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Elfink’s Privacy Policy

Elfink Privacy Policy

Last Updated: August 12, 2026

At Elfink, personalization is built on trust.

Customers may share names, photographs, messages, and other information relating to the people who matter most to them, including children. We recognize the responsibility that comes with handling this information and are committed to using it thoughtfully, securely, and only for legitimate purposes connected with our products, services, and business.

This Privacy Policy explains how Elfink LLC (“Elfink,” “we,” “us,” or “our”) collects, uses, stores, shares, protects, and otherwise processes personal information when you:

  • visit or use www.elfink.com;

  • purchase an Elfink product;

  • use our personalization or product-customization tools;

  • upload a photograph, image, or other personalization content;

  • create or edit a cart;

  • communicate with our customer-service team;

  • submit a review, testimonial, photo, video, or other content;

  • subscribe to marketing communications; or

  • otherwise interact with Elfink online or through services connected with our business.

This Privacy Policy should be read together with our Terms of Service, Shipping & Returns Policy, and any additional privacy or consent notices presented when information is collected.

1. Who We Are

Elfink LLC operates the Elfink brand and the website www.elfink.com.

Elfink creates personalized books and other personalized products designed primarily for children and families.

For questions regarding privacy, children's information, uploaded photographs, deletion requests, or this Privacy Policy, please contact:

Elfink LLC
Nevada, United States
Email: service@elfink.com

Additional mailing or legal contact information may be provided where required by applicable law.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information processed in connection with Elfink's operations, including:

  • Elfink.com;

  • our Shopify-powered storefront;

  • product pages;

  • our product customizer;

  • “Customize Now” experiences;

  • cart customization and editing;

  • product-preview tools;

  • customer accounts;

  • checkout;

  • orders;

  • payments;

  • production;

  • printing;

  • fulfillment;

  • shipping;

  • customer service;

  • uploaded photographs;

  • personalization information;

  • reviews and testimonials;

  • email communications;

  • analytics;

  • advertising;

  • fraud prevention;

  • security systems; and

  • related Elfink services.

Third-party websites, marketplaces, social-media platforms, payment providers, or other independent services may maintain their own privacy policies and practices.

3. Our Store and Customization Tools Are Intended for Adults

Elfink products may be created for children, but our storefront, checkout system, and personalization tools are intended to be used by adults purchasing products for children or other recipients.

Elfink does not intend for children under 13 to independently:

  • create customer accounts;

  • place orders;

  • submit payment information;

  • upload photographs;

  • provide personalization information; or

  • otherwise submit personal information through our purchasing and customization systems.

If you submit information about a child, including a photograph, name, age, likeness, or other identifying information, you represent that you have the authority to provide that information as described in this Policy.

If you believe information relating to a child was submitted to Elfink without proper authority or consent, please contact:

service@elfink.com

We will review appropriate requests and take reasonable action where required or appropriate.

4. Categories of Personal Information We May Collect

Depending on how you interact with Elfink, we may collect the following categories of information.

A. Contact Information

This may include:

  • name;

  • email address;

  • telephone number;

  • billing address;

  • shipping address;

  • country or region;

  • customer-account information; and

  • other contact details you provide.

B. Order and Transaction Information

This may include:

  • products ordered;

  • product variants;

  • order numbers;

  • cart identifiers;

  • transaction status;

  • purchase date;

  • shipping method;

  • fulfillment information;

  • tracking information;

  • refunds;

  • replacements;

  • discounts;

  • taxes; and

  • payment-related transaction identifiers.

Complete payment-card information is generally processed by our payment providers rather than stored directly by Elfink.

C. Personalization Information

Depending on the product, you may provide information such as:

  • a child's or recipient's name;

  • age or age range;

  • pronouns;

  • dedication text;

  • personal messages;

  • character selections;

  • appearance options;

  • story selections;

  • relationship information;

  • product preferences; and

  • other information required to personalize the product.

Please do not include unnecessary sensitive personal information in free-text personalization fields.

D. Uploaded Photographs and Images

Certain Elfink products may require or allow photographs to be uploaded.

Those photographs may depict:

  • children;

  • adults;

  • family members;

  • friends;

  • other individuals;

  • clothing;

  • accessories;

  • surroundings; and

  • other information visible within the image.

We may also process technical information associated with uploaded files, including:

  • file name;

  • file type;

  • file size;

  • image dimensions;

  • upload time;

  • processing status;

  • internal file identifiers;

  • storage identifiers;

  • customization identifiers;

  • order associations; and

  • production identifiers.

E. Device and Website Usage Information

We and our service providers may automatically collect information such as:

  • IP address;

  • browser type;

  • device type;

  • operating system;

  • device or browser identifiers;

  • referring page;

  • pages viewed;

  • website interactions;

  • approximate geographic region;

  • dates and times of access;

  • session information;

  • cookie identifiers;

  • shopping activity;

  • conversion activity;

  • diagnostic information; and

  • security information.

F. Customer-Service Information

If you contact us, we may receive and retain information such as:

  • emails;

  • messages;

  • order numbers;

  • support history;

  • complaint information;

  • replacement requests;

  • refund requests;

  • photographs showing damaged or defective products; and

  • other information you voluntarily provide.

G. Reviews and User-Generated Content

If you submit content to Elfink, we may process:

  • product reviews;

  • star ratings;

  • testimonials;

  • photographs;

  • videos;

  • comments;

  • captions;

  • stories;

  • feedback; and

  • other content submitted voluntarily.

Special terms relating to this content are explained later in this Policy and in our Terms of Service.

5. Personalized Products, Uploaded Photos, and Children's Likenesses

This section applies when you use our product customizer or related tools to order a personalized product.

It supplements the remainder of this Privacy Policy.

If this section conflicts with another portion of this Policy specifically regarding personalization data or uploaded photographs, this section will control for those topics to the extent permitted by applicable law.

6. Your Authority to Upload a Photograph

If you upload an image depicting a child or another individual, you represent and warrant that:

  • you are the child's parent or legal guardian; or

  • you have obtained any permission, consent, or authorization required by applicable law from the child's parent or legal guardian; and

  • where required, you have obtained appropriate permission from other individuals depicted.

You also represent that:

  • you have the right to provide the image;

  • the image was not unlawfully obtained;

  • submitting it does not violate another person's privacy rights;

  • submitting it does not violate publicity rights;

  • submitting it does not infringe copyrights or other intellectual-property rights; and

  • Elfink may process the image as reasonably necessary to provide the personalized product or service you requested.

If you do not have the necessary authority or permission, do not upload the image.

7. How Uploaded Photographs May Be Processed

To create a personalized Elfink product, photographs may be processed manually and/or automatically.

Depending on the product and workflow, image processing may include:

  • detecting the relevant person within an image;

  • locating a face;

  • identifying facial or image landmarks for positioning purposes;

  • cropping;

  • resizing;

  • rotation or orientation correction;

  • background removal;

  • image isolation;

  • positioning;

  • compositing;

  • image-quality adjustment;

  • fitting a photograph into an illustration or page design;

  • preparing production files;

  • generating print-ready assets;

  • quality checking; and

  • troubleshooting production issues.

Certain automated systems may analyze facial or image characteristics solely for purposes such as positioning, cropping, orientation, image preparation, or product creation.

Elfink does not intend to use this processing to determine who a person is.

We do not knowingly use customer customization photographs for:

  • facial recognition of identity;

  • authentication;

  • surveillance;

  • tracking an individual across unrelated services; or

  • building identity databases of children.

8. No General-Purpose AI Training With Customer Personalization Photos

Unless we separately provide clear notice and obtain any consent required by applicable law, Elfink does not use customer-uploaded personalization photographs or children's likenesses to train general-purpose artificial-intelligence models for unrelated purposes.

Photographs uploaded through the customization process are intended to be used for purposes connected with the service requested by the customer, including:

  • customization;

  • image preparation;

  • production;

  • fulfillment;

  • quality control;

  • customer support;

  • security;

  • troubleshooting; and

  • related operational functions.

We may use aggregated, statistical, technical, or appropriately de-identified information that does not reasonably identify a particular individual to evaluate and improve our systems.

9. Customization Photos Are Not Public Content

Photographs uploaded through the product customization process are different from photographs voluntarily submitted as public reviews or marketing content.

Customization photos are not intended to be:

  • publicly displayed;

  • placed into a customer gallery;

  • posted to social media;

  • used as advertising photographs; or

  • made available to unrelated customers.

Our customization system is not a social network or public photo-sharing service.

We do not intend to provide permanent public links to customer customization photographs.

Access may instead be provided through private systems, authenticated interfaces, controlled production systems, or temporary access mechanisms where necessary.

10. How We Use Personal Information

We may use personal information for the purposes described below.

Product Creation and Fulfillment

We may use information to:

  • operate our customizer;

  • create product previews;

  • personalize products;

  • prepare images;

  • generate production files;

  • manufacture and print products;

  • associate personalization data with orders;

  • process purchases;

  • fulfill orders;

  • ship products; and

  • provide tracking.

Customer Support

We may use information to:

  • answer questions;

  • locate orders;

  • investigate issues;

  • correct production problems;

  • provide replacement products;

  • address shipping issues;

  • process eligible refunds;

  • communicate with customers; and

  • resolve disputes.

Security and Fraud Prevention

We may process information to:

  • secure Elfink systems;

  • protect customer accounts;

  • prevent abuse;

  • detect fraud;

  • investigate suspicious activity;

  • prevent unauthorized transactions;

  • protect infrastructure; and

  • respond to security incidents.

Business Operations and Improvement

We may use appropriate information to:

  • troubleshoot systems;

  • improve website functionality;

  • improve our customizer;

  • analyze conversion and performance;

  • improve production workflows;

  • evaluate fulfillment performance;

  • improve customer support;

  • conduct internal reporting; and

  • operate our business.

Legal and Compliance

We may process information to:

  • comply with applicable laws;

  • respond to lawful requests;

  • maintain legally required records;

  • protect legal rights;

  • investigate misconduct;

  • enforce our agreements; and

  • establish, exercise, or defend legal claims.

Marketing

Where permitted by applicable law, we may process certain customer and website information to:

  • send promotional communications;

  • measure advertising;

  • understand marketing performance;

  • recommend Elfink products; and

  • advertise our business.

Customization photographs of children are not intended to be used to build advertising profiles of children.

11. Legal Bases for Processing Where Applicable

Where privacy law requires Elfink to identify a legal basis for processing personal information, the applicable basis may include:

Performance of a Contract

Processing may be necessary to:

  • create your personalized product;

  • manufacture your product;

  • complete your transaction;

  • ship your order; or

  • provide order-related support.

Consent

We may rely on consent where required for certain activities, such as:

  • marketing;

  • non-essential cookies;

  • certain advertising technologies;

  • voluntary promotional submissions; or

  • uses requiring separate permission.

Legitimate Interests

Where legally available, we may process information in furtherance of legitimate interests such as:

  • operating our business;

  • protecting our systems;

  • preventing fraud;

  • improving our services;

  • managing production;

  • providing support; and

  • protecting legal rights,

provided applicable individual rights and interests are appropriately considered.

Legal Obligations

We may process or retain information where necessary to comply with:

  • tax requirements;

  • accounting requirements;

  • consumer-protection laws;

  • court orders;

  • regulatory requirements; or

  • other legal obligations.

12. Shopify

Elfink's online store operates using Shopify technology.

Shopify and services connected with Shopify may process information related to functions such as:

  • storefront operation;

  • customer accounts;

  • checkout;

  • transactions;

  • orders;

  • payment processing;

  • fraud prevention;

  • analytics;

  • privacy controls; and

  • related e-commerce functionality.

Shopify may process certain information under its own applicable privacy terms and agreements.

Elfink remains responsible for describing our own processing practices and for managing information processed through our store as required by applicable law.

13. Global Production and Fulfillment

Elfink uses a global production and fulfillment network.

To create and deliver your order, personalization information and production files may be provided to the production or fulfillment partner selected for that order.

Our production network may include locations in:

  • the United States;

  • Canada;

  • the United Kingdom; and

  • China.

Production location may be selected dynamically based on factors such as:

  • delivery destination;

  • product type;

  • current production capacity;

  • availability;

  • quality requirements;

  • carrier availability;

  • production speed; and

  • estimated delivery performance.

An order delivered to the United States, for example, is not necessarily produced or shipped from the United States.

Regardless of production location, our goal is for every product to meet the same Elfink quality standards.

Production and fulfillment providers are intended to receive only the information reasonably necessary to manufacture, fulfill, support, or deliver an order.

14. Other Service Providers

We may use service providers that assist with functions such as:

  • website hosting;

  • cloud infrastructure;

  • databases;

  • private object storage;

  • application hosting;

  • payment processing;

  • email;

  • analytics;

  • security;

  • monitoring;

  • customer service;

  • fraud prevention;

  • printing;

  • manufacturing;

  • logistics;

  • shipping;

  • customs processing;

  • fulfillment; and

  • professional services.

These providers may process information where reasonably necessary to perform services for Elfink.

15. Shipping and Logistics Providers

To deliver an order, information may be provided to carriers and logistics partners.

This may include:

  • recipient name;

  • shipping address;

  • telephone number where needed;

  • email where appropriate;

  • product or package information;

  • customs information where applicable;

  • order reference;

  • shipment identifier; and

  • other information reasonably necessary for transportation and delivery.

International shipments may involve multiple carriers or logistics providers.

16. Legal Disclosures

We may disclose personal information if we reasonably believe disclosure is necessary to:

  • comply with applicable law;

  • respond to valid legal process;

  • respond to government or regulatory requests;

  • protect customers;

  • investigate fraud;

  • protect Elfink systems;

  • enforce our Terms;

  • protect the safety or rights of another person; or

  • establish, exercise, or defend legal claims.

17. Reviews, Testimonials, Photos, Videos, and User-Generated Content

Elfink loves seeing how customers and families enjoy their personalized products.

However, content voluntarily submitted for reviews, testimonials, social sharing, promotions, or marketing is treated differently from private photographs uploaded solely for product customization.

Content Submitted Directly to Elfink

If you voluntarily submit or upload a:

  • review;

  • rating;

  • testimonial;

  • photograph;

  • video;

  • comment;

  • story;

  • caption;

  • feedback;

  • social post submission; or

  • other material

directly to Elfink or through an Elfink-controlled review, feedback, promotion, survey, social-content, or submission feature (“User-Generated Content” or “UGC”), you confirm that you are voluntarily providing that content.

You represent and warrant that:

  • you have the right to submit the content;

  • you own the content or have sufficient rights to authorize its use;

  • your submission does not violate another person's privacy or publicity rights;

  • your submission does not infringe another person's copyright or other rights; and

  • if another individual appears in the content, you have any permission required to submit and authorize use of that content.

Content Showing a Child

If a review, testimonial, photograph, or video depicts a child, you represent and warrant that:

  • you are the child's parent or legal guardian; or

  • you have obtained the permission and authorization required from the child's parent or legal guardian to submit the material and permit its authorized use.

If you do not have such permission, you should not submit the image or video for review, testimonial, promotional, or public-use purposes.

18. License for User-Generated Content Submitted to Elfink

By voluntarily submitting User-Generated Content directly to Elfink through a review, testimonial, promotion, feedback, or similar submission feature, you grant Elfink a:

non-exclusive, worldwide, royalty-free license

to use that content in connection with Elfink's business, subject to applicable law.

This license may include the right to:

  • reproduce;

  • display;

  • publish;

  • repost;

  • distribute;

  • format;

  • resize;

  • crop;

  • edit for presentation;

  • adapt for layout;

  • create promotional layouts from;

  • translate accompanying text;

  • communicate;

  • feature; and

  • otherwise use the submitted content

for purposes including:

  • Elfink.com;

  • Elfink product pages;

  • customer-review sections;

  • landing pages;

  • social-media accounts;

  • organic social posts;

  • email marketing;

  • newsletters;

  • digital advertising;

  • printed marketing;

  • promotional campaigns;

  • marketplace content;

  • presentations;

  • brand materials; and

  • other Elfink marketing or customer-experience materials.

This license does not transfer ownership of your original content to Elfink.

You retain whatever ownership rights you lawfully possess in your content.

19. Review Attribution

When featuring a review or other User-Generated Content, Elfink may display information that you voluntarily submitted or that accompanied the review, such as:

  • first name;

  • first name and last initial;

  • initials;

  • star rating;

  • review date;

  • general location;

  • product purchased;

  • review text; or

  • other non-sensitive information associated with the review.

Elfink may shorten or format a review for presentation, but we do not intend to materially change its meaning or create a false impression of the customer's experience.

20. Reviews and Content Posted on Amazon or Other Third-Party Platforms

Customers may also publish reviews, photographs, videos, comments, or other content relating to Elfink products on third-party services such as:

  • Amazon;

  • Instagram;

  • Facebook;

  • TikTok;

  • YouTube;

  • Pinterest;

  • other marketplaces; or

  • other social-media services.

Content posted on a third-party platform remains subject to that platform's terms, privacy rules, and content-licensing arrangements.

Posting content about Elfink on a third-party platform does not, by itself, necessarily grant Elfink an unrestricted independent marketing license to that content.

Elfink may use or feature such content where:

  • the applicable platform permits that use;

  • applicable law permits that use;

  • Elfink otherwise possesses the necessary rights; or

  • the customer or rights holder provides Elfink with permission.

21. Permission Requests for Third-Party Content

Elfink may occasionally contact a customer or content creator and request permission to feature content originally posted on a marketplace or social-media platform.

For example, we may ask whether we can feature:

  • an Amazon review photo;

  • an Instagram photograph;

  • a TikTok video;

  • a Facebook post; or

  • another customer-created image or testimonial.

If Elfink clearly requests permission and you affirmatively respond that Elfink may use the content, your affirmative response may constitute authorization for Elfink to use the identified content for the purposes described in that request.

Depending on the request, this may include use on:

  • Elfink.com;

  • social media;

  • emails;

  • advertisements;

  • product pages;

  • promotional materials; or

  • other Elfink marketing channels.

We may retain reasonable records showing that permission was provided, including:

  • the content reference;

  • account or profile reference;

  • date;

  • time;

  • permission request;

  • affirmative response; and

  • internal consent record.

22. Reviews Are Voluntary

Submitting a review or User-Generated Content is voluntary unless otherwise clearly stated in connection with a particular program.

Elfink does not require customers to provide a positive review in order to receive ordinary customer service relating to their purchase.

Where a review or testimonial was provided in connection with:

  • a free product;

  • discount;

  • promotion;

  • reward;

  • sponsorship;

  • affiliate relationship; or

  • other material incentive,

we may provide or require disclosures where appropriate.

23. Removal or Discontinuation of User-Generated Content

Elfink may decide whether to publish or continue displaying User-Generated Content on Elfink-controlled channels.

We may remove content for reasons including:

  • privacy concerns;

  • child-safety concerns;

  • intellectual-property concerns;

  • legal concerns;

  • inappropriate material;

  • fraudulent reviews;

  • misleading content;

  • technical reasons; or

  • business reasons.

If you have questions or concerns regarding our use of User-Generated Content you submitted, contact:

service@elfink.com

Where applicable law gives you a right to withdraw consent or request deletion, you may exercise that right as described below.

Withdrawal or deletion may not require us to recall physical marketing materials already produced or undo uses that lawfully occurred before withdrawal, to the extent permitted by applicable law.

24. Important Distinction Between Customization Photos and Review Photos

Elfink treats these two categories differently.

Private Customization Photo

A photo uploaded during the process of creating your personalized product is intended to be used for:

creating your product, production, fulfillment, support, security, and related operational purposes.

It is not automatically treated as marketing content.

Voluntarily Submitted Review or Promotional Photo

A photograph voluntarily submitted directly to Elfink as part of:

  • a review;

  • testimonial;

  • UGC submission;

  • social campaign;

  • promotion; or

  • similar feature

may be used according to the UGC license and notices described in this Policy and our Terms.

This distinction allows customers to personalize a product without automatically agreeing that their private customization photographs may be used in Elfink advertising.

25. Sale and Sharing of Personal Information

Elfink does not sell customer-uploaded customization photographs or children's likenesses as standalone products to third parties.

We do not intend to provide children's private personalization photographs to unrelated third parties for their independent marketing purposes.

Privacy laws in some jurisdictions may define terms such as:

  • “sale”;

  • “sharing”;

  • “targeted advertising”; or

  • “cross-context behavioral advertising”

more broadly than those terms are ordinarily understood.

As a result, certain advertising or analytics technologies involving browser, device, or website activity may be legally treated as sale, sharing, or targeted advertising even where information is not literally sold for money.

Where required by applicable law, Elfink will provide applicable choices or opt-out mechanisms.

26. Cookies and Similar Technologies

Elfink and service providers may use technologies including:

  • cookies;

  • pixels;

  • tags;

  • SDKs;

  • browser storage;

  • local storage;

  • session identifiers; and

  • similar technologies.

These may be used for:

Essential Functions

Including:

  • shopping carts;

  • checkout;

  • account sessions;

  • fraud prevention;

  • website security; and

  • core functionality.

Analytics

Including:

  • website traffic;

  • conversion measurement;

  • product-page performance;

  • customer journeys;

  • error diagnosis; and

  • website improvement.

Advertising

Where permitted, advertising technologies may be used for:

  • measuring advertising performance;

  • attribution;

  • audience measurement;

  • campaign optimization; and

  • displaying relevant advertising.

Where applicable law requires consent before activating non-essential technologies, appropriate consent mechanisms may be used.

27. Children's Personalization Information and Advertising

Elfink does not knowingly use private children's personalization photographs to:

  • create behavioral advertising profiles of children;

  • identify children across unrelated websites;

  • sell children's likenesses;

  • conduct surveillance;

  • target advertising directly to identified children; or

  • build facial-recognition databases.

Information used for general website advertising or measurement should be separated, where reasonably practicable, from private customization content.

28. Retention of Customization Photographs

Elfink intentionally limits the retention of uploaded customization photographs and production files.

Our operational defaults are generally as follows.

Abandoned or Unpaid Customizations

Customization photographs and associated files for an order that is not completed are typically scheduled for deletion approximately:

7 days after abandonment

unless a limited operational extension is reasonably necessary.

Paid Orders Awaiting Fulfillment

Customization information may be retained while reasonably necessary to:

  • produce the product;

  • complete quality control;

  • fulfill the order;

  • provide immediate customer support; and

  • correct production issues.

After Fulfillment

Customization photographs and production files are generally scheduled for deletion approximately:

30 days after fulfillment

subject to a limited extension where reasonably necessary for:

  • production support;

  • replacement requests;

  • disputes;

  • fraud prevention;

  • security; or

  • other legitimate operational reasons.

General Maximum Retention Safeguard

Absent a documented legal, security, fraud-prevention, dispute, or exceptional operational reason, customization photographs are generally intended not to remain in active production storage beyond approximately:

90 days from the relevant retention start point.

Automated storage lifecycle rules may also be used as a failsafe.

29. Review and UGC Retention

Reviews, testimonials, photographs, videos, and other content voluntarily submitted for public review, promotional, or marketing purposes may be retained differently from private customization files.

Because this content was voluntarily submitted for review or promotional use, it may remain available for as long as reasonably necessary for the purposes described in the applicable submission terms or UGC license.

Where applicable law provides a right to request deletion or withdraw consent, you may contact us to exercise that right.

30. Transaction and Business Records

Deletion of a customization photograph does not necessarily require deletion of the associated transaction.

Elfink may retain other information for longer where reasonably necessary or legally required, including:

  • order numbers;

  • purchase history;

  • financial records;

  • payment records;

  • tax records;

  • invoices;

  • shipping records;

  • customer-service history;

  • refunds;

  • fraud-prevention records;

  • consent records;

  • legal records; and

  • dispute information.

Where reasonably practical, sensitive customization assets are kept separate from longer-term business records.

31. Backups and Residual Copies

Deletion from active systems may not immediately remove every residual technical copy.

Limited copies may temporarily remain in:

  • system backups;

  • disaster-recovery systems;

  • security logs;

  • audit logs; or

  • legally required records.

Residual copies are intended to remain restricted and are not intended to be returned to normal personalization or marketing use.

They are deleted, overwritten, or anonymized according to applicable retention cycles where appropriate.

32. Information Security

Elfink uses technical and organizational safeguards intended to reduce risks such as:

  • unauthorized access;

  • unauthorized disclosure;

  • misuse;

  • loss;

  • alteration; and

  • destruction.

Depending on the applicable system, safeguards may include:

  • private cloud storage;

  • encrypted transmission;

  • access controls;

  • authenticated administrative tools;

  • shop-scoped data handling;

  • temporary or signed links;

  • restricted production access;

  • logging;

  • monitoring;

  • infrastructure security;

  • retention controls;

  • vendor management; and

  • separation of different data categories.

Access to personalization information is intended to be limited to systems, personnel, service providers, and production partners that reasonably require access to perform relevant functions.

No transmission method, network, storage system, or computer system can be guaranteed to be completely secure.

Therefore, we cannot guarantee absolute security.

33. International Processing

Elfink operates internationally and uses technology, production, and logistics providers in multiple countries.

Information may therefore be processed, stored, transmitted, or accessed outside your home jurisdiction.

This may include processing in countries such as:

  • the United States;

  • Canada;

  • the United Kingdom;

  • China; and

  • other countries where our service providers operate.

Privacy laws may differ among jurisdictions.

Where required by applicable law, Elfink intends to rely on appropriate contractual, organizational, technical, or legally recognized international-transfer safeguards.

34. Your Privacy Rights

Depending on where you live and which laws apply, you may have certain rights relating to personal information.

These may include the right to:

  • know whether personal information is processed;

  • request access;

  • request correction;

  • request deletion;

  • obtain information about categories of collected information;

  • obtain information about categories of recipients;

  • request data portability;

  • object to certain processing;

  • restrict certain processing;

  • withdraw consent where legally applicable;

  • opt out of certain sales or sharing;

  • opt out of certain targeted advertising;

  • appeal certain privacy decisions where applicable; or

  • complain to a privacy regulator.

Not every right applies to every person, company, or circumstance.

35. Privacy Request Verification

Before granting access to, correcting, or deleting personal information, Elfink may take reasonable steps to verify:

  • your identity;

  • your authority to make the request; and

  • your relationship to the applicable customer, order, or customization.

We may request information such as:

  • purchaser email address;

  • order number;

  • approximate order date;

  • recipient information; or

  • another reasonable identifier.

Please do not send unnecessary government identification documents by ordinary email unless specifically requested through an appropriate verification process.

36. Requests Relating to a Child's Photograph

A parent, legal guardian, authorized uploader, or another individual with applicable legal rights may contact Elfink regarding a child's photograph or personalization information.

Depending on applicable law and circumstances, requests may include:

  • access;

  • correction;

  • deletion; or

  • information regarding processing.

We may limit or delay a request where permitted or required in order to:

  • complete an open order;

  • resolve a production issue;

  • investigate fraud;

  • protect security;

  • resolve a dispute;

  • comply with legal obligations; or

  • protect another person's rights.

Where deletion is appropriate, reasonable steps will be taken to remove relevant files from active systems.

37. California Privacy Rights

If California privacy law applies to Elfink and to your information, California residents may have additional rights relating to matters such as:

  • access;

  • correction;

  • deletion;

  • portability;

  • information about collection and disclosure;

  • opting out of sale;

  • opting out of sharing;

  • certain targeted advertising practices; and

  • certain uses of sensitive personal information where applicable.

Elfink will not unlawfully discriminate against an individual for exercising applicable privacy rights.

Where required, Elfink may provide a privacy-choice or data-sharing opt-out mechanism.

38. Nevada Privacy Rights

Because Elfink LLC is organized in Nevada, certain Nevada privacy requirements may apply where statutory conditions are met.

Eligible Nevada consumers may have rights relating to certain covered information and qualifying sales of such information.

Applicable requests may be submitted through:

service@elfink.com

Elfink may verify requests as permitted by law.

39. Canadian Privacy Rights

Where Canadian privacy law applies, individuals may have rights relating to matters such as:

  • access to personal information;

  • correction;

  • transparency regarding collection and use;

  • meaningful consent where required;

  • appropriate safeguards; and

  • complaints regarding privacy practices.

Elfink intends to process applicable Canadian privacy requests according to applicable federal or provincial requirements.

40. European Economic Area and United Kingdom

Where the GDPR, UK GDPR, or related legislation applies, individuals may have rights including:

  • access;

  • rectification;

  • erasure;

  • restriction;

  • objection;

  • portability; and

  • withdrawal of consent where processing is based on consent.

Individuals may also have the right to lodge a complaint with an applicable supervisory authority.

41. Global Privacy Preference Signals

Certain jurisdictions recognize browser-based or device-based privacy preference signals.

Where Elfink is legally required to recognize a supported opt-out preference signal, we intend to process it in accordance with applicable requirements.

Because “Do Not Track” does not have one universally applicable technical and legal standard, our response to ordinary Do Not Track signals may differ from legally recognized opt-out preference signals.

42. Email and SMS Marketing

Where permitted and where applicable consent has been obtained, Elfink may send communications relating to:

  • promotions;

  • discounts;

  • new products;

  • gift ideas;

  • new stories;

  • seasonal campaigns; and

  • other marketing.

You may unsubscribe from promotional email using the unsubscribe mechanism contained in the message.

Where SMS marketing is offered, additional consent or terms may apply.

Unsubscribing from marketing does not prevent us from sending transactional messages relating to:

  • an order;

  • payment;

  • fraud prevention;

  • security;

  • production;

  • shipping;

  • customer support; or

  • other service-related matters.

43. Customer Content Ownership and Limited Production License

You retain whatever intellectual-property or other ownership rights you lawfully possess in photographs, text, dedications, and other content you submit.

When you submit content for personalization, you grant Elfink and service providers acting on our behalf a limited right to:

  • access;

  • copy;

  • reproduce;

  • format;

  • resize;

  • crop;

  • modify for production purposes;

  • transmit;

  • store; and

  • otherwise process

that content only as reasonably necessary to:

  • provide the requested personalization;

  • create the product;

  • manufacture the product;

  • fulfill the order;

  • provide support;

  • resolve production issues;

  • maintain security; and

  • administer related services,

unless another use is separately disclosed and authorized.

This production license does not transfer ownership of the original photograph to Elfink.

The broader marketing license described in the User-Generated Content sections applies only where the content was voluntarily submitted under circumstances giving rise to that authorization.

44. Prohibited Content

You must not submit content that:

  • you do not have the right to provide;

  • unlawfully violates privacy rights;

  • unlawfully violates publicity rights;

  • infringes copyright or other intellectual-property rights;

  • contains unlawful content;

  • exploits a child;

  • contains abusive or illegal material; or

  • otherwise violates applicable Elfink Terms.

Elfink reserves the right, where reasonably necessary, to reject, suspend, quarantine, or delete submitted content or refuse production.

45. Business Transfers

If Elfink becomes involved in a:

  • merger;

  • acquisition;

  • investment;

  • financing;

  • corporate restructuring;

  • reorganization;

  • sale of assets;

  • insolvency proceeding; or

  • similar transaction,

personal information may be transferred or disclosed as part of that transaction where permitted by applicable law.

Any recipient of personal information would remain subject to applicable legal obligations concerning that information.

46. Changes to Our Service Providers

Our technology, production, payment, fulfillment, advertising, and logistics providers may change over time.

We may therefore update this Privacy Policy as our systems and business operations evolve.

We encourage customers to review this Policy periodically.

47. Changes to This Privacy Policy

Elfink may update this Privacy Policy to reflect changes relating to:

  • products;

  • personalization technology;

  • artificial-intelligence or image-processing systems;

  • vendors;

  • production partners;

  • advertising practices;

  • storage;

  • retention;

  • security;

  • customer-service systems;

  • legal requirements; or

  • business operations.

When we update this Policy, we will revise the Last Updated date.

Where applicable law requires additional notice or consent before materially different processing begins, we will take appropriate steps.

48. Contacting Elfink About Privacy

For:

  • privacy questions;

  • parental-consent concerns;

  • child-photo concerns;

  • access requests;

  • correction requests;

  • deletion requests;

  • marketing-content questions;

  • review-photo concerns;

  • consent withdrawals; or

  • other privacy matters,

please contact:

Elfink LLC
Nevada, United States

Email: service@elfink.com

When your request relates to an order, please provide the order number and email address associated with the purchase where possible.

When your request relates to User-Generated Content, please provide sufficient information for us to locate the content.

49. Our Commitment to Children's Privacy

Personalization requires trust.

A family may provide Elfink with photographs and information relating to some of the people most important to them.

We recognize that photographs of children deserve particular care.

Our goal is to:

  • collect only information reasonably necessary for legitimate purposes;

  • clearly distinguish private customization photos from public review content;

  • restrict access to sensitive customization files;

  • limit retention;

  • avoid unnecessary collection;

  • avoid using private child customization photos for unrelated advertising;

  • provide meaningful privacy choices;

  • protect information throughout production and fulfillment; and

  • give parents and customers practical ways to contact us when they have questions.

A photograph uploaded to create a personalized book is personal information entrusted to us for that purpose. It is not automatically advertising content.

When a customer separately and voluntarily submits a photograph, video, review, or testimonial for public review or promotional use, we may use that material only under the permissions, notices, and legal rights applicable to that submission.

That distinction is an important part of the way Elfink approaches privacy.

50. Additional Notice

This Privacy Policy is intended to provide transparency regarding Elfink's privacy practices.

Nothing in this Policy is intended to waive, restrict, or eliminate privacy or consumer rights that cannot lawfully be waived, restricted, or eliminated.

Where mandatory law provides greater protection than this Policy, the applicable mandatory legal requirements will control.

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