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Privacy of Information | Collection of Personally Identifiable Information
- Contact details, such as your full name, e-mail address, postal address and telephone number;
- Comments, feedback, posts and other content submitted to staff;
- Interests and communication preferences including marketing permissions where appropriate; and
- IP address, browser and domain information, and visitor usage.
We are aware of and sensitive to the issue of unsolicited email (“spam”); therefore EFE and its Affiliates will never rent, trade or sell your PII.
Purposes for Collecting Your Personally Identifiable Information
- When you register to join our organization;
- When you donate online or offline;
- When you subscribe to our e-newsletter;
- When you indicate interest in learning more about EFE;
- When you otherwise participate in our online community;
- To help administer and improve our website;
- To maintain ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between the parties;
- To fulfill any legal or regulatory requirement; or
- For any other purpose that has been notified, or has been agreed, in writing.
Our web server does not automatically recognize or collect personal information based on your email address. EFE provides you with the ability to unsubscribe to any email list and to request deletion of any personal information maintained by EFE or its Affiliates.
Your EU Data Subject Rights
The European Union’s General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their PII. The GDPR allows consumers to access their PII and find out details of how that data is processed, to rectify inaccurate PII, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that PII is secured.
Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PII. If you are an individual who resides in the EU and whose PII is collected and processed by EFE, you have the right to:
- Request access to your data;
- Rectify your data;
- Take your data (in a readable, “portable” format) to another service provider;
- Erase your PII;
- Restrict or object to the processing of your PII;
- Lodge a complaint with a Member State Supervisory Authority; and
- Withdraw previously given consent to collect and process PII (which will not impact PII processed before the withdrawal).
If you have any questions or concerns regarding your data subject rights, or would like to exercise any of your rights, please contact us by emailing firstname.lastname@example.org.
Data Storage and Retention
Your PII will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We reserve the right to retain and use your PII for as long as necessary to comply with our legal obligations and business requirements and/or to resolve ongoing disputes and enforce our agreements.
Protecting Personally Identifiable Information
When you give EFE PII, we take steps to ensure that your information is treated securely. EFE uses industry-standard encryption technologies when transferring and receiving sensitive visitor data (e.g., financial information) with our site. All online donations are processed via a secure server, managed by Cybersource (for donations in USD) or Stripe (for donations originating from the EU). Please view the Cybersource and Stripe privacy policies. In addition, access to such information is restricted to those employees who are trained in the proper handling of such information and have a legitimate business need to access that information. We follow generally accepted standards to protect the PII you submit to us, whether that information is in transit or at rest.
EFE never stores your credit card information for future use. EFE uses commercially reasonable efforts to ensure the security of any personal information on our systems, and to protect against the loss, misuse, or alteration of information transmitted to us. Of course, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, EFE cannot warrant the security of any information you transmit to us.
We use various technologies to collect other types of information, including PII, automatically. For example, in order to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.
We also use analytics providers, such as Google Analytics to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics, visit https://tools.google.com/gaoptoutand download and install the Google Analytics Opt-out Browser Add-on.
Links to Third-Party Sites
The EFE website provides links to EFE Affiliate and other third party websites. While we make efforts to choose our links carefully, we cannot take responsibility for the content of linked websites, or for the privacy policies of websites we link to. Since we do not control those websites, we encourage you to review the privacy policies on those websites prior to any use.
Linking to the EFE Website
Generally, websites may link to EFE websites without seeking the permission of EFE. However, such links must clearly identify EFE as the source of the information displayed and preserve the integrity of the EFE web pages without alteration.
Transfers of PII
Your PII may be transferred, processed and/or stored in a country other than the one in which your PII is collected. When transferring your PII to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PII regardless of where it is being transferred to.
In addition to disclosing PII amongst themselves, EFE may disclose PII, where permitted by law, to other service providers, prospective or current investors in applicable funds, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Notice. In addition, EFE may share PII with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors and tax advisors (where necessary or required by law, rule or regulation).
EFE may transfer PII to a non-equivalent country (a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for PII), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact the applicable fund general partner.