Privacy Statement

EFL Global LLC ("EFL", "we", "us" or "our") and its subsidiary and affiliated entities have created this privacy policy ("Policy) to demonstrate our firm commitment to protecting the personal information of our users ("you") and to inform you of our data collection, use and disclosure practices. This Policy addresses maintaining the privacy of personal information and data we collect.

The Policy describes our privacy practices in connection with your use of our website https://efl.global (the "Site") and the usage of our services (the "Services"). Please read this Policy carefully. By using the Site you agree that your data and personal information may be collected, used and disclosed in the ways we describe. Do not use the Site if you do not agree with the practices described in this Policy.

We may change the Policy from time to time in order to address new issues and to reflect changes on the Site or in the law. We reserve the right to revise or make any changes to the Policy. Please bookmark this page and review it periodically to assure familiarity with the current version of the Policy.

INFORMATION WE COLLECT AND TRACK. EFL collects and retains data, including personal information, about you. "Personal Information" generally means information that can reasonably identify an individual or household. We collect Personal Information and data when you interact with the Site, or provide it to us on certain other occasions (such as via the phone, in person meetings, emails or in response to mailings).

Information collected may include but is not limited to the following:

We collect personal identifiers including name, date of birth, email address, postal or residential address, and telephone number.

Personal Identifiers. We collect personal indentifiers including name, date of birth, email address, postal or residential address, and telephone number.

Tracking Data. We collect information that is automatically collected from every Site visitor. The data may include, without limitation, information regarding the number and frequency of visits to the Site, the websites that you access before and after you visit the Site, the Internet software used to access the Site, and your IP address and Internet service provider.

Survey and Poll Data. Through our Site, you may have the opportunity to participate in surveys and polls that ask for Personal Information. Participating in these polls in completely optional.

Sensitive Information. We do not currently collect "sensitive" or "special category" data or information as defined by data protection laws. Do not provide us with any sensitive information unless we have given you prior authorization to do so.

Third Party Information. Through our Site and Services, you may have the opportunity to invite other individuals to register for our Services or receive communications from us by providing us with their name, email, and company. By providing us with another individual’s information, you represent and warrant that they have provided you with consent to do so, and you have full authority to provide us with this information.

Providing Us With Personal Information. You may decline to provide us with certain Personal Information, but please realize that you may be unable to utilize the Site or our Services. Personal Information is required to process your requests to us, to provide information to you about EFL’s activities and to provide to you. If you do not provide the Personal Information we ask for, it may delay or prevent us from providing services to you.

HOW WE USE YOUR INFORMATION. The data and Personal Information that we collect and that you provide to us is used for our business purposes and the purpose for which you provided it, including, without limitation, to respond to your requests or correspondence. EFL may also use your Personal Information to contact you about the Site or to request your input regarding ways in which we might improve the Site. We may also use your Personal Information to inform you about EFL'S services. The Personal Information may also be analyzed so that we can provide you with useful information and can serve you in the best manner possible through enhanced features and functions on the Site.

In addition to the uses described above, we may use your Personal Information for the following purposes:

Operating our Site and Services;
Providing you with newsletters, alerts and other information tailored to your interests;
Conducting surveys, internal research and analytics to help us understand trends and
improve our services;
Marketing, improving our Site and Services, develop new features, and communicate
offers, promotions, and events;
Preventing, investigating or providing notice of fraud, unlawful or criminal activity or
unauthorized access to or use of Personal Information, or to meet legal obligations;
Investigating and resolving disputes and security issues and enforcing our terms of use and
other agreements; and
Executing any other lawful purpose.

HOW WE SHARE YOUR PERSONAL INFORMATION. Data and Personal Information provided to third-parties is limited to the data and Personal Information needed to perform their functions. We seek to limit third-party use of Personal Information; however, we are not responsible for such third-party use of Personal Information that is not in compliance with this Policy.

We will not disclose any Personal Information to third-parties, except (i) to parties who perform a service for us, such as sending you communications via the postal service or internet, web hosting, and other similar services; (ii) when we believe that such disclosure is required by law; (iii) to enforce this Policy or the Terms; (iv) to protect the rights, property, security or safety of EFL, Site users or the public; (v) to respond to an emergency; or (vi) as otherwise stated in this Policy. In addition, we may disclose Information to certain third-parties if you have requested or authorized the disclosure of such Information.

Legal Process, Safety and Terms Enforcement. We may disclose your Personal Information to legal or government regulatory authorities in response to their requests for such Personal Information; for example, for standard reporting purposes or to assist in investigations. We may also disclose your Personal Information to third-parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you, us or others or to enforce our legal rights or contractual commitments you have made.

For a Merger, Acquisition, Change in Ownership, or Reorganization. Personal Information we have collected may be disclosed to a third party in the event of a merger, transfer of ownership or assets, bankruptcy, or other corporate reorganization.

With our Affiliated Businesses. We transfer the information that we collect to other affiliated businesses, subsidiaries, and related affiliates acting on our behalf for the purposes described in this Policy.

Service Providers. We share your Personal Information with third-party service providers who perform services on our behalf or for your benefit, such as web hosting and analytics. We may also use services provided by third-parties (such as social media platforms) to serve targeted ads to you on third-party platforms. We may do this by providing a hashed version of your Personal Information to the third-party for matching purposes.

Promotional Communications. For European Economic Area ("EEA") residents, we have a legitimate interest in processing your Personal Information for promotional purposes. United States laws do not require consent to send promotional electronic communications. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. You may opt out using the instructions in the "Choices Regarding Your Personal Information" section.

Disclosure of Aggregated Non-Personal Data. We may disclose aggregated, non-personal information received from providing the Services, including information that does not identify any individual, without restriction.

NOTICE FOR RESIDENTS OF THE UNITED STATES. Certain U.S. state consumer privacy, including California, laws may provide their residents with additional rights regarding our use of Personal Information. For purposes of this section, "Personal Information" means "personal information" or "personal data" under U.S. state consumer privacy laws.

Statement of U.S. Resident Rights. You may have the following rights based on your residential jurisdiction, which you can exercise free of charge:

Chart of privacy points

If you would like to exercise a subject access request, please contact us as per the details in section ‘How To Contact Us’.

Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive. If you would like to update or correct your email address, street address, or other personal information with us, please include specific details about the information you wish to have updated or corrected.

For requests submitted by email, you must provide enough information that allows us to verify your identity. Only you or your authorized agent may make requests regarding your personal information. An authorized agent must have documentation that they are authorized to act on your behalf. We will fulfill or reject your request within the amount of time required by law. You will be kept informed of our progress.

Sale and Sharing of Data. We have not sold or shared your Personal Information for monetary or other valuable consideration within the past twelve months, however, our use of cookies and other website tracking technologies may be considered a sale or sharing of Personal Information under certain state data protection laws, in which case the categories of Personal Information that we have sold or shared include identifiers (e.g., IP addresses) and internet or other similar network activity. Categories of third parties to whom Personal Information is sold or shared include data analytics providers, advertising, and marketing providers. For the avoidance of doubt, we do not sell or share the personal information of children under the age of 16.

Nevada Privacy Rights. Nevada residents have the right to opt-out of the sale of their Personal Information by, emailing us at the "How to Contact Us" section and including "NV Sale Opt Out Request" in the subject line. Please note we will take reasonable steps to verify your identity and the authenticity of the request. We will respond to your request within sixty (60) days and, once verified, we will maintain your opt-out request in the event our practices change. Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the Nevada resident's reasonable expectations, when considering the submission’s circumstances.

USE OF TRACKING DATA AND COOKIES. Personal Information, including online tracking information, may be used for a variety of purposes, including but without limitation, to compile statistical, demographic or aggregated information about visitors to the Site generally, or for load balancing metrics and also may be used to create reports on user demographics and the traffic patterns of the Site. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, page views and/or clickstream data. We generally only use this data for purposes such as tracking traffic patterns on the Site, security, fraud detection and protecting our rights. The reports that are generated from Tracking Data are used for a variety of purposes, including, for example, to improve the Site and our services.

We use cookies to enhance your experience while using the Site. "Cookies" are small pieces of information that a website transfers to your computer's hard drive for record-keeping purposes. The use of cookies makes web surfing easier by performing certain functions such as saving your passwords and your personal preferences in connection with your use of a particular website.

Many consider the use of cookies to be an industry standard. Your browser is probably set to accept cookies, but you are always free to decline our cookies if your browser permits. Your browser also probably allows you to delete cookies. If you choose to have your browser refuse cookies, or if you delete cookies, it is possible that some of the services provided on the Site will not function properly. Note also that you can click on the cookie icon on our website to opt out of all types of cookies except "Essential cookies," which are required to enable basic web functionality.

CHOICES REGARDING YOUR PERSONAL INFORMATION.

Global Privacy Controls. Global Privacy Control ("GPC") is a special browser setting that helps user's exercise their rights or share privacy preferences. The GPC sends signals such as not to share or sell personal data without their consent. You can download the GPC browser extension here.

Do Not Track Signals. CalOPPA requires us to let you know how we respond to web browser Do Not Track ("DNT") signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on DNT, see here. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time.

Analytics. We use analytics providers such as Google Analytics to help us evaluate and measure the use and performance of the Site. To opt out of the aggregation and analysis of data collected about you on the Site by Google Analytics, visit https://tools.google.com/dlpage/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

Messaging and Newsletter Communications. You may control how you receive certain types of communications by unsubscribing within the body of the communication. Note that some messages are required, service-related messages like transaction confirmation messages, legal notices, or updates.

WHERE WE PROCESS AND STORE INFORMATION. Personal Information and data we collect about you may be transferred, processed, and/or accessed by us in the United States, or another country where we or our service providers operate. Please be aware your personal information may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live.

If you are located outside the United States and choose to allow us to collect information about you, please be aware that we may transfer your personal information to the United States and process and store it there. If you are located in the European Economic Area ("EEA") or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Policy.

HOW YOUR INFORMATION IS PROTECTED. We take reasonable precautions to protect your data and Personal Information from loss, misuse or alteration. We maintain reasonable physical, electronic and procedural safeguards for your Information. You should recognize, however, that there is no such thing as "perfect security" on the Internet, and we cannot guarantee the security of your Information. In addition, because Internet communication is unsecure, it is also possible that the information you supply to us or your access of any information via the Site will be intercepted during transmission. We are not liable for any breach of our systems or interception of our transmission, and we hereby fully disclaim, to the fullest extent provided under law, any liability associated with any claim relating to a breach of security, data or information.

CHILDREN UNDER THE AGE OF 13. The Site is not intended for use by anyone under the age of 13, and we do not knowingly collect Information from anyone under 13 years of age without the consent of a parent or guardian. We encourage parents or guardians to participate in and monitor their children's online activity. If a child under 13 has provided Personal Information to us, we encourage the child's parent or guardian to contact us through the contact information provided below to request that we remove the information from our systems. If you are under the age of 13, do not provide us with any Personal Information.

DATA RETENTION. We will retain your Personal Information for as long as it is reasonably useful and necessary for the purposes that it was collected. We will retain and use your information and data as necessary to comply with our legal and regulatory obligations or data retention policies.

LINKS TO OTHER WEBSITES. The Site may include links to websites operated by other third-party organizations. These features may collect your IP address, which page you are visiting on our Site and may set a cookie to enable the feature to function properly. This Policy does not apply to, and we are not responsible for the content, privacy policies or data practices of third-parties that collect your Personal Information. We encourage you to review the privacy policies for those third-parties to learn about their information practices.

APPLICABLE LAW. This Policy will be governed by and construed in accordance with the laws of the State of Florida, without regard to any principles of conflicts of law. You agree that any action at law or in equity that arises out of or relates to any use of the Site will be filed only in the state or federal courts located in Miami-Dade County, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action.

ADA INFORMATION. In designing the Site, we endeavor to make every reasonable effort to comply with the web accessibility standards and guidelines established pursuant to Section 508 of the Rehabilitation Act and promulgated by the U.S. Access Board. Our Site has been designed to reach the widest audience possible. If you have difficulty viewing the Site or accessing any information presented on the Site, please contact us.

HOW TO CONTACT US
You may contact us by any of the following means:

Email: info@efl.global
Telephone: (800) 519-EXPO

Last Revised: February 7, 2024

EXHIBIT: EEA (European Economic Area) and UK

This exhibit applies to you if you interact with EFL Global LLC ("EFL", "we", "us" or "our") and its subsidiary and affiliated entities and you are based in the EEA or UK (or if EEA or UK data protection law applies). This exhibit is with respect to the GDPR and the UK GDPR (hereinafter collectively referred to as the "GDPR") that apply to the processing of your personal data by us.

This exhibit is an addition to the Policy and specifies as well as amends the Policy. To the extent the processing of personal data of individuals based in the EEA or UK is concerned in case of conflicting contents this Exhibit prevails over the Policy.

Your use of this site is not considered to amount to consent to the data processing described in this Policy. This Exhibit contains your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the "STATEMENT OF YOUR RIGHTS" section below.

1. CATEGORIES OF PERSONAL DATA PROCESSED BY US

We collect and process personal data about you outlined in the "INFORMATION WE COLLECT AND TRACK" section of the Policy. Sometimes, we receive information about you from third parties. In particular: [set out details of relevant third party collected data and the source of the information.]

2. OUR LEGAL BASIS FOR PROCESSING PESONAL DATA

We process your personal data outlined in the "INFORMATION WE COLLECT AND TRACK" section of the Policy pursuant to the following legal bases for the purposes stated in the "HOW WE USE YOUR INFORMATION" section of the Policy.

When processing is necessary for the pursuit of legitimate interests (GDPR Art. 6(1)(f)(*)

To respond to your requests or correspondence;
To contact you about the Site or request your input regarding ways in which we might improve the Site where consent is not required by law;
To inform you about EFL's services where consent is not required by law;
To analyse so that we can provide you with useful information and can serve you in the best manner possible through enhanced features and functions on the Site where consent is not required by law;
To operate our organization;
To provide you with newsletters, alerts and other information tailored to your interests where consent is not required by law;
To conduct surveys, internal research and analytics to help us understand trends and improve our services where consent is not required by law;
To prevent, investigate or provide notice of fraud, unlawful or criminal activity or unauthorized use of personal data, or to meet legal obligations; and,
To investigate and resolve disputes and security issues and enforce our terms of use and other agreements.

When processing is necessary for compliance with a legal obligation (GDPR Art. 6(1)(c))

To perform obligations pursuant to the laws and regulations of countries in the EEA and UK

When your consent is obtained in advance, (GDPR Art. 6(1)(a))

To provide you with newsletters, alerts and other information tailored to your interests, when consent is necessary pursuant to direct marketing regulations;
To process data obtained in connection with cookies
To serve targeted ads to you on third-party platforms; and
To conduct surveys, internal research and analytics to help us understand trends and improve our services when consent is required by law.

(*) Please contact us at the contact details provided in the "HOW TO CONTACT US" section below regarding the details of the balancing test for legitimate interests (GDPR Art. 6(1)(f).

There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.

3. HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with other recipients as outlined in "HOW WE SHARE YOUR PERSONAL INFORMATION" in the Policy.

4. TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY

When we transfer personal data outside the EEA or the UK, we implement appropriate safeguards based on an adequacy decision with respect to countries determined to provide adequate protection (GDPR Art. 45) or by entering into standard data protection clauses adopted by the EU Commission (GDPR Art. 46(2)(c) and Art. 46(5)) or standard data protection clauses adopted by ICO, with respect to other countries (UKGDPR Art. 46(2)(d)). If you wish to receive a copy of documents regarding these safeguards, please contact us using the contact details provided in the "HOW TO CONTACT US" section below.

We will retain your personal data for as long as it is reasonably useful and necessary for the purposes that it was collected. We will retain and use your information and data as necessary to comply with our legal and regulatory obligations or data retention policies.

5. DATA RETENTION

6. STATEMENT OF YOUR RIGHTS

You have the rights set out in the "STATEMENT OF YOUR RIGHTS" section of the Policy, including the right to object to some of the processing which we carry out.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of these rights, please contact us using the contact details provided in the "HOW TO CONTACT US" section below.

Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.

If you have unresolved concerns, you have the right to complain to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place.

7. UPDATES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

8. HOW TO CONTACT US

The data controller for your personal data is EFL Global LLC. If you have questions about this Policy including this Exhibit or wish to contact us for any reason in relation to our personal data processing, please contact us at info@efl.global or (800) 519-EXPO.

9. APPLICABLE LAW

The governing law and jurisdiction stated in the "APPLICABLE LAW" section of the Policy does not apply.

Last Revised: February 7, 2024