Privacy Policy
Effective Date: September 14, 2026
This Privacy Policy explains how Efficion LLC collects, uses, discloses, retains, and protects Personal Information in connection with Efferent and its related products and services.
1. Scope and Acceptance
This Privacy Policy explains how Efficion LLC ("Efficion," "we," "us," or "our") collects, uses, discloses, retains, and protects Personal Information in connection with Efferent, including the Efferent website, applications, APIs, dashboards, communications tools, customer engagement services, and related products and services (collectively, the "Services"). By using the Services, you acknowledge the practices described in this Policy. If you use Efferent on behalf of an organization, you represent that you are authorized to do so and that references to "you" include that organization.
2. Definitions
"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual, as defined by applicable privacy law. "Customer Data" means data submitted to or processed through Efferent by a customer or its authorized users, including message content, contact records, social interactions, campaign information, and other customer-controlled information. "Processing" includes collection, access, use, storage, disclosure, transmission, analysis, alteration, and deletion. "Controller" or "Business" and "Processor" or "Service Provider" have the meanings assigned by applicable law.
3. Information We Collect
We may collect: (a) account and identity information, such as name, business name, email address, telephone number, login credentials, and role; (b) billing and transaction information, such as subscription, invoices, and payment status; (c) usage and technical information, such as IP address, device and browser information, log data, approximate location derived from IP address, authentication events, and product usage; (d) Customer Data submitted through the Services; (e) communications and support information; (f) information received through connected third-party platforms and APIs, subject to the permissions granted to Efferent and the applicable platform terms; and (g) information collected through cookies and similar technologies.
4. Sources of Information
We collect information directly from users and customers; automatically through use of the Services; from administrators and organizations that provision accounts; from service providers; and from third-party platforms or integrations when a customer authorizes a connection. We do not intentionally collect more information than reasonably necessary for the purposes described in this Policy.
5. How We Use Information
We may use Personal Information to provide, operate, maintain, secure, and improve the Services; authenticate users; process transactions; deliver messages and communications at the customer's direction; manage the Unified Inbox, Social Engagement, Social Listening, Automation Studio, analytics, webhooks, APIs, and AI Engagement features; provide customer support; detect fraud, abuse, security incidents, and violations of applicable terms; perform analytics and product improvement; comply with legal obligations; enforce agreements; and communicate about service, security, administrative, or transactional matters. Where required by law, we rely on an applicable legal basis for processing, including performance of a contract, legitimate interests, consent, compliance with legal obligations, or protection of vital interests.
6. Customer Data and Customer Instructions
As between Efficion and a customer, the customer generally retains its rights in Customer Data. Efficion processes Customer Data to provide the Services and according to the customer's documented instructions, contractual terms, and applicable law. Customers are responsible for determining whether their collection and use of Personal Information is lawful and for providing required notices and obtaining required consents or other permissions.
7. Communications and Messaging Data
Efferent may process telephone numbers, email addresses, message content, delivery information, recipient identifiers, opt-in/opt-out information, and related metadata when customers use SMS, WhatsApp, email, or other communications features. Customers are responsible for lawful consent, disclosures, sender identification, opt-out mechanisms, content restrictions, and compliance with applicable messaging, telecommunications, marketing, and platform rules. Efficion may suspend or restrict messaging activity when reasonably necessary to protect users, third parties, the Services, or platform providers.
8. Social and Third-Party API Data
Efferent may connect with services such as Facebook, Instagram, X, TikTok, LinkedIn, WhatsApp, Twilio, and other authorized providers. Depending on the integration and permissions granted, Efferent may receive messages, comments, posts, account identifiers, engagement information, profile information, media, analytics, webhook events, or other permitted data. Such data is used to provide the requested integration and related Efferent functionality. Third-party providers independently control their own services and privacy practices. API access may be limited, modified, revoked, or discontinued by the applicable provider.
9. AI Features
Efferent may provide AI-assisted content generation, summarization, classification, recommendations, analytics, workflow assistance, and suggested responses. AI features may process information submitted for those functions. Customers should avoid submitting sensitive information unless the applicable service configuration and contractual terms permit it. AI outputs may be inaccurate or incomplete and should be reviewed before consequential use. Efficion does not use Customer Data to train a general-purpose AI model except where expressly authorized by contract or otherwise permitted by applicable law and disclosed to the customer.
10. Cookies and Similar Technologies
We may use cookies, local storage, pixels, SDKs, and similar technologies for authentication, security, preferences, analytics, performance, and service functionality. Where required, we obtain consent for non-essential cookies. Browser controls and available consent tools may allow you to manage certain technologies. Disabling essential technologies may impair portions of the Services.
11. How We Disclose Information
We may disclose information to: (a) service providers and subprocessors that process information on our behalf; (b) third-party platforms selected and authorized by a customer; (c) payment, hosting, communications, analytics, security, and infrastructure providers; (d) professional advisers subject to appropriate confidentiality obligations; (e) governmental authorities or other parties where required by law or legal process; (f) parties involved in a merger, acquisition, financing, reorganization, or sale of assets, subject to applicable law; and (g) other parties with your direction or consent. We do not sell Personal Information for monetary consideration in the ordinary operation of Efferent.
12. International and Cross-Border Processing
Efficion may process information in the United States and other jurisdictions where Efficion, its affiliates, service providers, subprocessors, or integration partners operate. Where applicable law requires a lawful transfer mechanism, we will use an appropriate mechanism, such as contractual safeguards or other legally recognized measures.
13. Data Retention
We retain Personal Information and Customer Data for as long as reasonably necessary to provide the Services, fulfill contractual and legal obligations, resolve disputes, enforce agreements, maintain security, and otherwise fulfill the purposes described in this Policy. Retention periods may vary by data type, service configuration, customer contract, legal requirement, and deletion request. Customers may request deletion of Customer Data subject to contractual and legal requirements.
14. Security
Efficion maintains administrative, technical, and organizational safeguards designed to protect Personal Information against unauthorized access, alteration, disclosure, destruction, and loss. Measures may include access controls, authentication, encryption in appropriate contexts, logging and monitoring, secure software development practices, vulnerability management, backup and recovery controls, and vendor risk management. No method of transmission or storage is completely secure, and Efficion cannot guarantee absolute security.
15. Data Breach and Incident Response
Efficion maintains incident management processes designed to detect, investigate, contain, remediate, and document security incidents. Where required by applicable law or contract, Efficion will provide notice of qualifying incidents to affected customers or authorities within the applicable time period and with information reasonably available at the time.
16. GDPR and EEA/UK/Swiss Privacy Rights
Where GDPR or substantially similar data protection law applies, individuals may have rights including access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent where processing is based on consent. Individuals may also have the right to lodge a complaint with a competent supervisory authority. Where Efficion acts as a processor, requests relating to Customer Data should ordinarily be directed to the applicable customer/controller. Where Efficion acts as a controller, requests may be submitted using the contact information below. Efficion will assess each request under the law applicable to the requester and the relevant processing activity.
17. California and Other U.S. State Privacy Rights
Depending on residence and applicable law, U.S. consumers may have rights to know/access, correct, delete, obtain a copy of Personal Information, opt out of certain sales or targeted advertising, limit certain uses of sensitive Personal Information, and avoid unlawful discrimination for exercising privacy rights. Efferent is not intended to sell Personal Information for monetary consideration. Requests are subject to applicable statutory exceptions, verification requirements, and other limitations. California residents may exercise rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, by contacting us at the address below.
18. Verification and Authorized Agents
To protect Personal Information, we may need to verify your identity before completing a privacy request. We may request information reasonably necessary to match the request with information in our records. California residents may use an authorized agent where permitted by law, subject to applicable authorization and verification requirements.
19. Children's Privacy
The Services are intended for business and professional use and are not directed to children under 13. We do not knowingly collect Personal Information directly from children under 13. Where a higher minimum age applies under local law, that higher age requirement applies. If you believe a child has provided Personal Information improperly, contact us so that we can evaluate and take appropriate action.
20. Do Not Track and Global Privacy Controls
Some browsers transmit "Do Not Track" signals. Because there is not a uniform industry standard for responding to such signals, Efferent may not respond to all Do Not Track signals. Where required by applicable law, we will honor recognized opt-out preference signals, including applicable Global Privacy Control signals, for covered processing activities.
21. Data Protection Agreements
For business customers subject to data protection laws, Efficion may enter into a Data Processing Agreement ("DPA") addressing controller/processor roles, processing instructions, confidentiality, security, subprocessors, international transfers, data subject rights, incident notification, deletion or return of data, and related requirements. Where the DPA conflicts with this Policy concerning Customer Data, the applicable DPA controls to the extent of the conflict.
22. Subprocessors and Vendors
Efficion may use carefully selected subprocessors and vendors to provide hosting, databases, communications, authentication, analytics, customer support, security, payment, infrastructure, and other services. Efficion remains responsible for its subprocessors to the extent required by applicable law and contract. Customers may obtain applicable subprocessor information through the Efferent privacy or trust documentation and contractual process.
23. Data Minimization and Sensitive Information
Customers should use the Services in accordance with their intended functionality and should not submit sensitive or regulated information unless the applicable Efferent service, contract, and legal requirements support such processing. Efficion may impose restrictions on categories of information that may not be processed through particular features or integrations.
24. Your Responsibilities
Customers and users are responsible for maintaining accurate account information, securing credentials, configuring integrations appropriately, determining lawful purposes for communications, obtaining required permissions, honoring recipient preferences, and complying with applicable laws and third-party platform requirements. Customers must not use Efferent to unlawfully collect, infer, disclose, or exploit Personal Information.
25. Third-Party Websites and Services
The Services may contain links to or integrations with third-party websites and services. Efficion is not responsible for the privacy practices of independent third parties. Your use of a third-party service is governed by that provider's terms and privacy policy.
26. Corporate Transactions
If Efficion undergoes a merger, acquisition, financing, restructuring, bankruptcy proceeding, or sale of assets, Personal Information may be transferred as part of that transaction, subject to applicable legal requirements and appropriate safeguards.
27. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in the Services, law, technology, or business practices. We will post the revised Policy and update the effective date. Where required by law, we will provide additional notice or obtain consent before material changes take effect.
28. Contact and Privacy Requests
Privacy inquiries and rights requests may be submitted to privacy@efficion.org. Please identify the nature of your request and the jurisdiction in which you reside. Efficion may request information reasonably necessary to verify and process your request. We will respond within the period required by applicable law.
29. Governing Framework and Legal Disclaimer
This Privacy Policy is intended to describe Efficion's privacy practices and establish a clear framework for compliance with applicable privacy and data protection requirements, including GDPR, UK GDPR, CCPA/CPRA, and applicable U.S. state privacy laws. It does not create rights or obligations beyond those required by applicable law or an applicable written agreement. This Policy should be read together with the Efferent Terms of Service, applicable DPA, Cookie Policy, Acceptable Use Policy, and other contractual or legal notices.
30. Company Information
Efferent is a product and service operated by Efficion LLC. For privacy and data protection matters, contact: privacy@efficion.org.