1. Our Commitment to Your Privacy
2. Personal Information
What personal information do we collect?
“Personal Information” includes information that identifies you, or could be reasonably used to identify you, and which is submitted to and/or collected by EF and maintained by EF in an accessible form. Examples of personal information that we may collect through the Sites include your:
- User name
- Postal address (including billing and shipping addresses)
- Telephone number (including home and mobile phone numbers)
- Email address
- Credit and debit card number
- Profile picture
- Social media account ID
- Country of residence
- Usage habits
- IP Address
- School name and address
- Company name and address
- Preferred educational courses
- Browser and device information
- Server log file information
- Information collected through cookies, pixel tags and other technologies
- App usage data
- Demographic information and other information provided by you
- Location information
- Aggregated information
How do we collect personal information?
We and our service providers may collect Personal Information in a variety of ways, including:
- Through the Sites: We may collect Personal Information through the Sites, e.g., when you sign up for a newsletter or make a purchase.
- Offline: We may collect Personal Information from you offline, such as when you contact customer service.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
- Through your browser or device: Certain information is collected by most browsers or automatically through your device. We use this information for statistical purposes as well as to ensure that the Sites function properly.
- Through server log files: Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited.
- Through your use of an App. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- From you: Information such as date of birth, gender and zip code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information.
- Physical Location: We may collect the physical location of your device.
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.
How do we use personal information?
We may use Personal Information:
- To respond to your inquiries and fulfil your requests, such as to send you newsletters or to respond to your questions and comments.
- To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies. Because this information may be important to your use of the Sites, you may not opt-out of receiving these communications.
- To complete and fulfil your purchase and/or your donation, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
- To provide you with updates and announcements concerning our products, promotions and programs and to send you invitations to participate in special programs.
- To allow you to contact and be contacted by other users through the Sites, as permitted by the applicable Site.
- To permit you to participate on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including our Social Media Pages).
- For our business purposes, such as analysing and managing our businesses, market research, audits, developing new products, enhancing our Sites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the Sites experience and content based on your past activities on the Sites, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).
- We use information collected by browsers or your device for statistical purposes as well as to ensure that the Sites function properly.
- We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (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.
- Your personal data will be processed by EF both within and outside the EU/EEA/Switzerland, primarily for the purpose of completing your booking, providing you with the products and services that you have ordered (including travel insurance coverage), and for customer service and marketing activities. Because our servers are located in the US, our sales teams are based in local offices globally, our head office is in Switzerland, and the schools where the students chooses to take the classes are in local offices globally, we may share your personal data with our corporate affiliates, claims handlers and business partners both within and outside the EU/EEA/Switzerland. The business partners that we share information with are only such that need access to the Personal Information to process the order that you have placed on the Sites, such as transportation assistance, accommodation, or schools, and they will only receive the information necessary for that purpose. No business partner will receive your Personal Information for their own marketing purposes. EF processes your personal data in compliance with applicable privacy and data protection legislation. If you have questions about EF’s processing of your personal data, or would like to have a copy of the information EF holds about you, or have inaccurate personal data rectified or erased, please contact us.
We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section form.
4. Access, Modification and Choices
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes.
- If at any time you wish to stop receiving marketing communications from us, the easiest way to do so would be to use the unsubscribe feature in the marketing communication you received. You may also let us know by emailing, calling or writing to us using the contact information listed below 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 and in no event later than 5 working days after we received your request. Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
- To review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that has been previously provided to us, please use the “Contact Us” form and clearly describe your request. In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.
We will try to comply with your request as soon as reasonably practicable. Note that despite our efforts, there may be residual information that will remain within our databases and other records, which will not be removed or changed. Further, please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
5. Third Party Sites
We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
6. Retention Period
7. Use Of Sites By Minors
We offer programs for children for purchase by adults. For the protection of children’s privacy, we require parental consent from users who wish to make a reservation or order a brochure for one of these programs for any users under the age of 18.
8. Sensitive Information
We generally ask that you do not send us, and you do not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, criminal background, membership of a professional, trade or political association, or trade union memberships; health or medical information; genetic information; and biometric information or templates) on or through the Sites or otherwise to us. In specific exceptions, such as insurance requests, we will make clear how you can do this securely.
10. Contact Us
We will investigate any complaint and will use reasonable endeavours to respond to you in writing as soon as possible.
If we fail to respond to your complaint within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the Office of the Australian Information Commissioner ("OAIC"). Details of how to contact the OAIC are located at www.oaic.gov.au.