1. Key terms
It would be helpful to start by explaining some key terms used in this policy:
- We, us, our refers to Efflux, LLC or Efflux
- Personal information refers to any information relating to an identified or identifiable individual
2. Personal information we collect about you
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories of personal information | Specific types of personal information collected |
|---|---|
| Identifiers | To establish a user account, we collect your name and email address. If you become a paying customer, we will request your payment information via a third-party payment processor. |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences. | We draw inferences from how you use our services to understand what types of results are most relevant and important to you. |
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
3. How your personal information is collected
We collect most of this personal information directly from you: in person, by email, or via our services. In addition, we may also collect information:
- From publicly accessible sources;
- From cookies on our website; and
- Via our IT systems, including automated monitoring of our websites and infrastructure.
4. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
|---|---|
| To provide products and services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information |
| To comply with our legal and regulatory obligations | To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you; to comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
| External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; to comply with our legal and regulatory obligations |
5. Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organizations or groups for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at privacy@efflux.io; or
- Using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
7. Where your personal information is held
Information may be held on our servers or third-party service providers (see above: “Who we share your personal information with”).
8. How long your personal information will be kept
We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
9. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. How to exercise your rights
If you would like to exercise any of your rights as described in this privacy policy, please email us at privacy@efflux.io.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
11. Changes to this privacy notice
This privacy notice was published on June 6, 2023 and last updated on June 6, 2023.
We may change this privacy notice from time to time. When we do, we will inform you via our website or other means of contact such as email.
12. How to contact us
Please contact us by email if you have any questions about this privacy policy or the information we hold about you: privacy@efflux.io.
13. Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).