This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer. Please refer to the list of categories of personal information above which we may collect or may have been collected from California residents within the last twelve (12) months.
Sources of Personal Information
We obtain the categories of personal information listed above from the categories of sources listed in the Privacy Policy above.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples
We use advertising services, including Google Customer Match and Enhanced Conversions, to deliver relevant ads and measure campaign effectiveness. To do this, we share hashed identifiers (such as email addresses, phone numbers, and postal addresses) with Google to match our customers with Google accounts.
We use cookies, pixel tags, and similar tracking technologies on our websites. These technologies may collect or receive information about your device and interactions with our websites, including IP address, browser information, pages viewed, and interaction data, and may allow third‑party partners to receive such information, to operate our websites, measure performance, and deliver advertising or to support marketing campaigns, including postal or direct mail marketing.
To operate our Service and provide You with our Service.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, 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.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "How Do We Use Your Personal Data" section.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Category A: Identifiers, such as hashed email addresses, phone numbers, and postal addresses; commercial information related to transactions; and online activity data used for ad matching.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose personal information for a business purpose or a commercial 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.
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit, including for cross‑context behavioral advertising.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
Category A: Identifiers, such as hashed email addresses, phone numbers, IP addresses and postal addresses; commercial information related to transactions; and online activity data used for ad matching.
Category D: Commercial information
Category F: Internet or other similar network activity
Category G: Geolocation data
This sharing may be considered a ‘sale’ or ‘share’ under California law because we receive value in the form of improved advertising performance.
Share of Personal Information
We may share Your personal information identified in the above categories with the following categories of third parties:
Service Providers, including advertising partners such as Google, who use this information for conversion tracking and ad targeting
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services we provide to You.
Sale of Personal Information of Minors Under 16 Years of Age
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 between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Consent and Control for Tracking Technologies
Where required under California law, non‑essential Tracking Technologies (including advertising and cross‑context behavioral advertising technologies) are not deployed until you have been provided with notice and an opportunity to exercise your choices. You may control the use of Tracking Technologies through:
our cookie or privacy preference tools available on our websites;
browser‑level signals (including Global Privacy Control, described below); and
other opt‑out mechanisms we make available.
Your Rights under the CCPA
If you are a California resident, the California Consumer Protection Act (“CCPA”) provides you with the following specific rights regarding your personal information that is subject to this Privacy Policy and this section explains how to exercise those rights.
The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to say no to the sale or share of Personal Data (opt-out). You have the right to direct us to not sell or share your personal information, including use for cross‑context behavioral advertising or postal or direct mail marketing.
You may exercise your opt-out rights by:
following the opt‑out instructions available on our websites or in applicable cookie or privacy preference tools; or
Where required by applicable law, we also treat browser‑enabled Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information.
Access to Specific Information and Data Portability Rights. California residents 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 verified consumer request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting that personal information; (iv) the categories of third parties with whom we share that personal information; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing any sales (identifying the personal information categories that each category of recipient purchased) and disclosures for a business purpose (identifying the personal information categories that each category of recipient obtained).
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 verified consumer request, we will delete (and direct any service providers to delete) your personal information from our records unless an exception applies, which may include but is not limited to information needed: (i) to 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, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) enable solely internal uses that are reasonable aligned with consumer expectations based on your relationship with us; (iv) comply with a legal obligation; and (v) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Under California Civil Code Section 1798.83, California residents have the right to request and receive from us, once per year and free of charge, information about the personal information we have disclosed (if any) to third parties for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to deletemydata@ef.com including the phrase “California Privacy Request” in the subject line, and provide us with your name, postal address and email address.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights above, please submit a verifiable consumer request to us by either:
Calling us at 1.800.665.5364
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verified 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: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us properly to understand, evaluate, and respond to it. We cannot response 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 a request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within 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. 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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without issue. 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.
Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.
