Our Commitment to Your Privacy
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, such as:
- 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, nationality
- 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
- Preferences (e.g. shopping habits, preferred courses)
- Credit and debit card number, payment history
- Lifestyle information, such as training goals, needs and fitness level
- Training efforts and progress
- Health data, such as heart rate variability, height, weight, injuries, illnesses, medical procedures and conditions, sleep pattern
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, enrol in a product or service or provide information to us in writing.
- Online: We collect your Personal Data through the Team EF Coaching Products, for example when you sign up for a newsletter or a brochure, enrol in a product or service. We also collect Personal Data:
- 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, business partners, or service providers. We may receive Personal Data from other parties in conjunction with your course/program, including:
- Business partners, such as the training coach that provides some of the services that you have ordered.
- When you make payments to, or transact with us, our service provider Stripe will receive your transaction information directly from you. The information that Stripe collects will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and in some cases, some information about your purchases. Different payment methods may require the collection of different categories of information. The payment method information that Stripe collects will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you at the time of check-out. We may also receive your name, email, billing or shipping address and in some cases, your transaction history to authenticate you.
How do we use Personal Data?
- Your Personal Data will be processed by Team EF Coaching for the purposes of providing you with the products 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:
- For statistical purposes, calculating usage levels, and helping diagnose server problems with the Team EF Coaching Products as well as to ensure that the Team EF Coaching Products function properly.
- To allow you to contact and be contacted by other users through the Team EF Coaching Products.
- To 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.
- 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 Team EF Coaching Products experience and content based on your past activities on the Team EF Coaching 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, or through other channels such as SMS, other messenger services like WhatsApp, Facebook Messenger or chat bots. 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, for example a local Team EF Coaching company that promotes the sales of our services and offers customer service in your country of residence, or assists with any of the services you have ordered.
- Business partners, for example:
- Our partners that may provide you with special offers for premium members;
- Service providers, such as or contractors for providing the coaching services to you; or providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics.
- 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
Data processed by us and our service providers may be stored in another country than your own, including the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. We have put appropriate safeguards in place for transfers of your Personal Data from EEA/Switzerland to a third country, 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 or its successor documents. For more information on standard data protection clauses in place, please see the contact section below.
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 need to do so in order to provide you with the services or products that you have ordered from us, or when there is a legitimate interest for us to use your Personal Data, such as for the marketing of products or services similar to the one(s) you have already purchased; to detect and prevent fraud or to develop new products, services, features, and functionality.
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 “Sensitive data”.
To the extent that we use your Personal Data for marketing purposes, we base this on your specific consent.
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.
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
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 service or delivery of product.
If you are under the age of 18
To use the Team EF Coaching Products, you must be at least 18 years old. If we learn that you are under the age of 18 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use Team EF Coaching Products.
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 order to provide you with advice and coaching services related to your performance and your health, we may ask for Personal Data related to your health and fitness. We will make sure that we receive your explicit consent to such processing and treat this information securely.
You have a right to contact us and without cost find out which information about you that is being used. 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 your consent or object to us using your Personal Data 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 provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.
Special notice to California residents
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 firstname.lastname@example.org including the phrase “California Privacy Request” in the subject line, and provide us with your name, postal address and email address.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to the email address listed below including the phrase “California Privacy Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
• 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.
• 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 here: https://corporate.ef.com/customerservice/contactus/inschool
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 respond 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.
If you would like to have a copy of the information Team EF Coaching 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 above or email at email@example.com.
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.