Privacy policy

Version: January 2026

Our Commitment to Your Privacy

Efekta Education Group is committed to protecting the privacy of our potential and existing customers and learners.

This privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) collected or submitted through our website learn.better.efekta.com, through our official social media pages or through other channels online and offline and our online training platform, as further described below (collectively the “Efekta Products”).

We are providing the below information so that you can understand how we protect and use your information. If you are under 18, we suggest that you review this information with your parents.

Controller

Where we make decisions on how personal information is used in connection with our services, Efekta Education Ltd, incorporated and registered in England and Wales with company number 15012429 whose registered office is at 22 Chelsea Manor Street, London SW3 5RL United Kingdom (“Efekta Education”), is the controller for the processing of your personal data. This applies for example when we process Personal Data to pursue our own legitimate interests, if you register for a newsletter or if we are legally obliged to process data (e.g. to pass on data to an investigative authority). Aggregated de-identified student data is leveraged by Efekta Education to improve existing or develop new educational products and services.

Where we only use personal information as allowed by our customers (where we are acting as a “processor”), our customers are similarly responsible for the obligations of a controller under applicable laws for the data that they share with us about you and we will act as a processor on their behalf. If you are using our services through one of our customers, you should contact them if you have questions or concerns about the processing of your personal information or compliance with applicable laws.

Personal Data

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

  • Country of residence

  • Technical information, e.g. screen/username, 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

  • Institution related information

  • Online training platform placement details (e.g. language level, gender)

  • Student ID

  • Study history and results, writing and speaking submissions or writing tests

  • Audio or video recordings of study exercises you’ve completed and metrics of such recordings (e.g. speed, vocabulary, pronunciation etc.)

How do we collect Personal Data?

We collect Personal Data in a variety of ways:

  • Directly from you: Personal Data is collected directly from you, for example:

    • Online: We collect your Personal Data through the Efekta Products, for example when you study Efekta courses or use Efekta’s AI tools.

This may include:

  • 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 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.

  • If you browse our sites. We may 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 Efekta Education Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the Efekta 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

  • 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 participation in the learning platform. We record your voice and content when you use some of the learning tools in the learning platform.

  • From our corporate affiliates or business partners. We may receive Personal Data from other parties in conjunction with your course/program, including:

    • Our corporate affiliates that offer customer service in your country of residence and provide us with the Personal Data that is needed to perform the agreed services .

    • Business partners, such as local sales agents that promote the sales of our services in your country of residence.

  • From your institution. In order to set up your learning account or take a survey, your institution may provide us with your contact and institution details.

How do we use Personal Data?

We will use your Personal Data for the following purposes:

  • Your Personal Data will be processed by Efekta Education for the purposes of providing you with the information and services that you or your institution have requested, for customer service, administrative services or as otherwise necessary to perform the contract between you or your institution and us or as further described in this policy.

  • This includes:

    • To invite you as a student to create a user account and do a need survey;

    • To establish the appropriate language level, analyze your skills and suggest improvements;

    • For statistical purposes, system maintenance, backup, calculating usage levels, and helping diagnose server problems with the Efekta Products, for business development as well as to ensure that the Efekta Products function properly;

    • To provide customer service or send service related information, via various channels such as SMS, messenger services, chat bots or email;

    • To track progress and give feedback to your institution about the services and the studies. Many times, the personal data will be anonymised before used for such purposes;

    • Where relevant, to establish, exercise or defend legal claims;

    • To detect, investigate or prevent information security incidents, fraud, misrepresentation or crime;

    • To meet applicable legal, regulatory and compliance requirements;

  • We use aggregated and de-identified data about your studies, including audio recordings and metrics of such recordings (e.g. speed, vocabulary, pronunciation etc.) as well as study history and results, writing submissions or writing tests to better understand demand for our offerings, inform product developments, and build higher quality, more useful services including to further improve our AI models. Such data does not include any personally identifiable information such as student name or student ID, but could include identifiable information if voluntarily provided in the text or voice submission due to the nature of the use case. No data is ever used to train any third party LLMs.

How do we share Personal Data?

We share your Personal Data as described below and in this Privacy Policy, and as permitted by applicable law:

  • Learner study results and progress (but not audio or video recordings) may be shared with your institution, as necessary to perform the contract for language training between your institution and us.

  • Corporate affiliates

Our corporate affiliates are for example Efekta Education affiliates that provide internal service functions such as IT, legal or other shared services. 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, providers of IT systems in order to manage customer relations; providers of software and services for digital marketing automation and analytics; advertising platforms; for customer service, business analytics, and fraud prevention and compliance services; to serve you with advertising tailored to your interests.

Efekta Education is using a crash reporting tool to send information about bugs and crashes that users experience. The application automatically collects certain information that does not personally identify users of it. This information includes, but is not limited to, information on the device such as device ID, device mode, time of failure and the physical location of a device at the time of a crash.

  • Corporate transactions.

In the event that our business is sold or integrated with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and will be passed 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.

International Data Transfers

Efekta Education has business activities in several different countries, and your Personal Data may be shared with affiliates of Efekta Education or other recipients as described above having a need to receive such data for the purpose of performing the services you have requested, or according to this policy. Such recipients may be located outside your own country, including countries outside the country where you are domiciled, including USA and India. Unless the European Commission or the equivalent authority in your home country has decided that a country ensures an adequate level of protection for personal data, Efekta Education will use contracts based on the European Commission’s standard data protection clauses for international transfers of personal data to ensure compliance with applicable law, or other transfer mechanisms required by the law in your home country. You have a right to ask us for a copy of the standard data protection clauses (by contacting us as set out in the Contact Us section below).

On what do we base our right to collect and use Personal Data?

When we process Personal Data on behalf of a customer, as a processor, we do so to perform the contracted services with the customer. In such cases we process the Personal Data solely on behalf of the customer and you should read their privacy policy or notice to understand how your Personal Data will be processed by or on their behalf.

For other processing where we act as a controller, we have documented the lawful bases for our processing activities in Annex 1.

On some occasions, we process your Personal Data on the basis of your consent (for example, when you agree that we may set cookies other than those that are strictly necessary, or opt-in to receive marketing communications). Where we do process data based on consent, your consent is revocable at any time.

The processing of some of your Personal Data is necessary in order to provide services to you pursuant to the agreement that you or your institution enters into with us. Without this information, we would not be able to provide certain services to you.

On other occasions, we process your data when we are required to do this by law (for example, if we are required by court order or any applicable law to process data or we otherwise need to do so in order to meet our legal obligations in either case).

We also process your Personal Data when it is in our, or a third party’s, legitimate interests to do so, provided that your data protection rights do not override these interests.

How long do we store personal data?

We will keep most of your Personal Data for two (2) years after your course finishes, in order to be able to provide you the possibility to re-activate your account, should you or your institution decide to purchase additional courses from us, or otherwise 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.

Data collected for speech scoring exercises and writing corrections are retained for one (1) year, except audio recordings for those processing activities are retained for one (1) month before they may be transcribed and anonymised for certain of the purposes described in this policy, such as research and service improvement.

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 unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

Unsubscribe

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, change the privacy setting in the online school 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.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

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 any event within legally stipulated deadline.

Third Party Sites

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 Efekta Product contains a link. The inclusion of a link on Efekta 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 Efekta 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.

Sensitive Data

We do not generally seek to collect nor infer any sensitive Personal Data. 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 certain limited situations, this might however be necessary (for example in order to provide you with the services and products you have ordered). We will make sure that we receive your explicit consent to such processing or otherwise meet a legal condition to do so, and we will treat this information securely.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS - please click here

Updates To This Privacy Policy

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.

Your Rights

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

Depending on the lawful basis for processing upon which we rely, you have a right to:

  1. request access to your Personal Data;

  2. request that we correct or complete Personal Data that is inaccurate or incomplete;

  3. request that we erase your Personal Data, which we will do where required by applicable privacy and data protection legislation;

  4. restrict our processing of your Personal Data, in certain circumstances;

  5. request that we provide you with copies of your Personal Data in a machine-readable format or transfer it across different services;

  6. object to certain types of processing, including where we process your Personal Data on the basis of our legitimate interests and for direct marketing purposes; and

  7. where we have asked for your consent to process your data, to withdraw this consent.

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 using the contact details below. 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.

AUTOMATED DECISION-MAKING

If you have explicitly given your consent for marketing purposes by ticking the relevant checkbox (for clarity, agreeing to this Privacy Policy does not constitute marketing consent), Efekta Education may collect Personal Data for the purpose of profiling in order to serve promotional information tailored to your interests, for example to analyse or predict aspects concerning that your economic situation, personal preferences, interests, behaviour, approximate location or movements. This type of profiling does not produce any legal effects on you.

DOES EFEKTA EDUCATION USE ARTIFICIAL INTELLIGENCE?

Yes, we do use artificial intelligence (“AI”) at times. However, we do not use your Personal Data in this context to make ‘solely automated’ decisions about you (i.e. a decision made solely by technology without any human intervention) or profiling (i.e. processing your Personal Data using technology to evaluate certain conditions about you) that produces a legal effect or similarly significant effect concerning you.

Our AI features that do not require audio (e.g. voice) specifically, are transcribed before analysis is made. This reduces bias around accent, nationality, gender, age etc. Output is monitored on an ongoing basis, and where it is deemed unacceptable, changes are made to the AI model to reduce the risk of such output arising again. We take steps to reduce or remove entirely where possible the amount of Personal Data in these transcripts before using them to train AI models.

Apart from the EF custom built LLM used to provide EFSET speaking and writing tests, we use third party foundational models that are fine-tuned with our own data. The machine learning technology is run on our own servers and no data will be shared with any third parties.

These features are part of the school and cannot generally be turned off based on individual preferences. However, to the extent we undertake this processing on the basis of legitimate interests, you have a right to contact us to object to this processing on the basis of your specific circumstances.

Set out below is a description of what data we record/capture for AI and its purpose, together with an explanation of the AI technology used and how long that data is kept by us.

Description

Technology used (third party or our own), storage of data, retention time.

Speech scoring exercises, either delivered through videos, text or pre-recorded audio. The student responds using speech, and an AI functionality then provides feedback/ a score on this.

Technology used:

  • Proprietary EF model.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details (name, student ID etc.) is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Length personal data is stored:

  • 1 year for Student ID

  • 1 year for text data (transcription text and result)

  • 1 month for audio data

  • 1 year for audio score data

AI Conversations

AI conversational roleplays enable students to develop their spoken fluency by practicing open-ended dialogues in a low-pressure environment with instant feedback.

Technology used:

  • Fine-tuned EF model built on existing foundational models.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details (name, student ID etc.) is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Length personal data is stored: 

  • Audio: 1 year

  • Transcription: 1 year

After class report

After class reports are provided to students after each OnDemand class, summarising their performance. Our proprietary AI provides quantitative insights and leverages an LLM to generate unbiased qualitative analysis.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details (name, student ID etc.) is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Length personal data is stored: 

  • Videos: 6 months

  • Audio: 1 year

  • Transcription: 1 year

Writing exercise corrections: High accuracy response with rich feedback to develop more effective and impactful written communication.

Technology used:

  • Proprietary EF model built on existing foundational models.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details (name, student ID etc.) is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Length personal data is stored:

  • Data to process the correction is linked to student id only and can be deleted upon request from the client.

  • Data around submissions / corrections will be kept for retraining purposes unless otherwise specified / requested for deletion.

EF SET speaking and writing tests:

When students take EF SET speaking and writing tests they receive instant CEFR evaluation alongside other skills giving learners a more complete picture of their language proficiency.

Data collected in connection with EF SET includes information submitted while taking the tests, such as audio, writing tests, information provided in form fields (email address, name, country, city, job function. Optional: phone number, and possible other fields selected by the client) as well as test results.

This data is used to provide results to learners, clients and our own reporting.

Anonymized test results are used as part of our analysis that informs our EPI research.

Technology used:

  • Proprietary EF model.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details (name, student ID etc.) is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Length personal data is stored:

  • PII data is stored for 10 years, to allow for certificates to be redeemed.

  • The data retention period is 1 year for the text data (transcription text and result).

  • The retention period for the audio data is 1 month.

Chatbot

Real-time student support provided by our AI agent.

Technology used:

  • Agentforce. Salesforce does not use data for model training.

Length personal data is stored:

  • Salesforce has a zero data retention policy in place which ensures any third-party LLMs used by Salesforce do not retain Customer Data or use it for model training. The student data and the content of the chat will be retained in Salesforce as the rest of student data (2 years after the course finishes).

Contextual help / Addi

Learning data generated during the studies, in combination with student ID, is processed through an LLM to provide a more personalized learning experience and feedback.

  • Fine-tuned EF model built on existing foundational models.

  • The machine learning technology is run on our own servers and the recording will not be shared with any third parties. No learner details is ever used to train the models at any time and the training data is not used to train public-facing LLMs.

Contact Us

If you would like to have a copy of the information Efekta Education holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at our address above.

If you have complaints about our handling of your Personal Data, please first contact our contact our DPO here. You also have a right to contact the supervisory authority in the country where you live.

Annex 1

Type of and purpose of processing

Lawful basis for processing

Providing you with services and information that you or your institution have requested, for customer service, administrative services.

To invite you to do a need survey

To establish the appropriate language level analyze your skills and suggest improvements

To provide services to you as agreed with your institution.

For statistical purposes, system maintenance, backup, calculating usage levels, and helping diagnose server problems with the Efekta Products, for business development as well as to ensure that the Efekta Products function properly.

Legitimate interest in administering and maintaining the Efekta Products for the benefit of users.

To provide customer service or send service related information, via various channels such as SMS, messenger services, chat bots or email.

To provide services to you as agreed with your institution.

To track progress and give feedback to your institution about the services and the studies.

To provide services to you as agreed with your institution.

To establish, exercise or defend legal claims

Legal obligation

Legitimate interest in bringing and defending legal claims to protect the business.

To detect, investigate or prevent information security incidents and/or report fraud, misrepresentation or crime

Legal obligation

Legitimate interest in detecting, investigating or preventing information security incidents, misrepresentation and crime to protect (a) users of the Efekta Products, and (b) our directors, employees and consultants.

To meet applicable legal, regulatory and compliance requirements.

Legal obligation

Legitimate interest in ensuring compliance with applicable laws and regulations.

To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the Efekta Products experience and content based on your past activities on the Efekta Products.

Consent, if explicitly obtained

To market our products and services, including special promotions based on your interests

Consent or where legally permitted, legitimate interest in running a viable business.

For the transmission and communication to third-party companies or Efekta Education affiliates for their marketing purposes, including direct marketing activities and telemarketing.

Consent

To provide AI enabled speech scoring for the purposes of providing a personalised and improved learning experience and study results, as well as to train Efekta’s AI model

To provide services to you as agreed with your institution.

Legitimate interest in developing our product.

To provide writing exercise corrections for the purposes of developing more effective and impactful written communication, as well as to train the AI model.

To provide services to you as agreed with your institution.

Legitimate interest in developing our product.

Chatbot: To provide real-time student support

To provide services to you as agreed with your institution.

Legitimate interest in developing our product.

Contextual help/Addi: To provide a more personalized learning experience and feedback

To provide services to you as agreed with your institution.

Legitimate interest in developing our product.