ESL is committed to maintaining the privacy and security of your personal data. This Privacy Notice explains how we collect, use, share and protect your personal data. It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data.

This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.

1. Who we are

ESL is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. Where we act as a data controller, we are required under data protection legislation to notify anyone who provides personal data to us, either directly or through a third party, of the information contained in this Privacy Notice.

When we mention "ESL", "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company below which is responsible for processing your data:

ESL Education S.A. (Reg No: CHE-108.556.655) Escaliers du Grand-Pont 7, 1003 Lausanne, Switzerland

ESL Education S.A.S (Reg No: 508 496 700 RCS Lyon) 29, Quai Docteur Gailleton, 69002 Lyon, France

ESL Education Italia S.R.L (Reg No: 06398560968) Via Montebello 27, 20121 Milano, Italy

ESL Education GmbH ÖSTERREICH (Reg No: FN 336917) Zieglergasse 3, 1070 Wien, Austria

ESL Services IT S.R.L (Reg No: 09312690960) Via Montebello 27, 20121 Milano, Italy

ESL Education GmbH Deutschland (Reg No: HRB 69208) Apostelnstrasse 11, 50667 Cologne, Germany

ESL Educación España S.L Calle Princesa Nº 2, Planta 7, oficina 7, ES - 28007 Madrid, Spain

ESL Services SP S.L Pas. de Garcia, 86 P.2, ES - 08008 Barcelona, Spain

ESL Education Belgique sprl (Reg No: 0821502403) Avenue de Tervuren, 204/2, 1150 Bruxelles, Belgium

2. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact details

Email address: [email protected]

If you are a UK national or resident in the UK, and wish to contact our UK Representative: Kaplan UK Limited, UK Data Protection Representative, Palace House, 3 Cathedral St, London SE1 9DE, England

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. What is personal data?

Personal data is any information about an individual from which that individual can be identified. Your name, address, phone number, and bank account number are examples of personal data. It does not include data where the identity has been removed (anonymous data).

4. Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

• Used lawfully, fairly, and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• We may also use your personal data in the following situations, which are likely to be less common:

               - Where we need to protect your vital interests (or someone else's interests).

               - Where it is needed in the public interest or for official purposes.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time either by unsubscribing by clicking on the link at the end of the email or by contacting us at the email address provided below.

6. The personal data we collect from you

Enquiries

When you request information or make enquiries about any of our services or products, we may use the personal data you provide in order to fulfil your request or respond to your enquiry. For example a brochure order, personalised offer, process your registration, or communicate with you.

It is in our legitimate interests to use your personal data in this way so that you receive the information you have requested.

Applications

If you make an application to study on one of the programmes we offer or related to accommodation we may collect the following categories of personal data about you:

• Personal contact details such as name, title, marital status, addresses, telephone numbers, and email addresses.
• Date of birth.
• Gender.
• Nationality and/or country of birth and/or country of residence.
• Passport number or national identity number
• Visa information and immigration status.
• Education history including academic certificates.
• Profession.
• Funding information.
• Emergency contact (name, surname, phone, personal email addresses)
• Health – relevant medical conditions and treatments, allergies, dietary requirements, difficulties with learning, smoker/non-smoker
• Language – Mother tongue and other linguistic levels
• Hobbies and interests

In order to assist us with the selection of a school and host family for you, we will also collect information by asking you to answer questions relating to your personality and what you expect from your studies abroad, and ask you to complete a presentation of yourself in order that your host family and the educational center can get to know you better.

If you are under 18 we will also collect the following personal details of your parents or legal guardian:

• Name
• Date of birth
• National identity number
• Telephone number(s)
• Address
• Profession
• Marital status
• Their signature

It is in our legitimate interests to collect and use the above information in order to consider and process your application.

We collect personal data relating to your visa application and immigration status in order to comply with our legal obligations.

We may also ask you to disclose information regarding any criminal convictions you may have as part of your application. We need to use this information in order to comply with our legal obligations.

Study and accommodation

If we enter into a contract with you relating to study or accommodation, we may collect additional personal data relating to you including accommodation preferences: house type, smokers, with children, room type, numbers of meals, dietary requirements.

We use a third-party payment provider called Ogone to proceed with the deposit payment. All the transaction details are encrypted and secured. We will provide you a link to their secure payment portal where you will be required to share payment information such as your credit card details in order to pay a deposit.

The final balancing payment is made by yourself to our bank account by transfer.

We do not collect your bank account details or payment information directly, although we may do so in the event that we need to issue you with a refund.

This information, together with the personal data provided to us above at the application stage, will be used by us to perform the contract we have entered into with you.

We may also collect personal data about your health and disability in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare, attendance, or accommodation. We use this information in order to perform our contract with you but also in order to fulfill our legal obligations.

We may also collect personal data about you (such as your name and telephone number) if you are named as an emergency contact for an individual. We use this information as it is in the vital interests of such individual.

If you use an agent to arrange your application and study with us, we may collect the categories of personal data described above from your agent.

Marketing

Where you have explicitly consented to do so or where we can rely on legitimate interest (for example for alumni), we may use your personal data to send you newsletters, inform you of special offers and new or existing services that we believe may be of interest to you or to send surveys or questionnaires so that we can learn more about your needs and interests. If you would prefer that we do not send such communications to you, please follow the opt-out links on any marketing message or contact us using the contact details in this Privacy Notice.

Internal business purposes

We also may use your personal data for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide. Where possible we will anonymise this information. Please contact us using the contact details in this notice if you would like more information.

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns such as IP address, operating system, visited pages and requests, hour and date of connection. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy on our website for further details.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

7. When and how we share your personal data with others

We may share your personal data with third parties where required by law, where it is necessary to perform our contract with you, or where we have a legitimate interest in doing so. Such third parties may include the following:

Our service providers: We may share your personal data with other companies that perform certain services on our behalf. These services may include providing insurance, processing payments, providing customer service and marketing assistance, performing business and sales analysis and supporting our website and IT functionality. These service providers may be supplied with or have access to your personal data solely for the purpose of providing these services to us or on our behalf. ESL is the data controller and will remain accountable for your personal data.

Our business partners: We may share your personal data with the school you have booked to study with, with other business partners, or with your sponsor or employer with whom we have a contract relating to your programme of study.

Agents: If you use an agent to arrange your application to study through us, or to arrange your travel or accommodation whilst you study, we may share your personal data with them.

Parents and guardians: If you are under 18, we may share your personal data with your parents or guardians in order to perform our contract, comply with our legal obligations, and if it is in your vital interests.

Other entities in the group: ESL, alongside Alpadia Language Schools and Kaplan International Languages are part of Kaplan International. We may share your personal data with other entities in our corporate group for the purposes of responding to your inquiry, processing your application, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise or for system maintenance support and hosting of data.

Regulators: We may need to share your personal data if required by a regulator or to otherwise comply with the law.

Others: We may share your personal information with other third parties such as in the context of the possible sale of our business. We may also need to share your personal data in order to permit us to pursue available remedies or limit damages we may sustain.

8. Transfer of your personal data to other countries

As we are part of a wider group of international businesses with employees, entities, and service providers all over the world, we may need to transfer the personal data you provide to us to other countries which may be outside the European Economic Area (EEA).

The data protection laws in such countries may not be as comprehensive and provide the same level of protection for your personal data as those within the EEA. In these circumstances, we will take appropriate steps to ensure that your personal data is handled as described in this notice. These steps will include appropriate contractual mechanisms. Please contact us using the contact details in this notice if you would like more information.

9. The security of your personal data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

10. Our storage and retention of your personal data

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please contact us using the contact details in this notice if you would like more information.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

11. Your rights as a data subject

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using the contact details in this Privacy Notice.

If you wish to make a rights request, please use this request form.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Your right to withdraw consent

In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details in this Privacy Notice. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

12. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.