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efi.org Privacy Statement
 Effective as of: May 29, 2018

 efi values your privacy.

This Privacy Statement of efi (“efi” “we” “us” or “our”) outlines how your personally identifiable information and other personal data (your “user information”) will be collected, used, and shared in connection with your access to and/or use of efi.org and any content, features, services, or other offerings that EFI may provide in connection therewith (collectively, the “Site”). This Privacy Statement also describes your choices and rights regarding the use, access and correction or deletion of your user information. By using the Site, you consent to the use of your user information in accordance with this Privacy Statement. If you are located in the EU, you will also be asked to provide clear and unequivocal affirmative consent to the collection, processing, and sharing of your user information via cookies and similar technologies. The Site is owned and operated by EFI. 

Notice to EU Individuals: this Privacy Statement and its enumerated policies are intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of your user information in accordance with the GDPR. 

Summary

To enhance, personalize, and support your experience on the Site, among other things, we collect, use, and share your user information. For example, we use aggregated information to develop content targeted to user interests and to generally improve the Site's user experience. As detailed below, your user information may also be used by EFI and its partners to tailor content and ads, provide social media features (e.g., features that allow you to share content directly to your preferred social media platform), track your preferences, analyze traffic, and provide similar services and content. EFI is committed to your privacy and will not share any user information with any third party without your consent, except as outlined in this Privacy Statement or as permitted by law. If you have any requests, comments, or questions about this Privacy Statement or your user information, please contact us in the manner provided below.

What this Privacy Statement Covers

This Privacy Statement covers the Site. While you may encounter links on the Site to other websites, such as those relating to our third party partners, please note that these websites are not covered by this Privacy Statement (unless otherwise noted on such site, which may be the case if, for example, the site is also owned and operated by EFI). 

This Privacy Statement does not apply to the activities of EFI third party partners that may collect your user information while accessing or using such third party's services in connection with your use of our Site.  The privacy and information practices of those third parties are not covered by this Privacy Statement. To learn more about such third party policies, we encourage you to read and review the privacy statements of each third party service that you may choose to use in connection with the Site. This Privacy Statement applies only to information collected by us. 

As a general reminder, please think carefully before you decide to put anything on the internet. For example, if you voluntarily disclose user information in chat areas or bulletin boards (e.g., comments sections), that information could be seen and used by others, and may result in unsolicited messages from others. We are not responsible for the personally identifiable information or other user information you may choose to submit in these public forums. To request removal of your personal information from EFI, please contact us as provided below. In some cases, we may not be able to remove personal information voluntarily disclosed by you in such forums for legal retention purposes or technical limitations (e.g., the data may not be searchable), in which case, we will notify you if we are unable to do so. 

CCPA Privacy Notice for California Residents

Energy Federation, Inc. Privacy Notice for California Residents

Effective Date: January 1, 2020

We adopt this notice to comply with the California Consumer Privacy Act of 2018 CCPA and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect: We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include: 

  1. Publicly available information from government records.
  2. Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

 

Examples

 

Collected

 

A. Identifiers.

 

A real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name.

 

YES

 

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 

A name, address, telephone number.  Some personal information included in this category may overlap with other categories.

 

YES

 

C. Protected classification characteristics under California or federal law.

 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

NO

 

D. Commercial information.

 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

NO

 

E. Biometric information.

 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

 

NO

 

F. Internet or other similar network activity.

 

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

 

YES

 

G. Geolocation data.

 

Physical location or movements.

 

NO

 

H. Sensory data.

 

Audio, electronic, visual, thermal, olfactory, or similar information.

 

NO

 

I. Professional or employment-related information.

 

Current or past job history or performance evaluations.

 

NO

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

 

NO

 

K. Inferences drawn from other personal information.

 

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

NO

 

 

 We obtain the categories of personal information listed above from the following categories of sources:

  1. Directly from you. For example, from forms you complete or products and services you purchase.
  2. Indirectly from you. For example, from observing your actions on our Website only in the aggregate; and
  3. Indirectly from you.  For example, from your utility provider or the marketplace sponsor. 

Use of Personal Information: We may use or disclose the personal information we collect for one or more of the following purposes:

  1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  2. To provide, support, personalize, and develop our Website, products, and services.
  3. To create, maintain, customize, and secure your account with us.
  4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  6. To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  7. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  8. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  9. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  10. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information: We don’t sell your personal information, subject to your right to opt out of those sales. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

  1. Service providers.
  2. Data aggregators.

Disclosures of Personal Information for a Business Purpose: In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose. 

Sales of Personal Information: In the preceding twelve (12) months, Company had not sold personal information. 

Your Rights and Choices: The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights: You 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 verifiable consumer request we will disclose to you: 

  1. The categories of personal information we collected about you.
  2. The categories of sources for the personal information we collected about you.
  3. Our business or commercial purpose for collecting or selling that personal information.
  4. The categories of third parties with whom we share that personal information.
  5. The specific pieces of personal information we collected about you (also called a data portability request).
  6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    1. sales, identifying the personal information categories that each category of recipient purchased; and
    2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

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 verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

  1. Calling us at 508-870-2277 and Request Marketing Opt-Out
  2. Marketing@efi.org

Only you, or someone legally authorized to act on your behalf, may make a verifiable 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:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email, transaction history including mailing address.
  2. Describe your request with sufficient detail that allows us to properly 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 the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (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.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically.

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.

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.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We may from time to time, provide the following financial incentives: utility sponsored rebates and/or limited time offer such as manufacturer discounts.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to marketing@efi.org or write us at: Marketing, EFI, PO Box 538 Marlborough MA, 01752

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 508-870-2277

Website: www.efi.org

Email: marketing@efi.org

Postal Address:

EFI
Attn:Marketing
PO Box 538

Marlborough, MA 01752

Gathering of Information

Section Overview: We collect user information when you use the Site. Sometimes you may submit it to us yourself, other times it may be collected automatically. You can manage and change your preferences as outlined below.

Information Collected

When you use the Site, your user information may be collected, used, and shared in a variety of manners. As detailed below, the type of user information collected may vary based on how it was gathered, but may include, among other things, your name, email address, and other information that you voluntarily submit (e.g., when setting up an account or submitting a registration or application on the Site, you may submit your contact information, utility account numbers), information automatically collected about your usage of the Site (e.g., the content that you choose to view. 

Voluntary Submission

EFI may collect user information that is voluntarily provided by you or with your permission. In the event you order something from the Site or one of our co-branded websites, we may request additional personal information, such as your address, telephone number and credit card information, in order to complete the purchase. You always have the option not to provide the information we request. If you choose not to provide the information we request, you can still visit most of the Site, but you may be unable to access certain options and services. When you register or become a member of the Site or provide information to EFI in any other manner, you agree to provide only true, accurate, current and complete information. We also supplement the data you provide to us with data from data append services such as public or social graph data in order to better serve you with content or promotions.

Cookies

A cookie is a small data file that is written to your computer's hard drive by your web browser. A cookie file can contain and/or automatically collect information, such as a user identification code or IP address that a website will use to track the pages and number of times you have visited. The data read from these cookies may be linked to personally identifying (PII) and non-personally identifying (non-PII) information.

We and our partners use cookies and similar technologies on the Site to personalize and optimize your browsing experience and the Site by:

  • providing you tailored content,
  • safeguarding against spam and malware,
  • analyzing trends, traffic, and user behavior,
  • administering the website,
  • gathering demographic information about our user base as a whole,
  • tracking web and advertising analytics throughout the Site and partner websites,
  • Session replay and website heatmaps,
  • performing location-related functionalities and analytics,
  • participating in market research and
  • educating ourselves about how we can continue to improve the Site and its various elements.

Cookies fall into the subcategories below.

Essential Cookies. Certain cookies are used for specific purposes that are essential to your secure use and navigation of the Site. Without them, EFI may not be able to provide core Site functions and features to you, and the Site would not operate as well as you or EFI would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files (detailed below), and other credential-related information. For EU individuals, essential cookies also help inform EFI whether you require, or have already been served, an affirmative consent request in connection with the GDPR. Essential cookies include analytics cookies, which provide us data that allows EFI to better understand its users and improve the Site based on what we have learned from that data.

Preference Cookies. Other cookies are used to collect and process information about your preferences and similar choices in connection with the Site in order to optimize your browsing experience. Preference cookies include social media cookies, which collect information about your social media usage and other data you may have provided in connection with such usage (if you access the Site through a social media website or mobile application, you may have social media cookies). If you wish to modify or change your social media cookies, please visit and review the settings on your applicable social media account(s).

Advertising Cookies. To help support the Site and further tailor your experience, EFI and its advertising partners (and/or their third party analytics providers) also use cookies on the Site to personalize the content and advertisements you may be shown. Such advertisements use cookies to provide you targeted advertisements that may be more consistent with your interests than non-targeted advertisements. Certain EFI advertising partners may also use cookies to monitor or track the performance of their advertising content, including native advertising content.  EFI does not provide user information to advertising partners except in connection with the Site or as required by law

If you would like to manage your cookie preferences or learn more information about this practice and your right to decline (or opt-out of) cookies placed by some or all of these companies, please click here 

We encourage you to consider keeping your cookies enabled, as if you choose to disable the receipt of cookies from our Site, you may not be able to use or benefit from certain features of the Site, particularly the features that are designed to personalize your experience. To learn more about the use of cookies in online advertising including how to manage or delete them click here.

Most web browsers automatically accept cookies, but generally allow users to modify their browser settings to display a warning before accepting a cookie, to accept cookies only from certain websites, and/or to refuse all cookies.

Web Beacons

We use web beacons (invisible images often referred to as pixel tags or clear GIFs) on our sites in order to recognize users, assess traffic patterns, identify preferred content and measure site engagement. We also include web beacons in our e-mail messages, including newsletters, in order to count how many e-mail messages have been opened.

EFI and its partners (including advertising partners) also use web beacons to collect various data provided by your browser while you are on our Site and elsewhere (i.e., outside of the Site) where we may be acting as a 3rd party. This data is collected in the aggregate, but may include or be associated with other non-PII or PII that users have voluntarily submitted.

Log Files

The Site's web and ad servers log information about a user's IP address, browser type and the current URL the user is requesting. This information is always provided by a user's browser and automatically logged by most websites. These log files are stored in a secure location and used in our internal analysis of traffic patterns within our website.

Use of Your Information

Section Overview: Our primary goal in collecting, using, and sharing user information is to enhance your experience on the Site, support the Site, and improve its features, performance, and other elements. Your user information may be used for the purposes outlined below. We will not use your user information without a valid legal basis to do so.

To Target Content and Advertising

To develop and provide content and advertising to you that is targeted to your interests, we use the analytics collected by the systems described above to determine which areas of our website you prefer based upon the frequency of your visits and engagement with those areas. We may make reasonable assumptions based on your browser provided data to target relevant content and advertising to you on our site and elsewhere where we may be acting as a 3rd party. We may also make reasonable geographic and demographic assumptions based on your presented IP address to target relevant content and advertising.

To Provide Interactive Communications from the Site

To enhance your experience we may provide you with interactive communications, such as notifications of activity by topic or contributor to the e-mail address that you provide to us. Such interactive communications are provided only to those users who have expressly provided us with their permission to receive them as part of their user profile.

From time to time we may provide e-mails highlighting new features, promotions or contests on the website to those users who have expressly provided us with their permission to send such communications as part of their user profile.

To Provide Communications from Third Parties

We respect the privacy of our users and will not disclose or distribute our user list to any third party, nor will we permit anyone else to do so. However, we do make available for rental our list of those registrants who have expressly provided us with their permission to receive third party offers as part of their user profile. In those cases, your e-mail address will be transferred to the third party. You can remove your consent to this use or modify your related user information by contacting EFI as indicated below.

Sharing of Information

You may be requested to voluntarily provide certain user information during your use of the Site. If you choose to do so, that user information may be shared with EFI as well as business partners and vendors providing hosting and other services for EFI.

We use third parties to provide credit card processing, e-mail service providers and hosting services on the Site. When you sign up for such services, we will share your user information only as necessary for the third party to provide that service. These third parties are prohibited from using your user information for any other purpose. With respect to credit card processing, we do not collect, store, or process any credit card information. If you do not want your information to be shared, you can choose not to allow the transfer of your information by not using that particular service. 

In addition, if you provide any personally identifiable information via an advertiser promotion, please be aware you are directly providing your personally identifiable information to that advertiser.

From time-to-time we may provide you the opportunity to participate in promotions or surveys on our site. If you participate, we will request certain personally identifiable information from you, such as your name and e-mail. Participation in these promotions or surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. We use this personally identifiable information to notify contest winners and award prizes.

As noted above, you can log in to our site using sign-in services that bridge your social media login information with the Site. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. These services give you the option to post information about your activities on this website to your profile page to share with others within your network. The Site includes social media features, widgets and/or interactive mini-programs that run on our site. These features are small content modules that users can embed on sites and may collect your IP address, which page you are visiting on our site, or set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Aggregate, Anonymous Information with Advertisers

We use the aggregated, anonymous information that we gather (as well as information from third-party market researchers) to describe our services to partners and to assist us to better understand our audience. We do not disclose personally identifying information about our users to these parties.

If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out or modify your choices by clicking here, or if located in the European Union by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

As Necessary to Provide Services to You

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of newsletter mailings, processing transactions, or performing statistical analysis of our services. We will only provide those companies the information they need to deliver the service. In some instances, these companies may collect information directly from you. In these cases, you will be notified of the involvement of the external service provider. In all cases, these companies are subject to agreements that require them to maintain the confidentiality of your information and they are prohibited from using that information for any other purpose.

In the Event of Sale or Bankruptcy

The ownership of the Site may change at some point in the future. Should that occur, we want this site to be able to maintain a relationship with you. In the event of a sale, merger, public offering, bankruptcy or other change in control of EFI, your information may be shared with the person or business that owns or controls this site. Opting out of receiving information from third parties will not affect our right to transfer your information to a new owner, but your choices will continue to be respected regarding the use of your information. You will be notified as described below in "How will I know if the Privacy Statement is changed." 

As Required By Law

EFI may disclose your personal information if required to do so by law such as to comply with a subpoena or in the good faith belief that such action is necessary to conform to the edicts of the law, protect your safety or the safety of others, investigate fraud or comply with a judicial proceeding, court order or legal process served on EFI or to protect and defend the rights or property of EFI.

Notice to EU Individuals: As outlined in this Privacy Statement, EFI will not process your user information without a lawful basis to do so, as such bases are defined in Article 6 of the GDPR. In general, EFI will process your user information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation (as noted above). EFI may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering and continuing to develop and improve the Site, learning from your behavior on the Site (e.g., analyzing traffic) to better serve you and other Site users, helping us modify or enhance the Site and its content, receiving insight as to what users do (and don't) like about our Site or aspects thereof, and providing a stable, consistent, and secure user experience in connection with the Site.

Security

Section Overview: We care about the protection of your user information and use industry standard safeguards to do so. Of course, it's important to keep in mind that no data transmission on the Internet is guaranteed to be 100% secure.

Your information is stored on EFI servers located in the United States. We use industry standard physical, electronic, and organizational safeguards to protect your user information against loss or theft as well as unauthorized access and disclosure to protect your privacy. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet. If you are concerned that your privacy may have been breached, please contact us as provided below. 

Privacy of Children

Section Overview: The Site is intended for people who are at least 16 years of age. 

If you are less than 16 years old, please do not send any user information to us--including information such as your name, address, or e-mail address. We do not knowingly collect (nor do we wish to collect) any personally identifiable information or other user information from children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete that information from our database and terminate the corresponding account, if any. We encourage you to discuss the Site with your parent or guardian.

Cross-border Transfers

Section Overview: Your user information may be transferred to other countries in connection with your use of the Site. If you access or use the Site outside of the United States, your user information will be transferred to our servers in the United States.

EFI participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. EFI is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov/list. EFI is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. EFI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, EFI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, EFI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

How to Contact Us

Section Overview: Please contact us if you have any questions or requests.

If you have any questions regarding this Privacy Statement or how to remove or modify your user information or related consents, please feel free to contact us by e-mail.

How Will I Know if the Privacy Statement Is Changed?

If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.