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EF Education First / Candidate Privacy Notice
OUR COMMITMENT TO YOUR PRIVACY

EF Education First (“EF”) is committed to protecting the privacy of its potential employees. The EF candidate privacy notice (the “Candidate Privacy Notice”) describes how EF handles and protects your Personal Data (as defined below) in connection with EF’s recruiting processes and programs.

The Candidate Privacy Notice only applies to the Personal Data of job applicants, potential candidates for employment, and any recruiting programs and events. It does not apply to our employees, contractors or clients, or other Personal Data that EF collects for other purposes. This Candidate Privacy Notice does not form part of any contract of employment offered to candidates hired by EF.

If you cannot, or will not, provide us with the Personal Data we require, we will be unable to receive and process your application.

EF Invest International AG, Zurich, Switzerland, is the controller for the processing of your Personal Data (as defined below). Being the controller means that this company is responsible for ensuring that your Personal Data is processed in compliance with applicable privacy and data protection legislation.

PERSONAL DATA
As used in this Candidate Privacy Notice, “Personal Data” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via external recruitment firms).

PERSONAL DATA WE COLLECT
The types of Personal Data that we request from you and the ways how we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of Personal Data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located. Furthermore, we request Personal Data from you for statistical purposes or to conduct internal surveys on our candidate pool (e.g., information relating to gender or age).

We usually collect Personal Data directly from you when you apply for a job with us, such as your name, address, contact information, work and educational history, achievements, and test results. We may also collect Personal Data about you from third parties, such as professional recruiting firms, your references, prior employers, EF employees that know you or with whom you have interviewed, and employment background check providers, to the extent this is permitted by applicable law.

Sensitive Personal Data is a subset of Personal Data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not generally seek to obtain and will not collect such data about a candidate unless permitted to do so by applicable laws or if you have specifically consented to provide us such information.

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 allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy available online under www.ef.com/legal/cookie-policy.

USE OF YOUR PERSONAL DATA
We collect and use your Personal Data for legitimate human resources and business management reasons including:
• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• recordkeeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including requests from unemployment authorities or diversity and inclusion requirements and practices;
• conducting criminal history checks as permitted by applicable law;
• protecting our legal rights to the extent permitted by law; or
• emergency situations where the health or safety of one or more individuals may be endangered.

We may also analyze your Personal Data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates.

We process your Personal Data for the purposes described above when we have your consent to do so. If applicable to you, we also process your Personal Data for the following purposes: (i) to enter into an employment contract with you, (ii) for us to comply with a legal obligation or (iii) for the purposes of our legitimate interests.

We may desire to retain your Personal Data to consider you for future employment opportunities. In such an event, we will seek your consent, either prior to or after you formally apply for a job opportunity, to be part of one of our recruiting programs.

If you join a recruiting program, but subsequently wish to withdraw, please contact us at jobvite.sar@ef.com.

HOW DO WE SHARE PERSONAL DATA?
We share your Personal Data with EF’s corporate affiliates, business partners and service providers both within and outside the EEA/Switzerland:

• Your Personal Data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the EF Group. Individuals performing administrative functions and IT personnel within EF may also have a limited access to your Personal Data to perform their jobs.

• We use third party service providers to provide a recruiting database and related software systems. We also share your Personal Data with other third party service providers that may assist us in recruiting, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

• In addition, we may disclose or transfer your Personal Data within the EF Group in the event of an internal re-organization, merger, sale, joint venture, assignment, or other internal transfer or disposition of all or any portion of our business.

We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, 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. For more information on standard data protection clauses in place, please see the contact section below.

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.

ON WHAT DO WE BASE OUR RIGHT TO PROCESS PERSONAL DATA?
We base our right to collect and use your Personal Data on your consent when applying for a particular position and on our need to do so in order to process your application, or when there is a legitimate interest for us to use your Personal Data, such as for informing you about potential job positions similar to the one(s) you have already applied for.

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”.

SECURITY
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.

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.

If you accept an offer of employment by us, any relevant Personal Data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements. If we do not employ you, we may nevertheless continue to retain and use your Personal Data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimum amount of your Personal Data to record your recruiting activity with us.

If you elect to join a recruiting program, we may retain your Personal Data to consider you for future employment opportunities and for a period of time specific to that program, unless you decide to opt-out prior to such time.

UPDATES TO THIS CANDIDATE PRIVACY NOTICE
Our Candidate Privacy Notice may change from time to time. We will not significantly reduce your rights under this Candidate Privacy Notice without informing you. We will post any Candidate Privacy Notice 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.

YOUR RIGHTS
You have a right to, once per calendar year, 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 contacting you with potential job opportunities 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 general information or particular job opportunities as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.

CONTACT US
If you would like to have a copy of the information EF 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 EF Group, Selnaustrasse 30, 8001 Zurich, Switzerland or the email address: jobvite.sar@ef.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.

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