Effective Date: June 18, 2026

1. Introduction

The Elephant Sanctuary in Tennessee (“The Elephant Sanctuary,” “we,” “us,” or “our”), a 501(C)(3) NonProfit Corporation, respects the privacy of your information. This Privacy Policy is designed to explain how we collect, use, disclose, and otherwise process Personal Information in connection with our websites, mobile applications, and other online or offline services that link to this Privacy Policy, including www.elephants.com (the “Site”) and the services, features, or content we offer (collectively, the “Services”).

This Privacy Policy is incorporated into and forms part of our Terms of Use and Website Cookie Policy. By using the Services, you agree you have read and understand this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Services.

You must be at least 18 years of age to use the Services. By using the Services, you represent and warrant that you are at least 18 years old.

If you have any questions or concerns about our use of your Personal Information, please contact us at privacy@elephants.com.

2. Information We Collect

We collect information in various ways depending on how you interact with our Services.

a. Personal Information

“Personal Information” means information that may identify, relate to, describe, or that could be linked or associated with, you or your household. Personal Information collected through Services may include: first and last name(s), mailing address, e-mail address, phone number, organization, payment information, geolocation information, and/or IP address. Users may also disclose communication preferences, physical location, and demographic information.

Billing information may be collected when users make a donation, contribute to an endowment fund, become a member, symbolically adopt an elephant, join The Elephant Sanctuary’s VIP Program, or make a purchase on or through the website (credit card number and billing address). Information may also be provided through online campaigns run through third parties. Physical mailings (pledge cards, inner envelopes) may also collect information including names, email, mailing address, phone, organization, and payment information.

Additionally, donors may elect to make Tribute Donations on behalf of another. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and you hereby authorize The Elephant Sanctuary to use the information in accordance with this Privacy Policy.

If you choose to process a payment on or through features on the Services, you may be required to provide Personal Information to third parties for services such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. In such cases, the information may be used by us and by such third parties, each pursuant to its own policies. You agree that we are not responsible for third parties’ processing of your information.

b. Non-Personal Information

“Non-Personal Information” means information that does not identify you, but provides insights regarding your use of the Site. This includes: internet connections, computer equipment, web browsers, URLs of sites visited before using the Site, traffic and usage information. Non-Personal Information is collected via automated tools such as Cookies and Web Beacons. Users can set browsers to reject cookies but that may limit use of certain features.

Web Beacons: Web Beacons are tiny graphics with a unique identifier included on Services for purposes including delivering or communicating with Cookies, tracking and measuring performance, and monitoring visitor counts.

Log Data: Log Data includes information such as IP address, browser type, operating system, pages/features browsed and time spent, search terms, links clicked, and other statistics.

Push Notifications: Users may be given the option to receive push notifications. To serve push notifications, we may need to collect your IP address and a persistent identifier from your device. Push notifications can be turned off in your device settings.

For more information on cookies, please reference our Cookie Notification Policy.

Personal Information and Non-Personal Information are collectively referenced as “Information.”

In some jurisdictions (e.g., the EEA), an IP address is considered Personal Information under applicable data protection laws. If so, Non-Personal Information is processed for the same purposes as Personal Information under this Policy.

c. Geolocation Information

You may choose to allow access to your location by granting the Site access when prompted or through your device’s location services settings. You may change these settings on your device, but this will impact your use of and access to the Services. When connected to Services, The Elephant Sanctuary can recognize the IP address of the computer providing internet access, which may be used to help diagnose server problems or otherwise administer Services. Your IP address may also be used to gather broad demographic information. Your IP address is never associated with you as an individual and never provided to another company or organization.

d. Third-Party Social Networking Service(s)

If you access or use third-party social networking services integrated with the Services, we may receive Personal Information and other information about you and your device that you have made available to those services, including contacts information. Some social networking services allow you to push content or pull contact information. Some allow interaction with elephant tribute pages and other features. The decision to use such services is voluntary. We encourage you to review the privacy policies of those providers.

We may obtain information, including Personal Information, from third parties and sources other than the Site, such as partners or advertisers. If we combine or associate information from other sources with Personal Information collected through the Services, we will treat the combined information as Personal Information in accordance with this Policy.

3. Use of Information

We use Non-Personal Information to: store preferences, improve website navigation, make personalized features available, generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of policies, improve products, services, materials, and content, and administer and improve Services.

Please reference our Cookie Notification Policy for more information on tracking technology.

We use Personal Information for the following legitimate business purposes:

• To process donations
• To complete purchase transactions
• To fulfill or meet the reason Personal Information was provided (e.g., responding to inquiries)
• To respond to requests and provide user support
• To evaluate and improve content of Services
• To customize Services to your preferences
• To establish and secure accounts, check account status, and validate credentials
• To communicate information and promotional materials (where no preference otherwise expressed)
• To notify of changes to agreements or policies
• For research analysis
• To provide, support, personalize, and develop Services
• To conduct aggregate analysis and develop business intelligence
• To enforce agreements, terms, conditions, and policies
• To work with service providers bound by contractual obligations consistent with this Privacy Policy
• To prevent or investigate fraud or for risk management purposes
• To comply with legal obligations, court orders, or exercise/defend legal claims
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other transfer
• To describe Services to current and prospective business partners
• As otherwise described when collecting Personal Information

Email Communications: Our email communications are an opt-in program. You may opt out at any time by clicking the “unsubscribe” link in any promotional email or by contacting privacy@elephants.com.

Surveys: We may invite you to participate in online surveys. Information requested may include opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent. This information is used to research market trends, company growth, community needs, and related purposes.

We may anonymize or aggregate Information, including de-identified demographic information, de-identified location information, device information, market trends, and analysis.

Consent Basis (EEA Data Subjects): We process your Personal Information on the basis of consent to send email/postal mail updates and news, process your requests, process commercial transactions (donations, orders, subscriptions), and process Personal Information as described in this Policy.

Performance of a Contract Basis: We process your Personal Information as necessary for the performance of a contract to establish accounts, validate credentials, respond to requests, provide merchandise, fulfill subscriptions, fulfill donations, notify contest/sweepstakes results, send service information and order updates, and notify of changes to agreements/policies.

4. How We Share Information

The Elephant Sanctuary does NOT sell or rent Personal Information.

We may share your information with:

• Service providers that help administer and provide Services (e.g., web hosting). Third-party providers have access to Personal Information only for performing services on our behalf. While we seek to require appropriate privacy policies and prohibit unauthorized use, we do not bear responsibility for the actions or policies of third parties.
• Authorized third parties directly authorized by you to receive applicable Information (subject to the third party’s privacy policy).
• Third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition (including bankruptcy), requiring the recipient to use information pursuant to this Policy.
• As necessary: (i) under applicable law; (ii) to enforce our terms; (iii) to protect our rights, privacy, safety, or property; (iv) to detect or prevent fraud, security, or technical issues; (v) to respond to claims of unauthorized posting of contact information or harassment; or (vi) to respond to courts, law enforcement, regulatory agencies, or government authorities (which may include authorities outside your country of residence).
• Pursuant to your express consent.

5. Behavioral Advertising

We may use Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We share information about your use of the Site, purchases, and interaction with advertisements on other websites with our advertising partners. We collect and share some of this information directly and some through cookies or similar technologies.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising through the following links:

• Meta (Facebook): https://www.facebook.com/settings/?tab=ads
  • Meta Privacy Policy - How Meta collects and uses user data | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy
  • Instagram: Data Policy | Instagram Help Center
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• Google: See Section 6 below.
• Digital Advertising Alliance opt-out portal: https://optout.aboutads.info/

6. Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data may be shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

We use Google Analytics to help us understand how our customers use the Site. You can opt out of having your activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page: https://policies.google.com/privacy.

7. Information Security

We take the security of your information seriously and use reasonable measures to protect it. Our security measures include: Secure Socket Layer (SSL) encrypted connections via HTTPS protocols, data encryption tools, multifactor authentication, access and identity management systems, industry-standard firewalls, regular security updates and patches, and other security safeguards.

However, transmission of information via the internet is not wholly secure, and we cannot guarantee the security of your information transmitted through the Services. We are not responsible for any theft, destruction, or inadvertent disclosure of your information. It is your responsibility to safeguard passwords, ID numbers, or other special access features. Any transmission is at your own risk.

If you have questions about the security of your information, or if you become aware of any unauthorized use or loss of your credentials, or suspected unauthorized access to your account, please notify us immediately via e-mail at privacy@elephants.com.

If our security system is breached, we will notify you to the extent required under applicable law.

8. Information Retention

We retain Personal Information for as long as you use the Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. If you have questions regarding our retention practices, please contact privacy@elephants.com.

9. Links to Third-Party Sites

The Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. Such links do not constitute an endorsement by The Elephant Sanctuary. This Privacy Policy does not apply to third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies and terms of all third-party websites and services that you visit.

10. Children’s Privacy

We do not sell products or services for purchase by anyone under the age of 13. In accordance with the Children’s Online Privacy Protection Act (COPPA), we will never knowingly request or solicit Personal Information from anyone under the age of 13 without verifiable parental consent. If we obtain actual knowledge that we have collected Personal Information from a child under 13 without consent, we will delete that information from our database as quickly as practical. We reserve the right to request proof of age at any stage to verify that minors are not using the Services.

11. Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made once a year, free of charge. You are entitled to make such a request by e-mailing privacy@elephants.com. Please reference our California Privacy Notice for more information.

12. Additional Information for Certain U.S. Residents and Their Consumer Data Privacy Rights

Depending on your state of residence, you may have additional rights regarding your Personal Information. The following is a summary of the rights that may be available to you under applicable state privacy laws:

• Right to Access / Know: You have the right to request that we disclose what Personal Information we have collected, used, disclosed, and sold about you.
• Right to Delete: You have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions.
• Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you.
• Right of Portability: You have the right to request a copy of your Personal Information in a portable and readily usable format.
• Right to Opt Out of Sale or Targeted Advertising: You have the right to opt out of the sale of your Personal Information or the use of your Personal Information for targeted advertising purposes. Please note that we do not currently sell Personal Information.
• Right to Opt Out of Profiling: You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit our use and disclosure of your Sensitive Personal Information. We will not process Sensitive Personal Information without your consent.
• Right Not to Be Discriminated Against: You have the right not to receive discriminatory treatment for exercising any of your privacy rights.
• Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information under certain circumstances.
• Withdrawal of Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
• Appeal: If we deny your privacy rights request, you have the right to appeal that decision.
• Managing Communication Preferences: You may opt out of receiving promotional emails by following the unsubscribe instructions in those emails. Please note that you may still receive non-promotional communications from us.

You may exercise these rights by contacting us using the contact details provided below. We may choose not to honor a request where we are not legally obligated to do so; we may also honor a request where not legally obligated, in our sole discretion. We may need to collect information to verify your identity (such as your email address or account information). You may designate an authorized agent to submit a request on your behalf; we may require proof of authorization and direct identity verification. We will respond in a timely manner as required under applicable law.

13. Additional Information for UK and EEA Residents

If you are located in the United Kingdom or the European Economic Area (EEA), the following additional information applies to you.

a. Legal Bases for Processing

We process your Personal Information under the following legal bases:

Legitimate Interests: We process Personal Information as necessary for our legitimate interests, including to administer Services, diagnose problems, communicate information, improve and customize Services, work with service providers, show content, prevent and investigate fraud, and comply with legal obligations.

Performance of a Contract: We process Personal Information as necessary for the performance of a contract with you, including to establish your account, validate credentials, respond to your requests, provide merchandise, notify you of contest or sweepstakes results, and notify you of changes to agreements or policies.

Consent: We process Personal Information based on your consent to share information with affiliates, process your requests and transactions, send you updates and news, and process Personal Information as described in this Policy.

b. Your Choices, Access, and Rights

As a UK or EEA resident, you have the following rights regarding your Personal Information:

• Right to Access: You may log into your account or contact us to request access to your Personal Information. We may require identity verification and may charge a fee where permissible under applicable law.
• Updating Communications Preferences / Opt-Out / Unsubscribing: You may opt out of promotional offers and newsletters by contacting privacy@elephants.com or by clicking the unsubscribe link in our emails.
• Right to Rectify - Correction and Deletion: You may request that we correct or amend your Personal Information if it is inaccurate, or request deletion subject to legal requirements. You may update your account information by contacting privacy@elephants.com.
• Right to Erasure / Be Forgotten: You may request deletion of your Personal Information in certain circumstances. Please note that compliance with an erasure request may also result in the deletion of research data you have submitted through the Services. You are responsible for compliance with your own data retention rules.
• Right to Object: You may object to the use of your Personal Information for direct marketing, scientific, or historical research purposes. You may contact our Data Protection Officer or unsubscribe from commercial messages. We may continue to send you transactional messages.
• Right to Restrict Processing: You may request that we stop or restrict the processing of your Personal Information.
• Right to Data Portability: You may request that we provide your Personal Information for sharing with another service provider via a secure process.
• Filing a Complaint: You have the right to complain to a data protection regulator.

c. Geographic Information Transfers

If you are located outside of the United States, your information will be transferred to, processed, and stored in the United States in accordance with this Privacy Policy and applicable U.S. and EU privacy laws. The laws governing data in the United States may differ from those in your jurisdiction, and an adequacy decision may not exist for your country. Our commitments to safeguarding your privacy remain unchanged regardless of where your data is processed. We seek to comply with all applicable cross-border data disclosure laws.

d. Data Protection Officer

We have appointed a Data Protection Officer: Jessica Howell. For inquiries regarding your Personal Information, please send a message to privacy@elephants.com.

14. Changes in the Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time by posting the amended version on the Site. We encourage you to refer to this Policy regularly. If we decide to use Personal Information in a manner materially different from that stated at the time of collection, we will notify you on our home page or via e-mail.

15. How to Contact Us

If you have questions or comments about this Privacy Policy, or if you would like to make a complaint, please contact us:

• By e-mail: privacy@elephants.com
• By telephone: (888) 229-9161
• By regular mail: The Elephant Sanctuary in Tennessee, Attn: Privacy Inquiry, P.O. Box 393, Hohenwald, TN 38462