EFE Privacy Policy (Draft)

Education For Employment (“EFE”, “we”, “us”, or “our”) is committed to protecting the privacy of personally identifiable information (“PII”) of identifiable individuals who visit www.efe.org (the “Site”) and inquire about or use services associated with our business available through our Site (the “Service/s”), or express interest in our business. The privacy of your PII is important to us at EFE. This Privacy Policy discloses the privacy practices for EFE and for its Site, and localized versions of that site, including the type of PII collected and tracked, how the information is used, and with whom the information is shared.

In order to provide you with Services you may request, it is necessary for us to possess some PII of yours. Similarly, without some of that information, we cannot inform you about the Services we have available or that you may request (though if you are currently receiving marketing communications from us, you may opt-out of receiving further communications at any time). This Privacy Policy explains our PII policies and practices. It includes, but is not limited to, explanations of the types of PII we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your PII, and the way to contact us to exercise those rights.

Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments.


Privacy of Information | Collection of Personally Identifiable Information

When you are on EFE’s website and are asked for PII, you are sharing that information with EFE and its Affiliates, unless stated otherwise or required by law. This section explains the PII that may be collected when using our Services, and the other information we may receive from other sources. In this Privacy Policy, the term “PII” refers to the types of information we may collect and use. Some examples are listed below:

·       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

You may provide your PII to EFE in order to fulfill a Service. You are then entering a relationship with EFE and are agreeing to the use of that data by EFE and its Affiliates, as stated in this Privacy Policy. We request PII for a variety of purposes throughout your interaction with EFE, some of which are listed below:

·       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.

Lawful Basis

There is a need to process PII for the purposes set out in this Privacy Policy in the legitimate interests of EFE to operate their respective businesses, and sometimes, as a matter of contractual necessity under or in connection with applicable agreement/s. From time to time, EFE may need to process the PII on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of a donor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, EFE is relying on performance of a legitimate interests or contractual necessity.

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).

Exercising Your Data Subject Rights

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 info@efe.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.

Our Site and Use of Cookies

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.

Additionally, like most interactive web sites, we use "cookies" on certain pages of our Sites. "Cookies" are small data files that are stored on your hard drive that store certain information, including certain PII, accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Sites to make them more useful to you. By visiting our Sites, you agree to our use of cookies. For more details, please refer to our Cookie Policy. [A1]

You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Sites may not be optimal, and you may not be able to use certain features on our Sites. For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies.

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/gaoptout and 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.

Privacy Policy Changes

EFE may amend this Privacy Policy from time to time. We will post the revised policy on our website so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Your continued use of our website after the date that such notices are posted will be deemed to be your agreement to the changed terms.

This Privacy Policy was last revised and posted on _____.


Terms of Use

Use of this site is provided by EFE subject to the following Terms of Use.

Your use constitutes acceptance of these Terms of Use.

EFE reserves the right to change these Terms of Use at any time by posting changes online. Your continued use of this site after changes are posted constitutes your acceptance of these Terms of Use as modified. Accordingly, you may wish to visit this page from time to time to review the then current Terms of Use.

You agree to use this site only for lawful purposes, and in a manner which does not infringe the rights of, or restrict or inhibit the use and enjoyment of the site by, any third party. If EFE reasonably determines that you have violated or are likely to violate the foregoing prohibitions, EFE may take any action it reasonably deems necessary to cure or prevent the violation, including without limitation, the immediate removal from this website of the related materials.

This site and the information, names, images, pictures, and logos regarding or relating to EFE are provided “as is” without any representation or endorsement made and without warranty of any kind, whether express or implied. In no event will EFE or its Affiliates be liable for any damages including, without limitation, indirect or consequential damages, or any damages whatsoever arising from the use or in connection with such use or loss of use of the site, whether in contract or in negligence or any other theory of liability.

EFE does not warrant that this site or the functions contained in the material contained in this site will be uninterrupted or error free, that defects will be corrected, or that this site or the server that makes it available are free of viruses or bugs or represents the full functionality, accuracy and reliability of the materials.

Copyright Restrictions

Commercial use or publication of all or any items displayed on the site is strictly prohibited without prior authorization from EFE. Nothing contained herein shall be construed as conferring any license by EFE or its Affiliates to use any item displayed.

Documents may be copied for personal use only on the condition that copyright and source indications are also copied, no modifications are made and the document is copied entirely. However, some documents and photos may have been published on this site with the permission of the relevant copyright owners (who are not EFE or its Affiliates). All rights in these documents are reserved to their owners, and permission to copy or otherwise exploit them must be requested and obtained directly from the copyright owners (the sources are indicated within these documents/photographs).

As noted, this website may contain links to other websites. All such links are provided as a convenience to our users. EFE takes no responsibility for the content of external websites.

Any communication or material that you transmit to, or post on, any public area of the site including any data, questions, comments, suggestions, or the like, is, and will be treated as, non-confidential and non-proprietary information.

If there is any conflict between these general Terms of Use and any rules and/or specific terms of use appearing on this site relating to specific material then the latter shall prevail.

This website is administered by EFE from its offices in Washington DC. These Terms of Use shall be governed by and construed in accordance with the laws of the District of Columbia. Any disputes relating to the use of this website shall be subject to the exclusive jurisdiction of the Courts of the District of Columbia or the United States District Court of the District of Columbia.

If these Terms of Use are not accepted in full, the use of this site must be terminated immediately.

We will add a link to our Cookies Policy here.

We will update this date when we post on the website.

Per advice from ACA, we will create separate links on the efe.org home page: one titled “Privacy Policy” another titled “Terms of Use”. This way the privacy policy is in a clear and transparent location, like required by the GDPR.

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