Effective Date: Nov. 1, 2018
- What information we collect about you
- How we use your information
- When and with whom we share your information
- How long we retain your information
- Cookies policy and other tracking technologies
- Third-party advertising and analytics
- Your Rights
- California Privacy Rights
What Information We Collect
1. Information You Provide to Us Directly
ELFA may collect different information from or about you depending on the manner in which you use our website. The following examples are provided to help you better understand the information We may collect through your use of the equipmentfinanceadvantage.org website. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We will collect any information you provide to us directly such as the following:
In order to use certain features of the ELFA website, such as creating a profile, purchasing a publication or registering for a meeting, you are required to create an Account, and in that case, we will collect and store any personal information you provided to us, such as first name, last name, company name, company address, phone, fax, e-mail address, payment and billing information, and credit card information.
Information Received Through Third-Party Platforms:
You may access equipmentfinanceadvantage.org through Third-Party Platforms, such as Facebook. If you use our ELFA website on or through a Third-Party Platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the ELFA website will also be subject to the privacy policies and other terms of such third parties or Third-Party Platforms. You should review such privacy policies, terms, and other agreements.
2. Information We Collect Through Automated Means
Technical and Usage Data
When you access the ELFA website, we collect certain information by automated means. This information may include without limitation: (a) technical information about your computer or Wireless Device, such as Your IP address, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information, platform types (collectively, “Technical Information”); and (b) usage statistics about your interaction with the E:FA website, including pages accessed, time spent on pages, pages visited, search queries, click data, date and time, and other information regarding your use of the ELFA website (collectively, “Usage Data”).
Geolocation Information: IP addresses received from your browser or device may be used to determine your approximate location, such as the city, state and/or country associated with an IP address.
How We Use Your Information
We may use information about you for a number of purposes, including:
Providing, Improving, and Developing Our Services
- Reviewing and analyzing user browser and wireless device technical information;
- Reviewing user activity across equipmentfinanceadvantage.org (for example, ELFA analyzes trends and user traffic and usage information to identify determine the performance of content, research reports or events);
- Processing or recording payment transactions or money transfers;
- Otherwise providing you with the ELFA products and features you choose to use;
- Displaying your historical transaction or appointment information;
- Providing, maintaining, and improving our Services;
- Developing new products and Services;
- Delivering the information and support you request, including digital receipts, invoices, and scheduling information;
- Improving, personalizing, and facilitating your use of our Services;
- Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services.
Communicating with You About Our Services
- Responding to questions or concerns;
- Sending you information we think you may find useful or which you have requested from us about our products, services and the industry we serve;
- Sending push notifications to your desktop or wireless device to provide updates on relevant resources and content, which can be managed through your computer or smartphone browser;
- Manage your account preferences, establish your profile and registration information;
- Conducting surveys and collecting feedback about our industry and Services.
Protecting our Services and Maintaining a Trusted Environment
- Enforcing our Terms of Service or other applicable agreements or policies;
- Verifying your identity;
- Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
- Fulfilling any other purpose disclosed to you in connection with our Services;
- Analyze trends and user traffic, track purchases and usage information;
- Contacting you to resolve disputes and provide assistance with our Services.
Advertising and Marketing
- Marketing of our Services, events, research and products;
- Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners;
- If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications.
- If we obtain any Personal Information from you we will not sell it to third parties. It may be used internally as part of special merchandising and promotion programs and we may disclose non-personally identifiable compilations of information to third parties for marketing-related purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us. To learn about your choices regarding interest-based advertising and cross-device tracking, please see below.
- If you provide ELFA with your contact information to receive receipts via email, we may store the email address or phone number you provide. We use your email address or phone number to send you a receipt for your purchase. Digital receipts may contain additional messages, offers, or links that may be of interest to you. For example, you may be able to submit feedback, or visit websites.
If you wish to opt out of receiving automatic digital receipts or change your preferences, please see below.
- For any other purpose disclosed to you in connection with our Services from time to time.
When and With Whom We Share Your Information
When and How We May Share/Disclose Your Information with Third Parties
Third-party companies that perform services on our behalf may collect and store personal information you provide, such as first name, last name, company name, company address, phone, fax, e-mail address, payment and billing information, and credit card information. We may use third-party services for transactions such as payment processing, order fulfillment, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), e-mail and hosting services (including the QuickBrief e-newsletter), and customer services and support. These third-party service providers may access your personal information and are required to use it solely as directed by us for the purpose of our requested service.
We require all third parties to respect the security of your personal data. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In addition, attendees at ELFA events authorize ELFA to share your contact information, including but not limited to email address and telephone number, with other registered attendees, sponsors and exhibitors.
Analytics and Data Enrichment Services
We use third-party analytics such as Google Analytics to help understand your usage of our services and to improve our Services.
Aggregate or De-identified Information
We may disclose or use aggregate or de-identified information for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity.
Social Media Features
How Long We Retain Your Information
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law, and in accordance with our document retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies, or to take any other actions consistent with applicable law.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows ELFA to keep the transaction or engagement data. For example, ELFA will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow ELFA to maintain a level of information that helps us develop and improve our products and services.
Cookies Policy and Other Tracking Technologies
Like many online platforms, ELFA and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable ELFA to understand how Users interact with the ELFA services. ELFA and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.
Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. ELFA uses both session cookies and persistent cookies.
A session cookie is used to identify a particular visit to the ELFA services and collect information about interaction with the ELFA service. These cookies expire after a short time, or when the user closes their web browser after using the ELFA service. ELFA uses these cookies to identify a user during a single browsing session, such as when you log into the ELFA services. This helps ELFA improve the Service as well as improve the Users’ browsing experience.
A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. ELFA uses these cookies to identify and recognize a specific user over a longer period of time. They allow ELFA to:
- analyze the usage of the ELFA services (e.g. what links users click on) in order to improve our offering
- test different versions of the ELFA services to see which particular features or content users prefer to optimize the ELFA services
- provide a more personalized experience to users with more relevant content and course recommendations and
- allow users to more easily log in to use the ELFA services. Persistent cookies include: preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language. Preference cookies make user experience more functional and customized authentication and security cookies to enable a user to log in or stay logged in and access the ELFA service, to protect user accounts against fraudulent log-ins by others, and help detect, and protect against abuse or unauthorized usage of user accounts.
- functional cookies to make the experience of using the ELFA service better, like remembering the sound volume level selected by the user.
- ELFA uses tracking technology to: (i) determine if a certain page was visited or whether an email sent by ELFA was opened or clicked on by a user; and (ii) to customize the learning experience of individual users by recommending specific courses and other content.
ELFA will retain the data of users for as long as instructed by the Customer. ELFA will delete certain or all personal data relating to users upon request of the Customer. ELFA may retain aggregated or anonymized data as set forth below.
|Cookie Name||Used By||Description||Expiration|
|__utma||Google Analytics||Older version of GA tracking cookies||2 years|
|__utmb||Google Analytics||Older version of GA tracking cookies||1 day|
|__utmc||Google Analytics||Older version of GA tracking cookies||Session|
|__utmt||Google Analytics||Older version of GA tracking cookies||1 day|
|__utmz||Google Analytics||Older version of GA tracking cookies||~6 months|
|VISITOR_INFO1_LIVE||YouTube||Used and controlled by YouTube||~6 months|
|YSC||YouTube||Used and controlled by YouTube||Session|
|GPS||YouTube||Used and controlled by YouTube||~30 minutes|
|IDE||YouTube||Used and controlled by YouTube||2 years|
|STPC||ShareThis||came up when I clicked share icon with value of "yes"||2 days|
User Preferences with respect to cookies and other tracking technologies
A user can set his or her web browser to notify about the placement of new cookies, limit the type of cookies or reject cookies altogether; if enabled, a user may not be able to use some or all of the features of the ELFA services (for example, may not be able to log in). General information about cookies and how to disable them can be found at www.allaboutcookies.org.
Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.
THIRD-PARTY ADVERTISING AND ANALYTICS
Examples of our third-party service providers to help deliver our Services or to connect to our Services include:
- Google Analytics: We use Google Analytics to understand how our Services perform and how you use them. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout.
- Clear Vantage by Euclid: Clear Vantage is ELFA’s Association Management Software (AMS) and is used to collect and store membership and contact details, event registration, store purchases and details about your interactions with ELFA so we can better serve our members and industry stakeholders.
Under certain circumstances, you have rights in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us. You have the right to:
You may access, change, or correct information that you have provided by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Do Not Track
You may opt out of receiving promotional messages from ELFA, if those messages, are powered by ELFA, by following the instructions in those messages. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we can still send you non-promotional communications, such as digital receipts that you request.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.
CALIFORNIA PRIVACY RIGHTS
California law permits residents of California to request certain details about our disclosure of your personal information by us to third parties for direct marketing purposes during the immediately preceding calendar year. If you are a California resident and would like to request this information, please contact us using the listing below.
Please contact ELFA with any questions or concerns regarding this Privacy Notice.
Equipment Leasing and Finance Association
Attn: Paul Stilp
1625 Eye St NW, Suite 850
Washington, DC 20006
Email: firstname.lastname@example.org or email@example.com
If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with ELFA using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.