PRIVACY POLICY

Effective Date: April 30, 2024

Privacy is important to EIF Book Fund (“EIF”). The following describes the information we collect and the ways we use that information. By using EIF (the “Website”) and engaging with our services and products (collectively, the “Services”), you are consenting to the collection, use, sharing, and storage of your personal information, as described below. This Privacy Policy supplements and is incorporated into our Terms and Conditions which, together with this Privacy Policy and our other online policies, govern your use of the Services. We have endeavored to make this Privacy Policy as clear as possible. If, however, you have any questions, comments or concerns about this Privacy Policy, please send us an email at [email protected].

The terms “EIF” or “us” or “we” or “our” refer to EIF, the owner of the Services. The terms “you” or “your” refer to the user or viewer of the Services.

Information We Collect. We collect information from those who visit and interact with our Services. This information may include: full name, email address, physical address, phone number, usernames for other internet messaging platforms, interests, comments, requests, and other information you may offer.

The categories of personal information we collect depend on whether you are a visitor, opt-in participant, or contest entrant and the requirements of then-applicable law (collectively, “Personal Information”). We may also automatically collect other information as you interact with the Services.

We may collect and maintain device, browser, and operating system information, your Internet Protocol (“IP”) address, Services visits, page response times, download errors, length of visits to certain pages, and page interaction information (such as swipes, share lists, and recommendations). We also may automatically collect information from cookies that are placed throughout the Services. Generally, this information is collected in aggregate form, which means we cannot personally identify you through these mechanisms. The above information may also be collected by third-party service providers, such as Cloudflare, First Direct, Inc., or any other third party. We collect certain information using the following technologies: ·      

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. ·      

• “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. ·      

• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

  
  How do we use your personal information? We use this information to facilitate the provision of your requested services, such as to fulfill orders or enter contests. We also use this information to track user behavior, improve our products and services, communicate with you regarding the Services, and generate statistics and trend data for internal and external business purposes, such as marketing campaigns and social media advertising.

  Sharing your Personal Information. We do not share your information for commercial purposes. However, we may share your information in the following ways: ·      

• With service providers: We may share your information with third parties that perform tasks on our behalf and that help us better provide our Services to you.

• To protect us, our users, or to law enforcement officials: We may share your information to comply with legal processes (including to comply with the law, to enforce our Terms and Conditions, or to respond to subpoenas, discovery requests, or similar legal processes or proceedings), cooperate with law enforcement or when we believe it is prudent to share information with legal authorities, and investigate and prevent fraud or imminent harm to you, our users, or to us. We may also share your information to ensure the security of our network and services.

• In the event of a business transfer: We may share your information with another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy or we go out of business. User information is generally considered an asset that is transferred in one of these types of corporate transactions.

• With your consent: We may also share your information in other circumstances when we have obtained your consent.

  Consent to Data Processing in the United States. Whether you are a resident of the United States, the European Economic Area, or any other global jurisdiction, we may send and store your personal information outside of the country in which you reside. We currently store your data in the United States. By using our Services and consenting to this Privacy Policy, you agree and hereby consent to the storage and processing of your Personal Data in the United States.

  Third Parties. Your information may be held by third parties or we may link to other sites or applications not affiliated, owned, or controlled by us. When you click on a link or an advertisement, you will be directed to that third party’s website. The fact that we link to a third party’s website or advertisement does not in any way create a relationship between us and that third party. We do not endorse or represent any third parties. The privacy practices of any third parties are outside the scope of this Privacy Policy and their use or disclosure of your information (including your personal information) will be governed by their own privacy practices or policies. We encourage you to review the privacy practices or policies of those third parties.

  Behavioral Advertising. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

  Google Analytics and Advertising. We use Google Analytics to better understand how users interact with the Website. For information on Google Analytics’ information handling practices and how you can control the use of information sent to Google, please visit: www.google.com/policies/privacy/partners/. To disable Google Analytics, please download and install the Google Analytics Opt-out Browser Add-On, which is available here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick or Google Dynamic Remarketing advertising cookie) together to inform, optimize, and display advertisements based on your past visits to the Website. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at: https://google.com/ads/preferences or by visiting the NAI opt-out tool linked to above.

  Do not track. Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

  Your Rights. If you would like to access, modify, or delete your personal information, you may submit a request to [email protected]. For more information or to see if these rights apply to you, please contact us. We will promptly review all such requests in accordance with applicable laws. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order or enter a contest through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

  Data Retention. When you place an order or enter a contest through the Site, we will maintain your order or contest-related information, including all provided Personal Information, for our records unless and until you ask us to delete this information.

  Security. The security of your information is important to us. We maintain various safeguards in order to keep your personal information safe. We always strive to do our best to protect your information, but we cannot guarantee that your information will always be secure. However, you can play your part in ensuring your information remains secure. You should never disclose your login credentials or personal information to anyone else, and you should keep such information in a safe and confidential manner. You should also adopt passwords that are hard to decipher and be sure to log out of your account whenever it is not being used by you. We will notify you, by email or through the Services, if we believe your information has been breached. Such notification will be made to you as soon as practically possible given our need to determine the scope of such breach and to comply with the needs of law enforcement. Please note that you transmit your personal information at your own risk and that we are not responsible for any deliberate or accidental circumvention of our privacy and security measures.

  Children’s Online Privacy Protection Act. The Services are intended for general audiences and are not directed to children under 13 years old. We do not target the Services to children under 13, and we do not intentionally collect any information from users under 13. If you become aware that your child has used the Services, and we may have personal information about a user under 13, please contact us at [email protected], so we may delete the information.

  Cookies. Cookies are small bits of electronic information that a website or application sends to your browser and are stored on your hard drive. We use cookies to identify users, track your behavior on the Website, keep the Services secure, and improve the Services’ performance. Some cookies are necessary in order to use the Services, and these cannot be disabled. Other cookies are not required to browse our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings, which can be done through your browser’s settings. Third-party services, such as Shopify, may employ cookies on the Services in order to better perform their services. We have no control over third-party cookies, and therefore, disclaim any and all liability related to third-party cookies.

  Supplemental Privacy Rights. If you are a California, Colorado, Connecticut, or Nevada resident, the law may provide you with additional rights regarding our use of your Personal Information. Please review our U.S. Supplemental Privacy Policy carefully to learn more about these rights. If you are a resident of the European Union, please review our EU Supplemental Privacy Policy (to be posted subsequently with these Terms and Conditions) carefully to learn more about these rights.

  Appealing Privacy Rights Decisions. Depending on your U.S. state or other residency, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact [email protected]. If you are unsatisfied with the way that we have handled your appeal, you may have the right to complain to your state’s Attorney General or your other jurisdiction’s official with analogous authority.

  Changes and Updates to Privacy Policy. This Privacy Policy may be revised periodically, and this will be reflected by the date above. Please revisit this page to stay aware of any changes. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions.

  Contact Information. If you have any questions or concerns about this Privacy Policy, please contact us by email at the following address: [email protected].

U.S. Supplemental Privacy Policy

Updated as of: April 30, 2024

This U.S. Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers in the following states: (1) California, (2) Colorado, (3) Connecticut, and (4) Nevada. This Supplemental Notice describes EIF’s (“we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. This Supplemental Notice is in addition to, and incorporated into, our Privacy Policy.

Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

To the extent terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a California consumer, terms used in this Supplemental Notice that are defined terms in the CCPA shall have the meanings afforded to them in the CCPA as this Supplemental Notice applies to you.

California Privacy Rights Act. In addition to the rights provided by the CCPA, California residents are provided with the following rights through the California Privacy Rights Act: (i) the right to request that incorrect or outdated personal information be corrected but not deleted; (ii) the right to restrict a business’s ability to process sensitive data about the consumer; and (iii) prohibition against a business making decisions about a consumer based solely on an automated process without human input.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.

Supplemental Notice for Colorado Residents. The Colorado Privacy Act provides Colorado residents with the following rights: (i) the right to opt out of the processing of personal data concerning the consumer; (ii) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (iii) the right to correct inaccurate personal data collected from the consumer; (iv) the right to delete personal data concerning the consumer; (v) the right to restrict a business’s ability to process personal information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes; (vi) a prohibition against a business making certain decisions about a consumer based solely on an automated process without human input; and (vii) the right to data portability. When exercising the right to access personal data, a consumer has the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance. A consumer may exercise this right no more than two times per calendar year.

Supplemental Notice for Connecticut Residents. The Connecticut Data Privacy Act provides Connecticut residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (ii) the right to request that incorrect or outdated personal information be corrected but not deleted; (iii) the right to delete personal data concerning the consumer; (iv) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (v) the right to request personal information about the consumer be disclosed in a common file format; (vi) the right to opt out of the sale of personal information about the consumer to third parties; and (vii) prohibition against a business making certain decisions about a consumer based solely on an automated process without human input.

Supplemental Notice for Nevada Residents. We generally do not disclose or share personal information for profit. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To exercise this right, if applicable, you or your authorized representative may submit a request to [email protected]. If you have any questions, please contact us at [email protected]. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Disclosure for Colorado and Connecticut Consumers: Unless specifically stated, we do not sell or share Personal Information to third parties for their own use. However, we may share or process one or more of the above categories of personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.

Supplemental Notice for California Residents. This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information EIF has collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

Disclosure for California Consumers: Unless specifically stated, we have not sold or shared Personal Information about California consumers to third parties for their own use in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. However, we may share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions. That said, we may share information with third-party advertising partners or analytics providers for the purpose of promoting our Services as described above, including for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your personal information shared with such advertising partners or analytics providers by emailing us here: [email protected]. For purposes of California law, a “sale” is the disclosure of Personal Information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

The following chart details which categories of personal information we have collected from and about California residents in the past twelve (12) months, the source(s) of each category of information, the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties to whom we have “sold” or with whom we have “shared” each category of information (as such terms are defined in the CCPA) (where applicable). Please note that the first column in the chart lists by category the types of information described in the “Collection of Personal Information” section above, as required by the CCPA.