Last Updated: July 28, 2025
1. Introduction
Efficiency ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including our transfer agent services, investor relations platform, and capital markets solutions.
2. Information We Collect
2.1 Personal Information
We may collect the following types of personal information:
- Contact Information: Name, email address, phone number, mailing address
- Account Information: Username, password, account preferences
- Financial Information: Shareholder records, transaction history, dividend information
- Corporate Information: Company details, tax identification numbers, regulatory filings
- Professional Information: Job title, company affiliation, industry
2.2 Technical Information
We automatically collect certain technical information when you use our services:
- Device Information: IP address, browser type, operating system
- Usage Data: Pages visited, time spent on site, click patterns
- Cookies and Tracking: Session cookies, analytics cookies, preference cookies
- Log Files: Server logs, error logs, access logs
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Provision: To provide and maintain our transfer agent and financial services
- Account Management: To create and manage your account, process transactions
- Communication: To send important updates, notifications, and respond to inquiries
- Compliance: To meet regulatory requirements and legal obligations
- Security: To protect against fraud, unauthorized access, and security threats
- Improvement: To enhance our services, develop new features, and improve user experience
- Analytics: To analyze usage patterns and optimize our platform
4. Information Sharing and Disclosure
We may share your information in the following circumstances:
- Service Providers: With trusted third-party vendors who assist in providing our services
- Regulatory Authorities: When required by law, regulation, or legal process
- Business Transfers: In connection with mergers, acquisitions, or asset sales
- Security: To protect our rights, property, or safety, or that of our users
- Consent: With your explicit consent for specific purposes
5. Data Security
We implement appropriate technical and organizational measures to protect your information:
- Encryption: Data is encrypted in transit and at rest using industry-standard protocols
- Access Controls: Strict access controls and authentication mechanisms
- Regular Audits: Regular security assessments and vulnerability testing
- Employee Training: Ongoing security training for all employees
- Incident Response: Comprehensive incident response and breach notification procedures
6. Data Retention
We retain your information for as long as necessary to:
- Provide our services and maintain your account
- Comply with legal and regulatory requirements
- Resolve disputes and enforce our agreements
- Protect against fraud and security threats
When we no longer need your information, we will securely delete or anonymize it.
7. Your Rights and Choices
Depending on your location, you may have the following rights:
- Access: Request access to your personal information
- Correction: Request correction of inaccurate or incomplete information
- Deletion: Request deletion of your personal information
- Portability: Request a copy of your data in a portable format
- Restriction: Request restriction of processing in certain circumstances
- Objection: Object to processing based on legitimate interests
- Withdrawal: Withdraw consent where processing is based on consent
8. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Remember your preferences and settings
- Analyze website usage and performance
- Provide personalized content and advertisements
- Ensure security and prevent fraud
You can control cookie settings through your browser preferences, though disabling certain cookies may affect service functionality.
9. International Data Transfers
Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers, including:
- Standard contractual clauses approved by regulatory authorities
- Adequacy decisions by relevant data protection authorities
- Other appropriate safeguards as required by applicable law
10. Children's Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
- Posting the updated policy on our website
- Sending email notifications to registered users
- Displaying prominent notices on our platform
Your continued use of our services after such changes constitutes acceptance of the updated policy.
12. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
13. Data Protection Officer
For privacy-related inquiries, you may also contact our Data Protection Officer at the same contact information above.
14. Regulatory Compliance
This Privacy Policy complies with applicable data protection laws and regulations, including but not limited to:
- California Consumer Privacy Act (CCPA)
- General Data Protection Regulation (GDPR)
- Gramm-Leach-Bliley Act (GLBA)
- Other applicable federal and state privacy laws
