ENGAGED ON PURPOSE

Louis Efron, LLC (“Louis Efron”) understands the importance of protecting personal information. For this reason, Louis Efron strives to have business procedures and security safeguards in place to protect personal information under its control.

Application and Scope

This Privacy Policy (“Policy”) is intended to establish responsible and transparent practices for the management of personal information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Louis Efron in respect of any personal information collected, accessed or processed by Louis Efron in the course of its business operations and specifies the obligations of Louis Efron that arise from Louis Efron Terms of Service (available at louisefron.com/engaged-on-purpose/terms) (the “Terms”) entered into between Louis Efron and its corporate customers (each, a “Customer”), whereby Louis Efron might handle or have access to personal information.

This Policy also governs personal information collected about Louis Efron’s website users and explains how Louis Efron uses and discloses personal information collected from people who visit its website and otherwise interact with Louis Efron through Louis Efron.com, EngagedOnPurpose.com and its sister websites provided by Louis Efron (collectively, the “website”). It also explains how Louis Efron may use cookies and similar technologies.

Any Personal Information (as defined below) received in communication or in material you transmit to the Site by electronic mail or otherwise are and will be treated in accordance with this Policy.

Definition of Personal Information

Personal Information is defined as “any information about an identifiable individual”. This may include, for example, email addresses and contact details and any similar information provided to Louis Efron in the course of its business operations, or which Louis Efron may receive from business inquiries. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be Personal Information. We endeavor to limit our requests for Personal Information to information we believe is reasonably necessary to achieve our purposes as described in the “Use of Personal Information” section below.

Use of Personal Information

When providing services, Louis Efron only processes Personal Information in accordance with the Terms and applicable laws. Louis Efron generally uses Personal Information from or about its Customers and Users (as defined in the Terms), (hereinafter referred to as “Customer’s Personal Information”) for the following purposes:

• to provide you with service information, and news,
• to support the services offered on the Site,
• to contact you for feedback about our Services,
• to conduct research about Louis Efron’s customer base or services,
• to process your payments including credit checks and collection,
• to notify you of technical updates or changes in policy, or
• to contact you for our own marketing and promotional purposes.

We may use non-Personal Information such as demographic data to analyze and develop our marketing strategy and further improve the Site and our Services.

Information Sharing and Disclosure

Louis Efron will not sell, rent or trade Personal Information to any third party. However, Louis Efron may share Personal Information when authorized and/or required by law or as follows:

• if sharing the information is reasonably necessary to provide a service that you have requested.
• if we believe in good faith that we are required to do so by law, in connection with litigation, to prevent a crime, or to protect personal safety, the public, or the Site.
• in connection with a sale or merger with another entity or if Louis Efron should ever file for bankruptcy or have its assets sold to another entity.
• when we otherwise have your consent to share the Personal Information.

Louis Efron may also share non-Personal Information with third parties (e.g. aggregate or demographic data).

Before sharing any Personal Information with any third party, Louis Efron will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of personal information and preventing unauthorized access.

Choice

When we collect your contact information from you, you will have the opportunity to indicate your preferences to receive direct marketing or market research information.

Access

You may correct, amend, or delete your Personal Information by contacting us.

Security

We are committed to protecting Personal Information from loss, misuse, disclosure, alteration, and unauthorized access. Louis Efron will store and process the personal information in a manner consistent with industry security standards. Louis Efron has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of personal information and to mitigate the risk of unauthorized access to or use of personal information, including (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the personal information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with up-to-date virus definitions and security patches so as to avoid any adverse impact to the personal information that it manages; appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; permitting only authorized users access to systems and applications; and (iv) all persons with authorized access to personal information must have a genuine business need-to-know prior to access (“Security Program”).

Third Party Sites

The Site may contain links to other sites. Louis Efron is not responsible for the privacy practices of such other sites. We encourage our users to be aware when leaving the Site to read the privacy statements of each site that collects Personal Information.

Cookies

While we do not currently use third-party advertising companies to serve advertisements on our behalf, we may in the future. These companies may use a cookie or an action tag, also known as a Web Beacon or a 1 pixel .gif file, to tailor the advertisements you see on this Website and other sites, to track your response to their advertisement and to measure the effectiveness of their advertising or to award incentives or points to their members who respond to their advertisements. The cookies, action tags or similar files do not contain any Personal Information.

Your Consent to this Policy

By using this Site, you agree to this Policy. We may occasionally update this Policy. The date of the most recent update of this document will always be displayed at the beginning of this page. If we change our Policy, we will post those changes on Louis Efron.com. If we decide to use Personal Information in a manner different from that stated at the time it was collected, we will notify users via email (if an email address has been provided) or display a notice on Louis Efron.com. We encourage you to periodically review this Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of this Site constitutes your agreement to this Policy and any updates.

Contacting Louis Efron

If you have any questions, comments, or concerns about this Policy, please contact us at:

Louis Efron, LLC
13009 S. Parker Road
Suite #118
Parker CO 80134
Email: contact@EngagedOnPurpose.com

Please also see sparkbay.com/privacy