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Privacy Policy

This privacy policy discloses the privacy practices for Equipment Leasing Association of America, Inc. ("ELFA") for the website at www.elfaonline.org (the "site"). This privacy policy does not cover information ELFA collects by means other than the site. If you have any questions about the uses ELFA makes of information collected by means other than the site, you should inquire at or before the time you give such information to ELFA.

Note that this policy contains several important exceptions, most notably the exception involving use of information to identify and/or pursue persons who are under criminal investigation or who damage, or may damage, ELFA's information or other resources. Please read the entire privacy policy to be sure that you understand these exceptions.

Information Ownership, Collection and Use

ELFA is the sole owner of the information collected on this site. It will not sell, share, or rent this information to others in ways different from those disclosed in this policy. ELFA collects information from its users at several different points on the site.

Registration

In order to use this certain portions of the site, a user must first complete a registration form. During registration each user is required to give its contact information (such as name and e-mail address and possibly additional information). This information is used to contact the user about the services on the site in which the user has expressed interest. Under certain circumstances, it is optional for the user to provide demographic information and unique identifiers, but ELFA encourages users to provide such information if requested so that it can provide a more personalized experience on the site. Where information is collected for purposes that include entry into a directory of members or others, ELFA may place such information in publicly-available directories and share such information with others, whether for compensation or otherwise.

Ordering, Event Registration and Related Processes

When users order products or services using the site or register for conferences or similar events, ELFA requests information from those users using an order form. When ELFA already has information about a user (such as through a previous order or registration), ELFA may use such information to facilitate the order or registration process. When using an order form, a user must provide contact information (such as name and shipping address) and financial information (such as credit card number and expiration date). This information is used for billing purposes and to fill users' orders. If ELFA has trouble processing an order, it uses this contact information to contact the user.

Cookies

A cookie is a piece of data stored on the user's hard drive containing information about the user or the session. The cookies ELFA uses are not linked to any personally identifiable information while on the site unless the user gives ELFA permission to link personally identifiable information to one or more cookies (whether through a registration process or otherwise). If the user has not given permission to link its personally identifiable information to a cookie, the cookie simply terminates when the user closes its browser.

Users may reject cookies by setting preferences in their browsers. Use the "help" feature of your browser to obtain more information about refusing cookies. Users who set their browsers to reject cookies can still use the site, but such users may not be able to use the site's full functionality or it may take additional time to utilize such functionality.

Some of the organizations with which ELFA does business, or to which ELFA provides links from the site, also use cookies. ELFA has no control over such organizations' uses of cookies and users should review the privacy policies of such organizations to determine the uses such organizations use cookies.

Log Files

ELFA or its hosting provider collects traffic information from visitors for statistical analysis and site improvement. When a user accesses the site, ELFA or its hosting provider collects information about the user's visit in a log file on the server. Log file information may include, but is not limited to, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. ELFA or its hosting provider uses this information to analyze trends, administer the site, track users' movements in the aggregate, and gather demographic information for aggregate use. IP addresses and other log file information are not linked to personally identifiable information.

Sharing

(a) Aggregated information. ELFA or its hosting provider may share aggregated demographic information with its users, its affiliated organizations and other organizations with which ELFA does business. Such information is aggregated and is not linked to any information that can identify individual users.

(b) Outsourcing providers. ELFA may use outside shipping or other outsourcing providers to process and ship orders. ELFA requires that these outsourcing providers not retain, share, store or use personally identifiable information for any secondary purposes, except for backup and recovery operations. Although ELFA makes good faith efforts to ensure compliance by its outsourcing providers, it cannot be responsible to users for misuse of personally identifiable information by such outsourcing providers.

(c) Specific services. ELFA may have agreements with other parties to provide specific services. When a user uses such services, ELFA may share personally identifiable information with such parties. In such cases, ELFA will use its good faith efforts to restrict the information provided to the information necessary for the provision of such services.

(d) General use. ELFA shares personally identifiable information (whether in return for compensation or otherwise) with various vendors, suppliers and advertisers. While ELFA uses good faith efforts to verify that such vendors, suppliers and advertisers promote products and services of interest to site users, ELFA cannot, and does not, endorse such vendors, suppliers, advertisers, products or services unless ELFA expressly states otherwise. ELFA shares only such information as users themselves provide to ELFA (such as through a registration process) and does not share personally identifiable information derived indirectly through IP address tracing or similar means. If you wish ELFA to refrain from providing your personally identifiable information in this manner, please see the opt-out information and contact information provided below.

Links and Information Gathered by Others

The site may contain links to other websites. ELFA does not operate these websites, cannot control the information that the operators of such websites gather or what the operators of such websites do with the information, and ELFA is therefore not responsible for the activities of the operators of such websites. This privacy policy only applies to information collected by ELFA.

Newsletter

If a user wishes to subscribe to a newsletter, ELFA collects from the user contact information necessary to send the newsletter to the user. This is usually limited to the user's name, company name, and e-mail address.

Surveys and Contests

From time to time, ELFA requests information from users through surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice as to whether to disclose this information. Information requested may include contact information and demographic information. ELFA will use such contact information to notify winners and award prizes. Survey information will be used for the purposes of monitoring or improving the use of the site and providing aggregated information for ELFA's own uses or to ELFA customers or other organizations.

Security

ELFA uses industry-standard encryption and security standards to protect sensitive information. Users can tell whether encryption is being used by noting the "locked" or other status indicators on their browsers. If a user's browser does not indicate that the session is secure (e.g. by displaying a key or other icon), the user should assume that the connection is not secure and that third parties may receive the information shared between ELFA and the user.

ELFA also uses commercially reasonable efforts to protect user information offline. All sensitive user information is maintained in ELFA's offices or at the facilities of ELFA's information technology provider(s). Only employees or agents who need the information to perform specific functions are granted access to personally identifiable information. ELFA uses reasonable efforts to assure that its employees are informed with regard to ELFA's security and privacy practices. When ELFA adds new policies or changes existing policies, it notifies affected employees.

Supplementation of Information

ELFA sometimes supplements the information it received from users with other information it receives from third party sources, such as credit card issuers or clearinghouses.

Special Offers

ELFA may send new customers or registered users a welcoming e-mail that may also verify password and username. ELFA occasionally sends newsletters or information about products, services, and special deals to users. Users may opt not to receive such informational communications by using the contact information below.

Site and Service Updates

ELFA also sends website and service announcement updates to users. Users are not able to un-subscribe or opt not to receive service announcements because such announcements contain important information about the services offered through the site.

Correcting or Updating Personal Information

If a user's personally identifiable information changes, or if a user no longer desires service, the user may contact ELFA using the contact information below and ELFA will accommodate all reasonable requests for such changes.

Choice/Opt-out

Users who no longer wish to receive newsletters or promotional materials or have their information provided to third parties may opt to not receive such communications or have information shared by contacting ELFA using the information below. ELFA will comply with such requests as soon as is commercially practicable. Such compliance may involve batch processing and other processes that take 30 days or longer.

To change your preference with regard to the way your information is treated, please send an e-mail to database@elfaonline.org.

Response Times

ELFA will use commercially reasonable efforts to timely make any changes you request. Many such changes are accomplished using batch processing (i.e. collecting a number of similar change requests and making all such changes at once), so the changes may not be immediately effective. If you require an immediate change to your personally identifiable information and are unable to make such a change using the available site resources, please contact ELFA using the information below.

Child Online Privacy Protection Act (COPPA) Compliance

The Child Online Privacy and Protection Act (COPPA) regulates collection of information from persons under the age of 13. It is the policy of ELFA to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable information through the site. If you are under the age of 18 and have already provided personally identifiable information through the site, please contact (or have your parent or guardian contact) ELFA immediately using the information below so that ELFA may remove such information from its files.

Changes to This Privacy Policy

If ELFA decides to change this privacy policy, it will post the changes on the site and/or other places it deems appropriate.

ELFA will use information in accordance with the privacy policy under which the information was collected.

If ELFA decides to use information about users in a manner different from that stated in the privacy policy in effect at the time of collection, ELFA will notify such users by e-mail if, and to the extent that, such users have provided their e-mail addresses. If you reply to such an e-mail within a reasonable time and request that ELFA not use your personally identifiable information in the proposed new manner, ELFA will honor your request, but ELFA reserves the right to suspend your access to all or part of the services offered through the site if you do so. If you do not reply to such an e-mail, or ELFA receives a reply of "undeliverable" or similar message from your last known e-mail address, in either case after a reasonable time, ELFA will use the information in the proposed new manner.

BY USING THIS WEBSITE, YOU AGREE TO THIS CHANGE PROCEDURE.

Exceptions

Notwithstanding anything else in this privacy policy to the contrary, ELFA may collect personally identifiable information and use such information in ways other than those described above if ELFA is required to do so by law or if ELFA deems it advisable in the course of assisting law enforcement activities or protecting its website(s) or other property.

Contact Information

If you feel that ELFA is not abiding by this privacy policy or if you have questions regarding the policy, you may contact ELFA's privacy liaison using the following information.

Privacy Liaison
Equipment Leasing and Finance Association
1825 K Street NW, Suite 900
Washington, DC 20006
E-mail: avogt@elfaonline.org
Telephone: 202.238.3400

If you (a) wish to begin or end receipt of newsletters or promotional information (b) wish to update your user information, or (c) wish to opt in or out of any other service offered through the site, please contact ELFA's membership personnel using the following information. Please be sure to include your name, company name, phone number and email address and your username (if applicable), but do not include any information regarding your password(s), if any.

Equipment Leasing and Finance Association
1825 K Street NW, Suite 900
Washington, DC 20006
E-mail: membership@elfaonline.org
Telephone: 202.238.3400