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EEA Privacy Addendum

Transferring EEA/UK citizens’ information outside of Europe

As part of the services offered to you through the Eficen’s websites and if you are located in the European Economic Area or United Kingdon (“EEA/UK”), the information that you provide to us will be transferred to countries outside the EEA/UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing.

If you use our services while you are outside the EEA/UK, your information may be transferred outside the EEA/UK in order to provide you with those services.

The Legal Bases for Using Your Personal Information

We collect your information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:

    • Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products
      and services and to provide you with information you request); you have a right to object to processing as explained in the section below entitled Your Legal Rights;
    • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example, to facilitate your participation a trial class that you have requested, where we use your personal information to respond to your customer service requests, to provide our services through our Websites; and/or
    • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).
    • Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with another party for their own marketing).


Retention of Your Personal Information

We retain your personal information for as long as necessary to provide our services to you, to fulfill the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.

Your Legal Rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you may have the following rights regarding your personal information:

Right to access, correct and delete your personal information

You have the right to request access to the personal information that we hold about you and:

  1. the source of your personal information;
  2. the purposes, legal basis and methods of processing;
  3. the data controller’s identity; and
  4. the entities or categories of entities to whom your personal information may be transferred.

You also have the right to request that we delete your information.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the
establishment, exercise, or defense of legal claims. 

Right to restrict the processing of your personal information

You have the right to restrict the use of your personal information when:

  1. you contest the accuracy of the data;
  2. the use is unlawful but you do not want us to erase the data;
  3. we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or
  4. you have objected to our personal information use where such use is justified on our legitimate interests and we must verify as to whether we have a compelling
    interest to continue to use your data.

We can continue to use your personal information following a request for restriction, where:

  • we have your consent; or
  • to establish, exercise or
    defend legal claims; or
  • to protect the rights of
    another natural or legal person.

Right to data portability

To the extent that we process your information 

    (i) based on your consent or under a contract; and 

    (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms
outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to obtain a  copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the UK/EEA.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt
to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How to Exercise Your Rights

If you would like to exercise any of the rights described above, please contact us by email at [email protected] or phone at +1 678-892-9800. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.