that 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.

• Corporate transactions

In the event that our business is sold or integrated with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and will be passed 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 EFEKTA English for Adults 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/UK that do not ensure the same level of protection as the country where you are domiciled, including USA and India.

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.

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]. Any 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]

How long do we store personal data?

We will only keep your Personal Data for five (5) 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 defense 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 5 years after your last completed service or delivery of product.

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.