Privacy Policy

INTRODUCTION.

EFL Global LTD (“EFL”) has adopted the following privacy policy statement applicable to the EFL questionnaire (“assessment”). This privacy policy has been adopted to apply to personal information EFL may receive related to products and services it provides. If you have any questions or concerns about this privacy policy, or require the correction of any personally identifiable information, please contact us at support@eflglobal.com

INFORMATION RECEIVED FROM INTERNET SERVICE PROVIDERS.

The EFL website and Web App receive information that is automatically generated by a user’s Internet service provider (ISP). This information may include the IP address (a number automatically assigned to a computer by the ISP), the associated URLs, domain types, the browser type used to access our site, the country, state and telephone area code, the location of the ISP’s servers, the pages of our site that the user views during the visit, any search terms entered on this site, and the website address and email address of a user. This information may be collected for system administration purposes, to gather broad demographic information and to monitor the level of activity on the site. EFL and its affiliates do not link IP addresses to personal information; however, we reserve the right to link IP addresses and other information supplied by the ISP to personally identifiable information in order to protect the integrity of our system and for security purposes.

PERSONAL INFORMATION RECEIVED ABOUT INDIVIDUALS.

We provide applicant tracking and assessment and testing services as a service provider to our clients. Our clients are companies or organizations that use our products to assist them in evaluating individuals for a bank loan. Individuals seeking a loan with our clients, or participating in testing processes provided by EFL are referred to in this policy as “Loan Applicant.” We collect or receive personal information from our clients’ Loan Applicants. We use this information in order to perform services on behalf of the client. Providing personal data is voluntary, but necessary if the Loan Applicant wishes to receive evaluation for consideration of a loan. We will handle and treat all personal information collected and received by us in connection with applicant tracking, and assessment administration and reporting in the manner outlined in this Privacy Policy, and as may be otherwise specified by our clients.

Personal Information Collected

The personal data that we collect or receive in registering a Loan Applicant for our services may include, but is not limited to: national id or passport number, name, email address, phone number, company and title. We may also collect or receive the following additional information at registration or in the testing or applicant tracking process, as necessary or appropriate: language, date of birth, employment information, previous employment history, and family information. For Loan Applicant verification and identification purposes, we may collect all or part of a government-issued identification number. When an electronic assessment is administered to a Loan Applicant, we may collect and score Loan Applicant responses and then derive a score and generate a report about their results.

INFORMATION SHARING AND DISCLOSURE.

Aggregation of Non-Person-Specific Data

We may statistically aggregate in non-person-specific form responses to assessment questions and other information collected in the assessment registration and delivery process and transfer this information to the client sponsoring the bank loan for which the Loan Applicant is seeking consideration and/or the assessment(s) the Loan Applicant is taking. Such aggregated non-person-specific information may be used for quality control, operations management, security and marketing purposes and to enhance, develop or improve our processes, services, and products (for example, by performing validation and normative testing on the assessments). By registering for an assessment through us, the Loan Applicant gives consent to this non-person-specific data aggregation and the use and transmission of this aggregated statistical data as outlined above.

Transfer of Information to Clients

By registering for an assessment through us, the Loan Applicant gives their consent for their personal information to be transmitted by EFL to the client sponsoring the bank loan for which the Loan Applicant is seeking consideration and/or the assessment(s) they are taking. The clients require this personal data so that assessments can be correctly administered and processed and the results used by the client. For further information about how the client may use a Loan Applicant’s personal information, please contact the client. Personal data may also be aggregated and provided to the client sponsoring the bank loan for which the Loan Applicant is seeking consideration and/or the assessment(s) the Loan Applicant is taking.

Other Disclosures

We also may disclose information, including personally identifiable information in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect user security or the security of other persons, consistent with applicable laws; (c) in connection with a sale, joint venture or other transfer to some or all of the assets of EFL; (d) to clients as set out above. We otherwise exercise commercially reasonable care to not otherwise share or disclose the names of users or any personally identifiable information with third parties, except with the prior approval of the user.

INFORMATION FROM CHILDREN.

This assessment is not directed to children or anyone under the age of 13. EFL will not, through this website, knowingly collect, maintain or use any personally identifiable information about anyone under the age of 13.

TRANSMISSION OF INFORMATION.

The Internet is a global environment. By using the EFL assessment and the EFL Web Application for receiving scores and sending information to us electronically, a Loan Applicant consents to transborder and international transmission of any data that the Loan Applicant may choose to supply us. Information transmissions to EFL and emails sent to us may not be secure. Given the inherent operation and nature of the Internet, all Internet transmissions are done at the Loan Applicant’s own risk.

COOKIES.

Cookies are small text files that a website transfers to a computer’s browser. We may use cookies to measure traffic patterns in the EFL Web Application, personalize content and control security. The cookies we use supply non-personally identifiable information, but may identify a user’s computer, browser and Internet specifications.

LINKS TO OTHER SITES.

The EFL Web Application may contain links to other websites on the Internet that are owned and operated by third parties, or by EFL, or its parent corporation, or affiliates. The information practices of those websites are not covered by this Privacy Policy, but by their own terms and policies, which a user should read carefully. No links are provided within the EFL assessment to other third party sites.

CHANGES TO THIS PRIVACY POLICY.

We reserve the right to change the terms of this privacy policy from time to time by posting an updated privacy policy. We encourage client users and Loan Applicants to review this Privacy Policy Statement periodically for any changes or updates.

GOOGLE ANALYTICS

We use “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser or prevent your data from being collected and used by Google Analytics by installing the Google Analytics opt-out browser add-on.

Google Analytics employs cookies to define user sessions, which allows for the collection of data about how visitors are using the websites. Google Analytics uses only first-party cookies for data analysis.  This means that the cookies are linked to a specific website domain, and Google Analytics will only use that cookie data for statistical analysis related to your browsing behavior on that specific website.  According to Google, the data collected cannot be altered or retrieved by services from other domains.

If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit Google Analytics.