Privacy Policy

EF (Education First) is committed to protecting the privacy of our potential and existing customers. 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, emails, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “EF Products”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

“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)
• Social Security number (for Group Leaders only)
• Country of residence or citizenship
• Birth date
• Gender
• Customer number
• 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. language, 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 and passport details, visa information
• Insurance data
• Name and contact details of family members or emergency contacts
• Other information you provide during a phone-or video call or a chat, and recordings and/or transcripts of such calls or chats.
• Photos or video recordings of you
• Study progress and attendance scores

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, enroll in a product or service or provide information to us in writing, or during a phone or video call.
• Online: We collect your Personal Data through the EF Products, for example when you sign up for a newsletter or a brochure, use our chatbot, enroll in or use a product or service. 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. 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 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 or office 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.
• 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, Snapchat, TikTok, LinkedIn, X, 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 Products 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, service provider, and the name and version of the EF Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the EF Products, along with the time of the visit and the page(s) that were visited. You can read more about collection of your IP address and other browsing data in our cookie policy.

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.
• To analyze 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 course length or tour, geography 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 also record and analyze sales calls, chats or other interactions with you with help of machine learning technology, for the purpose of quality control and to improve the sales performance, as well as to train our language models. Information from such calls, for example tone and key words are also combined with other personal data we have collected in connection with our communications with you, such as meeting attendance, and meeting notes.

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 U.S. and Canada as described below and in this Privacy Policy, and as permitted by applicable law:

• Corporate affiliates

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 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. We may also share your Personal Data to our affiliates for their own marketing purposes. This includes, but is not limited to, our brands EF Explore America, EF Language Abroad, EF Tours for Girls, EF Educational Tours Canada, EF Adventures, EF Ultimate Break, EF Go Ahead Tours, EF High School Exchange Year and Cultural Care Au Pair.

• 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 in order to serve you with advertising tailored to your interests; to other third parties to provide customer service, business analytics, fraud prevention and compliance services and to visa processing agencies. If you have not paid your bills to us in time, we may transfer some of your data to a debt collection provider.

Personal Data collected under a photo release form may be shared with the photographer/production company.

Where we offer the use of a chatbot on the EF Products through the latest AI technology, the questions that you ask the chatbot will be transferred to and temporarily stored by the AI technology provider, but will not be used to train or improve their AI models. No personal data will be transferred, unless you include personal data in your questions. You can read more here: https://openai.com/policies/api-data-usage-policies. The chat conversation and the personal data submitted in the designated fields of the chat will be stored by EF in our customer relations management system for the purpose of marketing or customer service purposes.

• Travel suppliers

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 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.

• Business partners

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. In most 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 social media platform, you will share certain information with that app or social media platform, such as the fact that you have visited or interacted with us.

• Corporate transactions

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.

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.

To respect the privacy of our users, you may choose not to receive commercial emails from us by following the unsubscribe instructions contained in the commercial emails we send you. Please note that even if you unsubscribe from commercial email messages, we may still email you regarding your account and your transactions.

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 Product contain a link. The inclusion of a link on EF Products 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 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.

If you are under the age of 13, you should review this text together with your parent or guardian to make sure you both understand them. If we learn that you are under the age of 13 and that we have collected information about you without consent from your parent or guardian, we may need to delete the information as soon as possible and you will not be able to use EF Products.

We may need to collect sensitive personal data (such as information about health, religious beliefs or sexual orientation) in order to administrate your travel, accommodation, insurance coverage and to safeguard your wellbeing throughout your course or tour.

Participation in our courses and travel requires you to be in good physical and mental health. Therefore, we may require you to disclose all serious pre-existing medical conditions and current medications prior to departure. We may also request proof of vaccination and doctors’ certificates. You must also continuously notify us any new developments in your physical or mental health until departure.

If you become ill or incapacitated during your course or tour, we may take any action we deem necessary for your safety and well-being, including securing medical treatment and transporting you home. If that happens, EF may contact the your emergency contact(s) with regard to the health issues that have occurred.

We will store and share any sensitive personal data that we collect about you in an encrypted environment and will only provide access to those who have a need to know the information. The data will be kept only for as long as necessary to achieve the purposes it was collected for, or for longer if required to meet local statutory limitation periods for bringing legal claims. We will make sure that we receive your explicit consent to such processing, unless an exception applies under the applicable data protection laws.

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.

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 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 10 years after your last completed service or delivery of product.

We respect your rights to access and control your information and will respond to requests in accordance with applicable privacy and data protection legislation. We may ask you to verify your identity and to provide other details to help us to respond to your request.

Depending on the jurisdiction you are based in, you may have a right to request access to your Personal Data; request that we correct or complete Personal Data that is inaccurate or incomplete; request that we erase your Personal Data, which we will do where required by applicable privacy and data protection legislation. You may also have a right to opt out of sharing of your Personal Data for marketing purposes.

These rights are limited in some situations under applicable privacy and data protection legislation – for example, where we can demonstrate that we are under a legal obligation or have other legitimate grounds to process your data.

If you wish to exercise these rights, please contact us at this address: [email protected]

We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.

If you have questions about this Privacy Policy, please contact us at the address EF Education First, Two Education Circle, Cambridge, MA 02141. If you have complaints about our handling of your Personal Data, please first contact our contact our DPO by clicking here.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer. Please refer to the list of categories of personal information above which we may collect or may have been collected from California residents within the last twelve (12) months.

Sources of Personal Information

We obtain the categories of personal information listed above from the categories of sources listed in the Privacy Policy above.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "How Do We Use Your Personal Data" section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category D: Commercial information
• Category F: Internet or other similar network activity
• Category G: Geolocation data

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services we provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

If you are a California resident, the California Consumer Protection Act (“CCPA”) provides you with the following specific rights regarding your personal information that is subject to this Privacy Policy and this section explains how to exercise those rights.

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact Us.
• Access to Specific Information and Data Portability Rights. California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verified consumer request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing any sales (identifying the personal information categories that each category of recipient purchased) and disclosures for a business purpose (identifying the personal information categories that each category of recipient obtained).
• Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verified consumer request, we will delete (and direct any service providers to delete) your personal information from our records unless an exception applies, which may include but is not limited to information needed: (i) to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) enable solely internal uses that are reasonable aligned with consumer expectations based on your relationship with us; (iv) comply with a legal obligation; and (v) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Under California Civil Code Section 1798.83, California residents have the right to request and receive from us, once per year and free of charge, information about the personal information we have disclosed (if any) to third parties for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to [email protected] including the phrase “California Privacy Request” in the subject line, and provide us with your name, postal address and email address.
• Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights above, please submit a verifiable consumer request to us by either:
• Calling us at 1.800.665.5364
• Emailing us at [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verified consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us properly to understand, evaluate, and respond to it. We cannot response to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make a request.

• Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without issue. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
• Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.