EF Education First (“EF” or “We”) is committed to protecting the privacy of our potential and existing customers and staff. This 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. You should read this Privacy Policy carefully before using EF Digital Products or submitting any of your Personal Data to EF and it means you have read this Privacy Policy and agreed that we can collect, use and/or share your Personal Data according to this Privacy Policy once you start using EF Digital Products or submit any of your Personal Data to EF. If you have not read this Privacy Policy or 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 Data 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 privacy and personal data protection legislation of mainland (excluding Hong Kong, Macao and Taiwan) of the People’s Republic of China(“China”).

“Personal Data” is information or pieces of information that could allow you to be identified, including but not limited to:

• Name and contact details, including but not limited to postal and email address, telephone number etc.
• Account information, including but not limited to user name, profile picture or social media account ID etc.
• Residential Address, including but not limited to country of residence, detailed address, postal code etc.
• Birth date
• Technical information, including but not limited to 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 etc.
• Preferences, including but not limited to shopping habits, preferred educational courses etc.
• Company or school name and address
• Credit and debit card number
• Medical condition (e.g. allergies or illness)

We may collect Personal Data in below 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, specific as follows:
  • Online: We may collect your Personal Data through EF Digital Products or other online channels, for example when you sign up for a newsletter or a brochure, enrol in or purchase a product or service or activity, or take part in online survey or community forum, or provide us with your resume. Besides, 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 function of setting cookies permission in most browsers that allows you to decline the use of cookies by setting function of browsers. 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.
  • Offline: We may collect Personal Data from you offline, for example when you contact customer service, enrol in or purchase a product or service or activity, provide us with your resume, or provide information to us in writing.

  Before you provide us with Personal Data of a third party, you should get the pre-consent of such third party about allowing us to process his/her Personal Data according to this Privacy Policy and notify such third party of the relevant contents of this Privacy Policy. It means you have made above notification and got above pre-consent once you choose to provide us with Personal Data of a third party.

• From our affiliates, business collaboration parties, service providers or claim handlers both within and outside China. Our affiliates, business collaboration parties, service providers or claims handlers both within and outside China may provide us with Personal Data in conjunction with your program.
• From other sources. We may receive your Personal Data from other public and legalized sources, including but not limited to public databases; joint marketing partners; social media platforms; people with whom you are friends or otherwise connected with on social media platforms; as well as other third parties. For example, if you elect to connect your social media account to your EF 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 Digital Products you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit EF Digital Products, along with the time of the visit and the page(s) that were visited. The above data are not related to any identified or identifiable personal information unless you have submitted personal information to EF and in connection with that have accepted this Privacy Policy.

• 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 but not limited to travel insurance coverage etc.), for customer service, administrative services or as otherwise necessary to perform the contract between you and us.
• EF 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 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. You should be aware that the information and materials you provide through above services are open to the public and other people may have access to such information and materials and use them to make contract with you, send messages to you or for purposes out of our or your control.
  • To analyse 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 Digital Products.
  • To provide you with personalized location-based services and content through the use of your device’s physical location (if such function is enabled in your device).
  • To send you information about our products and services, including for the purpose of marketing and customer satisfaction survey.
  • To perform background checks.

• We may share your Personal Data with our affiliates, business collaboration parties, service providers and claim handlers both within and outside China subject to privacy and personal data protection legislation of China. For this purpose, as permitted by the foregoing legislation, your Personal Data may be sent to, and shared, transferred, processed and stored in, other countries/areas outside the countries/areas where you live.
• We may share or disclose Personal Data, including but not limited to: (a) according to the requirements of Chinese laws and regulations; (b) to comply with legal process; (c) to respond to legal requests from government authorities including government authorities of your country of residence and those outside your country of residence; (d) to enforce the terms and conditions agreed between you and us; and (e) in other conditions required or allowed by laws and regulations.
• If we conduct or are involved in any merger, acquisition, reorganization or asset sale, we can share your Personal Data with our new affiliates or transfer your Personal Data to non-affiliates and, if the latter happens, we will inform you and you can withdraw you permit.
• 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/or 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 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 Education First Research Lab for Applied Language Learning is sponsored by EF Education First. As part of EF 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 Cambridge Open Language Database (“EFCAMDAT”). All examination scripts/course assignments entered in the EFCAMDAT contain the Personal Data of EF students. The EFCAMDAT is available to researchers worldwide investigating learning of English as a foreign language.

When you register to use any of the EF 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 testing or learning service, you, or your parent or legal guardian(applicable to minors under the age of 18) on your behalf, as agreed with EF, hereby agree and give consent to EF to reproduce and transfer to the DTAL at Cambridge and enter into the EFCAMDAT any material/information that you author or create during EF testing and learning services, courses or activities including but not limited to 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 to the DTAL at Cambridge:

• 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.
• Your date of birth (only to establish the age group you are in)
• Your nationality
• Your examination scripts/course assignments, the level/unit/exercise and any EF teacher markings and corrections.

The personal information noted above will only be allowed to 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 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 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: data.protection@admin.cam.ac.uk. Any queries you may have about the EF Research Unit programme of research at the DTAL at Cambridge and its use of your EF testing and learning services assignments and Personal Data should be addressed in the first instance to:

Department of Theoretical and Applied Linguistics (DTAL)
EF Education First Research Lab for Applied Language Learning
University of Cambridge
9 West Road
Cambridge, United Kingdom
CB3 9DA

tel. +44 1223 767384
Dr Dora Alexopoulou, Principal Research Associate, DTAL
email: ta259@cam.ac.uk

We set up strict system and use appropriate 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.

If at any time you wish to stop receiving marketing information from us you can use the unsubscribe feature in the marketing information 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 information 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 and in no event later than 30 days after we received your request.

This Privacy Policy does not address the privacy policies, information protection or other practices of any third parties, including any third party operating any site to which EF Digital Products contain a link. And we are not responsible for the privacy practices of the sites to which EF Digital Products contain a link.

Additionally, we may provide you with access to third-party functionality that permits you to share your activities on EF 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 use of this functionality.

We advise and encourage you to review the applicable third parties’ privacy policies when you visit above third parties’ sites or use above 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 defence 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 or we no longer need these Personal Data. Then we will take necessary and reasonable technical measures to destroy these Personal Data or return them back to you (if possible).

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 18 without parental or legal guardians’ consent, we will delete that data as soon as possible and may disable that individual’s access to EF 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, 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 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 agree that you will visit this page regularly to review and know about these changes. It means you have accepted and agreed to these changes if you continue to use EF Digital Products or submit any of your Personal Data to us after such changes are effective.

You have the right to, at any time, raise your questions or complaints relevant to privacy, request to review, correct, update or delete your Personal Data, withdraw your consent or object to us using your Personal Data for direct marketing purposes or otherwise by contacting us through e-mail to compliance.china@ef.com. We will give you feedback as soon as reasonably practicable.

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.