Legal Information

Hult EF Corporate Education is a division of the EF Education First group. We provide corporate education and services to clients based all around the world. When we herein refer to Hult EF Corporate Education, ‘we’, ‘us’ or ‘our’ we are referring to relevant entities in the EF Education First group.

This Policy covers only personal information that you have shared with Hult EF Corporate Education. Please refer to EF's privacy policy (www.ef.com/privacy) for further information about how EF treats your data.

Information we automatically collect:

The types of information your browser or internet session automatically sends us each time you use one of our online services, include:

• Your browser, e.g. Internet Explorer, Firefox, Safari, Opera;

• Your Internet Service Provider, e.g. TalkTalk, BT, AOL, NTL, Virgin, Bulldog;

• Your computer's operating system, e.g. Windows, Macintosh, UNIX, Linux;

• Your navigation path, that is, the URL of where you came to our site from, which of our pages you visited, and your IP address.

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. For more information please refer to Google's Privacy Policy.

This information lets us see how users are finding our webpages and online services and it tells us which pages and sites are visited the most often so we can make them more useful. This information in no way enables us to identify you personally.

We also operate CCTV at Ashridge House. For more information about this please refer to our CCTV policy.

Cookies are small text files that are placed on your computer by the websites that you visit. Cookies make the interaction between users and websites faster and easier. Without cookies, it would be very difficult for a website to allow a visitor to fill up a shopping cart or to remember the user's preferences or registration details for a future visit.

When you visit any of our online services, cookies enable us to measure which pages you view and how your computer views them. By measuring general use of our online services we aim to improve the user experience and make these services more useful to you.

We use cookies to collect statistical data about your browsing actions and patterns and to provide a better user experience. It is possible to switch off cookies by setting your browser preferences but turning cookies off may result in a loss of functionality when using our online services.

When using Leadership Live we will use the statistical data collected to provide feedback to our client organisation (your employer) which may include:

• Content types reviewed

• Learning preference on those content types

• Number of users accessing

• Number of page views, what day and by country

• Top search terms

• Top pages viewed

• Individual users by display email address

• Quiz results

Do not track browser setting

Do Not Track is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. Our online services do not currently respond to Do Not Track requests.

Web authentication and log-in

Some of our online services requiring a log-in (such as Leadership Live, AIMS, e-Sharing, Alumni), may operate a single sign-on policy. This allows an individual to re-use the same log-in details across a variety of authenticated online services provided by us. In many cases these log-in details are created by us with random passwords. However, there are instances when users are allowed to self-register and hence provide a password of their choice. Though our self-registration service enforces users to register high strength passwords, and these are securely protected, it is strongly recommended that you provide us with a separate password and NOT the ones used with your banking or other highly sensitive personal online accounts elsewhere.

We will never contact you to ask for your login details or password so please be aware of emails or calls claiming to be from us that request this information.

Third party websites, content and resources

Please be aware that you may be directed via links or other means to third party websites, content and resources. These third party websites, content and resources will have their own privacy policies and may send their own cookies to visitors, collect data, or solicit and use your personal information in ways that are different to those contained in this Policy. We are not responsible for the privacy practices of the providers of these other websites, content and resources and cannot guarantee the security of any of your Personal Information collected, used or shared there. The use of such websites is at your own risk and we suggest that you read their privacy notices or policies before proceeding to use the third party site.

Our Sales team uses telephony technology provided by NewVoiceMedia Limited which is both ISO27001 certified and has Level 1 PCI DSS. Using this technology we may monitor, record, store and use any telephone calls with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Many of our teams also use Zoom or Skype for external communications. You will always be made aware if the call is being recorded and for what purpose and your consent obtained. For more information please refer to Zoom’s privacy policy and Skype’s privacy policy.

All rights reserved. Use of Hult EF Corporate Education, Hult International Business School or EF Education First’s name or logo is strictly prohibited without prior written consent.

Unless otherwise specified, EF Education First is the owner or licensee of all intellectual property rights in and to the Website and its content, including but not limited to copyright and unregistered and registered trademark rights. All such rights, save as expressly granted, are reserved, and the benefit of any goodwill which arises through your use will belong to EF Education First.

You may not republish any content or material available on our website on any other public website without our prior written consent. You may not create a link to any part of our website, without our prior written consent.

We collect various types of information from you so that we can adjust our online and offline services to meet your needs and expectations. Some of this information is collected automatically through cookies, and other information is collected when you or your employer purchase(s), or register(s) for, any of our services or subscribe to any of e our E-newsletters. We have grouped this into five categories:

Contact Information: title, first name, last name, work and personal email address(es) and telephone number(s)

Job-related Information: job title or role, client organisation & business sector, previous experience and expertise

Education-related Information: qualifications held, previous programs attended

Special Category Information: dietary requirements, accessibility requirements, health information related to non-attendance, gender, nationality, date of birth, psychometric responses and reports,

IT-related Information: Cookies, IP address, site navigation – see ‘Information we automatically collect’ below.

We will only ever collect the minimum amount of information necessary to provide the services you or your employer request. For all of our services we would collect sufficient Contact Information to carry out those services, but depending on the type of service (see table below) we may collect additional information:

We will use your personal information for a number of purposes including:

provide and administer of our services and to carry out other contractual obligations under a contract with you or your employer and this may also include sending password reminders, notice of maintenance, updates of our policies including this one;

provision of services under a contract, furtherance of our legitimate interests, consent (special category)

seek your views or comments on the services we provide;

provision of services under a contract, furtherance of our legitimate interests,

notify you of changes to our services;

provision of services under a contract, furtherance of our legitimate interests,

send you, either electronically or in print, publications you have requested or similar publications or information about complimentary or connected services

provision of services under a contract, furtherance of our legitimate interests,

provide you with the most user-friendly online navigation experience

provision of services under a contract, furtherance of our legitimate interests,

respond to any enquiry, correspondence or request including during the processing of a job application or similar application to work with us as a supplier;

provision of services under a contract, compliance with other legal obligations, furtherance of our legitimate interests, consent (special category)

use your IP addresses and device identifiers to identify the location of users, block disruptive use, establish the number of visits and from which countries

provision of services under a contract, compliance with other legal obligations, furtherance of our legitimate interests,

carry out analysis and research activities (where your information would be anonymised unless we obtained your further consent so you could not be identified);

provision of services under a contract, furtherance of our legitimate interests, consent (special category)

carry out marketing activities, where you have agreed to be contacted or where you are a previous client or participant so we can tell you about similar services (we will continue to give you an opportunity to opt out of these communications every time we contact you);

furtherance of our legitimate interests,

participate in the Financial Times (“FT”) rankings where we provide names, job title and email addresses and on occasion organisation name to the FT after we have contacted you in advance to notify you that we intend to process your data in this manner and who you will be contact by, when and why

furtherance of our legitimate interests,

By requesting information, a publication or a service you will automatically be subscribed to receive similar, complimentary or related publications. All electronic communications sent have an Unsubscribe option at the bottom of the email or E-Newsletter. All print publications are sent with a contact form which can be used to update your contact information or to unsubscribe from that publication. If you would like to update any details or unsubscribe from our publications, please contact us by email at: info@hultef.com.

We guarantee that your personal information will not be passed to any third parties other than those that are working for or with us to deliver our various services (delivery of programs, consulting, coaching, research and hospitality) and to carry out the purposes listed above. We do not sell or otherwise distribute mailing lists to third parties. However, we have contractual assurances from those companies that the data is only used to send our publications and is destroyed afterwards.

Occasionally we may share your information with Hult International Business School, Ashridge (Bonar Law Memorial) Trust, or other educational partners with whom we work, in order to advise you of services that complement our own. These partners will provide you with an opportunity to opt out of these communications every time they contact you.

We may share aggregated and anonymised information about our clients, participants and guests with advertisers, business partners, sponsors and other third parties. However, no individual information provided will be shared in this way.

Except as set out here we will not share your personal data with anyone else, except as required by law.

Profiling

When you visit our webpage or use our Leadership Live or psychometric products your details will be added to our CRM and marketing systems. We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources e.g. LinkedIn, to help us get to know you better and provide more effective personalisation.

Your rights, our obligations

You can choose at any time whether or not you wish to be contacted by us. Every communication we send you will give you the opportunity to opt out of further communications but you can also notify us at any time by email (info@hultef.com). or by telephone on +44 (0)1442 843491 to withdraw your consent to marketing or any other contact from us.

We operate robust physical and system access controls together with transmission, input, availability, processing and segregation controls to protect your personal data. Many of our SaaS providers are ISO27001 accredited and we follow similar quality controls.

More information can be obtained from our IT Security Policy.

Transferring information overseas

Data protection legislation prohibits us from sending your personal details to a country outside the UK, Switzerland or the European Economic Area (EEA) without your informed consent. We work in partnership with some organisations and individuals that operate outside the UK, Switzerland or the EEA. We may consider it to be of benefit to individuals, based in the same geographical location, if their details are passed on to an appropriate contact in their area for marketing purposes. We have put appropriate safeguards in place for transfers of your Personal Data outside the UK, Switzerland or the EEA, including the standard data protection clauses adopted by the European Commission, available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN. For more information on standard data protection clauses in place, please see the contact section below.

We will hold your personal information on our systems for as long as it necessary for the relevant activity or services, as required by our accreditors or for as long as is set out in any relevant contract you have with us, whichever is longest. If you exercise any of your rights to restrict the processing, restriction, transfer or deletion of your personal data, we will retain sufficient personal data in order to action, and continue to abide by, that request.

Your rights to find out what information we hold about you

The right to access (subject access requests) and portability

You can write to us at any time and ask for a copy of the information we hold about you. Please address your letter to our Legal Counsel. There is no longer a charge for providing this information, except where we consider the request to be manifestly unfounded, excessive or you request duplicate copies where we may charge you for this.

We can withhold your personal information in the following circumstances and without giving you justification:

• the prevention, detection or investigation of a crime;

• national security or the armed forces;

• the assessment or collection of tax; and

• judicial or ministerial appointments.

You can also ask us to transfer your data to another organisation.

Right to request rectification, updating or deletion

You may request that your personal information it updated, rectified or completed. We will make every effort to inform all third parties to whom we have disclosed the information of the changes made (unless this is impossible or involves disproportionate effort) and, if you ask us, we will let you know who those recipients are.

You may ask us to delete or cease processing your personal information where it is no longer a needed for the purpose for which it was gathered or you withdraw your consent to such processing. We can refuse to comply e.g. where we need to retain it in connection with legal proceedings or where we are required to retain your personal information by law.

If you wish to update or delete your personal information please write to us and we will arrange for your personal information to be updated or deleted.

Right to restrict processing

You can request that processing of your personal information is restricted and only permitted with your consent, except where we need in connection with legal claims or to protect of the rights of others, in the following circumstances:

• where you contest the accuracy of information, for the period it takes us to verify its accuracy;

• where the processing is unlawful and you request restriction rather than deletion;

• where we no longer need the information but it is required by you in connection with legal proceedings; or

• where you have objected to the processing, pending verification of whether we or a third party has an overriding legitimate interest.

Where processing has been restricted, we will inform you before the restriction is lifted.

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Right to object

This is a right to object, on grounds relating to the worker's particular situation, to processing based on one of the following:

• the processing is necessary for a task carried out in the public interest

• processing in the exercise of official authority

• the processing is necessary for the pursuance of the legitimate interests of the employer or a third party which are not overridden by the worker's interests

If an objection is received the employer must stop processing unless it can demonstrate compelling legitimate grounds for processing overriding the interests, rights and freedoms of the worker or that it is in connection with legal proceedings.

There are also rights to object to:

• data processing for direct marketing purposes - employer must stop processing

• data processing for statistical purposes - must stop unless in public interest

Right to appeal against automated decision making and profiling

This right allows an individual access to information about the reasoning behind any decisions taken by automated means. You can:

• give written notice requiring us not to take any automated decisions using your personal data;

• even if you have not given notice, you have a right to be informed when such a decision has been taken; and

• you can ask us to reconsider a decision taken by automated means.

This is your safeguard against the risk that a potentially damaging decision is taken about you without any human intervention.

Time limit for responding

We will respond to requests for access, rectification, erasure, restriction and objections without undue delay and at the latest within one month. If we need to extend the period of compliance by up to a further two months where requests are complex or numerous, we will notify you in writing within one month, together with the reasons for the delay. If we do not take action on your request we will inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and we will remind you that you may wish to lodge a complaint with the ICO and/or seek a judicial remedy.

Policy Review

This policy was reviewed and updated in October 2021.