, a company incorporated under the laws of India (referred to herein as "efello," "we," "us" and "our"), understands the importance of the privacy of individuals (referred to as "users" and "you") who visit and interact with our websites. This Security and Privacy Statement (the "Statement") outlines the information efello.com collects through this website (the "efello.com WEBSITE"), and how efello.com will use and disclose that information. This Statement represents the sole, authorized statement of efello.com's practices with respect to the collection of information through the efello.com WEBSITE and efello.com's use of such information. By using the efello.com WEBSITE, you agree to this Statement. If you do not agree to this Statement, please do not use the efello.com WEBSITE.
This Statement applies solely to efello.com's collection of information through the efello.com WEBSITE and efello.com's use and disclosure of such information. This Statement does not apply to any of the following: (a) efello.com's collection of information through any website other than the efello.com WEBSITE, or the use or disclosure of any information so collected; (b) efello.com's collection of information offline, for example, by telephone or direct mail, or the use or disclosure of any information so collected; or (c) the collection, use or disclosure of information by any of our subsidiaries or affiliated entities or any third party.
2. CHANGES TO THIS STATEMENT
Because our business changes continually, we may change this Statement from time to time. Any changes to this Statement will become effective upon posting of the revised Statement on the efello.com WEBSITE. Your continued use of the efello.com WEBSITE following the posting of changes to our Statement will signify your acceptance of those changes.
3. THE INFORMATION WE COLLECT
We collect three basic types of information through the efello.com WEBSITE: Personally Identifiable Information, Non-Personally Identifiable Information and IP Addresses. "Personally Identifiable Information" (or "PII") is information that identifies you as an individual — for example, your name, address, telephone number, email address and any government issued personal identification number. "Non-Personally Identifiable Information" (or "Non-PII") is aggregated information, demographic information and any other information that does not reveal your specific identity. An "IP Address" is the Internet Protocol address of the computer that you are using.
a. PERSONALLY IDENTIFIABLE INFORMATION (PII).
You do not have to provide PII to access the efello.com WEBSITE. However, in order for you to take advantage of particular opportunities provided through the efello.com WEBSITE (for example, to sign up to receive efello.com email newsletters), we may require that you furnish us with PII through the efello.com WEBSITE. efello.com will collect PII from you through the efello.com WEBSITE only when you provide it to us voluntarily. By submitting PII to efello.com, you consent to the collection, use, processing and disclosure of PII as set forth in this Statement.
b. NON-PERSONALLY IDENTIFIABLE INFORMATION (NON-PII).
When you visit and interact with the efello.com WEBSITE, we and our Service Providers (as such term is defined below) may collect Non-PII (for example, a list of the efello.com WEBSITE pages you visit). Non-PII is generally collected from four different sources: environmental variables, cookies, pixel tags, and information that you voluntarily provide.
• ENVIRONMENTAL VARIABLES.
We and our Service Providers may collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.
• PIXEL TAGS.
We and our Service Providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some efello.com WEBSITE pages and HTML-formatted email messages to, among other things, compile aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on 'visitors' hard drives. Pixel Tags allow us and our Service Providers to count users who have visited certain pages of the efello.com WEBSITE, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.
• OTHER NON-PERSONALLY IDENTIFIABLE INFORMATION THAT YOU VOLUNTARILY PROVIDE.
We also collect certain Non-PII — for example, your geographic location — when you voluntarily provide such information to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the efello.com WEBSITE, for example, by using PII to calculate the percentage of our users who have a particular zip code or telephone area code. Such aggregate information is deemed to be Non-PII for purposes of this Statement.
c. IP ADDRESSES
An Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our and/or our Service Providers' server log files whenever users visit the efello.com WEBSITE, along with the time(s) of such visits and the pages that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.
4. HOW DO WE USE THE PII WE COLLECT?
Please note that efello.com will share your information with efello.com Products, Inc. which will jointly use such PII you provide through the Site. efello.com will remain responsible for the PII we collect. We may use the PII we collect in the following ways:
• RESPONDING TO YOUR INQUIRIES AND FULFILLING YOUR REQUESTS
We may use PII about you to respond to your inquiries to efello.com and to fulfill your requests — for example, to send you newsletters that you request when you sign up to join our mailing lists, to send you updates about efello.com news and events, to send you information on or contact you about becoming an independent sales representative (an "efello.com Independent Sales Representative") or to provide PII about you to efello.com Independent Sales Representatives when you provide it to us for that reason.
• COMMUNICATING WITH YOU ABOUT PRODUCTS AND SERVICES
If you choose to opt-in, we may use PII about you to send you information about specials, new products and services, and other items that may be of interest to you. If you wish to opt-out of receiving such communications, please see Section 10 (Opt-Out) below.
• PERSONALIZING YOUR efello.com WEBSITE EXPERIENCE
We may use PII about you to personalize your experience as on the efello.com WEBSITE.
• SENDING ADMINISTRATIVE COMMUNICATIONS
From time to time, at our sole discretion, we may use PII about you (a) to confirm a transaction through the efello.com WEBSITE, (b) to inform you that we have received PII about you, and/or (c) to provide you with information regarding the efello.com WEBSITE ("Administrative Messages"). Because this information may be critical to your use of the efello.com WEBSITE, you may not opt out of receiving Administrative Messages.
• INTERNAL BUSINESS PURPOSES
We may use PII about you for internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
5. HOW IS THE PII WE COLLECT DISCLOSED?
We may disclose the PII we collect in the following ways:
• DISCLOSURE TO SERVICE PROVIDERS
We may share PII about you with our third party and affiliated service providers who provide certain services (including without limitation website hosting, data analysis, order fulfillment, auditors, accountants, other professional advisors and other similar services) (collectively, our “Service Providers”) for the purpose of enabling them to provide services. We seek to require our Service Providers to treat PII confidentially.
• DISCLOSURE TO THIRD PARTIES FOR DIRECT MARKETING PURPOSES
We may disclose PII about you to third parties for their direct marketing purposes when you affirmatively consent to such disclosure. For example:
• Disclosing PII about You to efello.com Independent Sales Representatives:
If you wish to order products through an efello.com Independent Sales Representative or to otherwise have an efello.com Independent Sales Representative work with you to facilitate your efello.com experience, efello.com needs to provide PII about you to such efello.com Independent Sales Representative. Therefore, if you opt in to having an efello.com Independent Sales Representative work with you to facilitate your efello.com experience or to having PII about you shared with an efello.com Independent Sales Representative, we may disclose PII about you to such efello.com Independent Sales Representative. Such efello.com Independent Sales Representatives may use PII about you for direct marketing purposes. We do not control, and are not responsible or liable for, the use of PII about you by such efello.com Independent Sales Representatives.
• Facilitating Special Offers from Third Parties
From time to time, we may give you the opportunity to opt in to participate in special third party offers that require us to share certain PII with such third parties. We will disclose this anticipated sharing of PII at the time we make such opportunities available to you. If you opt in to participate in such an offer, we may disclose PII about you to such third parties for their direct marketing purposes. We recommend that you consult such third parties' privacy policies in advance if you wish to participate in these offers.
• FACILITATING SWEEPSTAKES, CONTESTS AND SIMILAR PROMOTIONS.
We may, whether alone or in cooperation with third party sponsors, operate sweepstakes, contests and similar promotions ("Promotions") through or in connection with the efello.com WEBSITE. We typically ask you for certain PII when you enter or otherwise participate in a Promotion, and, if applicable, when you win a Promotion. We reserve the right to share this PII with affiliated and third party sponsors of such Promotions ("Sponsors"), or otherwise in accordance with the rules applicable to the Promotion. You should carefully review the rules of each Promotion in which you participate through the efello.com WEBSITE, as they may contain important additional information about our or Sponsors' use of your PII. To the extent that the terms and conditions of such rules concerning the treatment of your PII conflict with this Statement, the terms and conditions of such rules shall control.
• FACILITATING "EMAIL A FRIEND" FUNCTIONALITY
If you wish to use the efello.com WEBSITE's functionality to send a friend a link to an efello.com WEBSITE page (e.g., by utilizing the “Send an ECard” functionality), you must provide us with your name and email address, as well as your friend's name and email address, so that we may facilitate your sending of such link. Your name and your email address will be disclosed to your friend in such email. By using this functionality, you affirm that you are entitled to use and provide us with your friend's name and email address for this purpose. We will not to use your friend’s PII for any other purpose other than to allow the email to be sent, unless we disclose such other purpose to you at the time you provide such PII to us.
• BUSINESS TRANSFERS
In the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of efello.com's assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all PII and Non-PII that we collect through the efello.com WEBSITE to a third party or an affiliated entity.
• OTHER DISCLOSURES
We may disclose PII about you to others if we believe we are required to do so: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process; (c) to respond to request from government or public authorities including from government or public authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any affiliates; (f) to protect the rights, privacy, safety or property of efello.com, our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
• CROSS BORDER TRANSFERS
To help us perform more effectively and efficiently in the future, we may need to transfer PII about you to affiliates and Service Providers located in other countries, including the United States. By using the efello.com WEBSITE, you agree to such transfers of PII about you.
6. HOW DO WE USE AND DISCLOSE THE NON-PII WE COLLECT?
Because Non-PII does not personally identify you, we reserve the right to use Non-PII, and to disclose Non-PII to third parties, for any purpose.
7. HOW DO WE USE AND DISCLOSE THE IP ADDRESSES WE COLLECT?
We use IP Addresses for purposes such as calculating usage levels on the efello.com WEBSITE, helping diagnose server problems, and administering the efello.com WEBSITE. We may use IP Addresses to communicate with users and, if necessary, to block access by users who fail to comply with our Terms and Conditions of Use located at the bottom of home page of the efello.com WEBSITE (the "Terms and Conditions of Use") or other policies. We may also use and disclose IP Addresses in accordance with Sections 4 and 5 above. Please note that we treat IP Addresses, server log files and related information as Non-PII, except where we are required to do otherwise under applicable law.s
8. COLLECTION, USE AND DISCLOSURE OF INFORMATION BY THIRD PARTIES. NOTE THAT THIS STATEMENT DOES NOT ADDRESS THE PRIVACY PRACTICES OR POLICIES OF THIRD PARTIES, INCLUDING efello.com INDEPENDENT SALES REPRESENTATIVES.
Without limiting the foregoing:
a. efello.com INDEPENDENT SALES REPRESENTATIVES
This Statement does not apply to the collection, use or disclosure of information by efello.com Independent Sales Representatives, who are independent third party contractors of efello.com and are not otherwise affiliated with efello.com. For example, this Statement does not apply to: (a) the use or disclosure by efello.com Independent Sales Representatives of information efello.com provides them to enable them to fulfill your orders; (b) the use or disclosure of information collected, stored or processed by efello.com Independent Sales Representatives through the efello.com WEBSITE; or (c) any communication between you and an efello.com Independent Sales Representative, either directly (for example, through your personal email) or through or in connection with an efello.com WEBSITE (for example, through a "mailto:" email link that launches an external email application, or through a "Contact Me" link that takes you to an online contact form), or the use or disclosure of any information exchanged through such communication. Although we seek to ensure that efello.com Independent Sales Representatives honor customers' and contacts' opt-out requests, treat customer information confidentially and act in accordance with applicable law, we are not responsible or liable for the statements, acts or omissions of efello.com Independent Sales Representatives.
b. OPERATORS OF THIRD PARTY SITES AND SERVICES
The efello.com WEBSITE may contain links to websites operated by third parties, or may embed services operated by third parties ("Third Party Sites/Services"), and those third parties may have privacy practices that are different from ours. If you provide information through any Third Party Site/Service, such information will be collected by, and may be used and disclosed by such third parties, in accordance with the privacy practices and policies of such third parties. efello.com WEBSITE users should consult such third parties' privacy policies when using Third Party Sites/Services, as we have no control over the use or disclosure of information by third parties.
We are aware of concerns regarding the privacy and confidentiality of PII. We have put in place certain physical, electronic and managerial procedures to help us safeguard against unauthorized access to PII and to help maintain data security. For example, we use an encryption technology called Secure Sockets Layer (SSL) to help protect the transmission of certain information to and from the efello.com WEBSITE. Unfortunately, no data transmission over the Internet or data storage solution will be 100% secure. If you have reason to believe that your interaction with an efello.com WEBSITE is no longer secure, you must immediately notify us of the problem by contacting us in accordance with the section entitled "CONTACTING US," below. (Note that contacting us by physical mail will delay the time it takes for us to respond to your communication.)
10. OPT OUT
If you no longer wish to receive marketing-related e-mails from efello.com on a going-forward basis, you may opt-out of receiving such marketing-related e-mails in a going-forward basis by contacting us at firstname.lastname@example.org. We will endeavor to comply with your request as soon as reasonably practicable.
11. CHANGING OR SUPPRESSING PII ABOUT YOU
We provide you with several options for reviewing, correcting, updating, suppressing or otherwise modifying PII that you have previously provided to efello.com through the efello.com WEBSITE. You can request to review, correct, update or suppress PII about you by contacting us as set forth below: A-5/340 Paschim Vihar, New Delhi-110063,INDIA. We will endeavor to comply with your requests to change, modify or suppress PII about you as soon as reasonably practicable. However, we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. Finally, we are not responsible for removing information or causing information to be removed from the databases or other records of third parties (including Sponsors, Service Providers and efello.com Independent Sales Representatives) with whom we have already shared PII about you.
The efello.com WEBSITE is not directed to minors, and we request that such individuals not provide personally identifiable information, or PII, through the efello.com WEBSITE.
efello.com does not represent or warrant that the efello.com WEBSITE, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the efello.com WEBSITE do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the efello.com WEBSITE's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
14. Retention Period
We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required by law.
15. CONTACTING US
If you have any questions regarding this Statement, please contact us either by email at email@example.com , or by regular mail at
Please note that email communications are not necessarily secure. Accordingly, you should not include credit card information or other sensitive information in your email correspondence with us.