Privacy Policy

Effective Date: July 3rd, 2024
Last Updated: November 25th, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. 

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party.
  • Company, Data Controller, “We”, “Us” or “Our” refers to Efficacity LLC.
  • Cookies are small files that are placed on Your device.
  • Country refers to: Massachusetts, United States
  • Device means any device that can access the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Efficacity, accessible from efficacity.net
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

We process your personal data based on:

(a) Your consent (where applicable)
(b) The performance of a contract
(c) Our legitimate interests
(d) Compliance with legal obligations

Our Legitimate Interests (Required Under GDPR/UK GDPR)

We rely on legitimate interests for:

  • Improving and optimizing our Website and services

  • Ensuring security and preventing fraud

  • Conducting analytics to enhance user experience

  • Communicating with existing customers

  • Developing new features and improving functionality

Personal Data You Provide

May include:

  • Email address

  • First and last name

  • Phone number

  • Address, City, State, ZIP code

  • Any information voluntarily submitted

Usage Data

Collected automatically, including:

  • IP address

  • Browser type

  • Pages visited

  • Time spent on pages

  • Device identifiers

  • Diagnostic data

Tracking Technologies and Cookies

We will only set non-essential cookies after you provide consent through our cookie banner (required in UK/EU).

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. We will only set non-essential cookies (e.g., analytics, marketing) after you have provided consent via our cookie banner. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity)

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
    • Type: Session Cookies
    • Administered By: Us
    • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
    • Type: Persistent Cookies
    • Administered By: Us
    • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
    • Type: Persistent Cookies
    • Administered By: Us
    • Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Additional U.S. State Privacy Rights 

Residents of Colorado, Connecticut, Virginia, Utah, and other U.S. states with privacy laws may also have rights including:

  • Right to confirm whether we process your data

  • Right to access your personal data

  • Right to delete personal data

  • Right to correct inaccuracies

  • Right to data portability

  • Right to opt out of:

    • Targeted advertising

    • Sale of personal data

    • Profiling with significant effects

  • Right to appeal a denied request

To exercise rights, email us at Brian@efficacity.net

We do not sell personal data or share it for cross-context behavioral advertising.

 

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
Your Rights Under CCPA/CPRA

California residents have the following rights regarding their personal information:

  • Right to Know and Access – You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the purposes for collecting or sharing it, and the categories of third parties with whom we share it.
  • Right to Delete – You have the right to request that we delete any personal information we have collected from you, subject to certain exceptions (such as to comply with legal obligations or complete transactions).
  • Right to Correct – You have the right to request that we correct any inaccurate personal information we maintain about you.
  • Right to Opt-Out of Sale or Sharing – We do not “sell” personal information as traditionally understood. However, if we engage in activities that may constitute a “sale” or “sharing” under the CCPA/CPRA (such as using third-party analytics or advertising services), you have the right to opt out. You can exercise this right by clicking the “Do Not Sell or Share My Personal Information” link on our website, if applicable.
  • Right to Limit the Use of Sensitive Personal Information – If we collect sensitive personal information, you have the right to limit our use of that information to only what is necessary to provide our services.
  • Right to Non-Discrimination – We will not discriminate against you for exercising any of your privacy rights, such as denying services, charging different prices, or providing a different level of quality.
Automated Decision-Making and Profiling (GDPR Article 22)

We do not use your Personal Data to make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.

If we ever implement automated decision-making processes in the future (for example, to evaluate certain user preferences or to deliver tailored content), we will ensure that such processing:

  • Is necessary for entering into, or the performance of, a contract between you and us;
  • Is authorized by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  • Is based on your explicit consent.

In such cases, we will implement suitable measures to safeguard your rights, freedoms, and legitimate interests, including at least the right to obtain human intervention on our part, to express your point of view, and to contest the decision.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, we apply the following retention periods:

  • Account information: retained for the life of the account and up to 6 years after closure.
  • Transaction data: retained for up to 7 years for tax and legal purposes if applicable.
  • Marketing data: retained until you withdraw consent or opt-out.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.

Recipients of Your Personal Data

We may disclose your Personal Data only as necessary to fulfill the purposes described in this Privacy Policy and in accordance with applicable privacy laws. The categories of recipients who may receive your data include:

  • Service Providers and Processors: Companies that perform services on our behalf — such as hosting, analytics, payment processing, communications, customer support, and marketing — under contractual obligations to keep your data secure and use it only as instructed.
  • Business Partners: In limited cases, we may share data with partners who help us deliver or improve our services, subject to lawful processing requirements.
  • Affiliates: Our corporate affiliates and subsidiaries, where necessary to provide our services or operate our business.
  • Legal and Regulatory Authorities: Where required by law or legal process, we may disclose Personal Data to public authorities, regulators, law enforcement, courts, or similar entities.
  • Corporate Transactions: In connection with a merger, acquisition, reorganization, or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to appropriate safeguards.

We do not sell Personal Data or share it for cross-context behavioral advertising (as those terms are defined under U.S. state privacy laws).

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices in the United States and in other locations where the parties involved in the processing are located. It means that this information may be transferred to — and stored on — computers located outside of Your country, province, country, governmental jurisdictions, or other European Economic Area (EEA) where data protection privacy laws may differ those from Your jurisdiction.

We transfer personal data to the United States on the basis of Standard Contractual Clauses approved by the European Commission, which provide appropriate safeguards for the protection of your data. While we implement these safeguards, please note that U.S. laws may allow public authorities to access your data for national security or law-enforcement purposes, which may not provide the same level of protection as in the EEA.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Under the GDPR, you have the right to request access to, correction of, or deletion of your personal data, to object to or restrict its processing, and to request a copy of your data in a structured, machine-readable format.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

How to Lodge a Complaint under GDPR Article 13(2)(d):

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local data protection authority in the EEA or with the Supervisory Authority in your country.

Additional UK/EU Transfer Compliance Requirements

Because Efficacity LLC is located in the United States, transfers from the EU/EEA and United Kingdom require specific legal mechanisms:

A. EU/EEA Transfers

We rely on:

  • EU Standard Contractual Clauses (SCCs)
  • Technical and organizational safeguards
B. UK Transfers

We rely on:

  • The UK Addendum to the EU SCCs, or
  • The UK International Data Transfer Agreement (IDTA)
C. EU Representative (Placeholder Required by GDPR Article 27)

Because Efficacity LLC has no EU establishment:

EU Representative:
[Insert EU Representative Name/Company]
[Insert Address]
[Insert Email]
D. UK Representative (Placeholder Required by UK GDPR Article 27)
UK Representative:
[Insert UK Representative Name/Company]
[Insert Address]
[Insert Email]
 

How to Lodge a Complaint Under GDPR / UK GDPR (Expanded Required Section)

You may lodge a complaint with:

A. Your local EU Data Protection Authority

(If you live in the EU/EEA)

B. The UK Information Commissioner’s Office (ICO)

Required for UK compliance:

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Under the GDPR, you have the following rights:

  • Right of access – to request a copy of the personal data we hold about you.
  • Right to rectification – to correct inaccurate or incomplete data.
  • Right to erasure – to request deletion of your personal data.
  • Right to restrict processing – to request that we limit how we use your data.
  • Right to data portability – to receive your data in a structured, machine-readable format.
  • Right to object – to object to processing based on legitimate interests or direct marketing.
  • Right to withdraw consent – where we rely on consent, you may withdraw it at any time
Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Policy

In accordance with the U.S. Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect, use, or disclose personally identifiable information from anyone under the age of 13 in the United States.

If you are located in the European Economic Area (EEA), you must be at least 16 years old to provide consent to the processing of your personal data. Where consent is required, and you are under 16, we will require authorization from your parent or legal guardian before collecting or processing your personal data. Some EU member states may set a lower age threshold (not below 13), and we will comply with the applicable local requirements in those jurisdictions.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 in the United States or under the age of 16 in the European Economic Area without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Your GDPR / UK GDPR Rights (Expanded for Compliance)

In addition to previously stated rights, you may:

  • Withdraw consent at any time

  • Object to processing based on legitimate interests

  • Request restriction of processing

  • Request data portability

  • Request erasure (“right to be forgotten”)

  • Request human review for decisions made by automated systems (if applicable)

 

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: