1. Scope of this notice
Efficiency, Inc. ("Efficiency," "we," "us," or "our") provides transfer-agent and related capital-markets services. This Privacy Notice explains how we collect, use, disclose, and protect personal information through the Efficiency website, portals, and services that link to this notice.
This notice does not replace a customer agreement, issuer-specific notice, or other notice presented when information is collected. If those terms conflict with this notice, the more specific terms govern.
2. Personal information we collect
The information we collect depends on your relationship with Efficiency and the services involved. It may include:
- Website and inquiry information: name, work email address, company, service of interest, and the contents of a message submitted through our contact form.
- Identity and contact information: name, mailing and email addresses, telephone number, date of birth, government-issued identification information, and taxpayer identification information.
- Account and professional information: login and authentication data, organization, title, permissions, issuer relationship, and authorized-representative information.
- Securities and transaction information: security ownership, positions, certificates, transfers, issuances, distributions, elections, votes, transaction history, and related instructions.
- Financial and tax information: payment and banking details, withholding information, tax forms, and distribution records.
- Compliance information: identity-verification materials, sanctions and KYC review information, beneficial-ownership information, and related supporting documents.
- Communications: support requests, emails, forms, instructions, call notes, and other communications with us.
- Device, network, and activity information: IP address, browser and device information, page and feature activity, timestamps, security events, audit records, and diagnostic data.
Please do not place taxpayer identification numbers, banking instructions, account credentials, or other sensitive information in the public website contact form.
3. Sources of personal information
We may collect personal information directly from you; from issuers and other customers; from shareholders, account holders, authorized representatives, brokers, custodians, nominees, counterparties, and professional advisers; from service providers; and from government, sanctions, securities, and other lawful public sources.
4. How we use personal information
We use personal information to:
- respond to inquiries and communicate about our services;
- provide, administer, support, and improve transfer-agent and related services;
- authenticate users, manage permissions, and protect accounts;
- maintain shareholder, securities, transaction, payment, tax, proxy, and other required records;
- process authorized instructions, corporate actions, distributions, transfers, votes, and related transactions;
- perform identity, KYC, fraud, and sanctions checks and investigate exceptions;
- secure, monitor, troubleshoot, and audit our systems and services;
- comply with contracts, legal process, and securities, tax, unclaimed-property, recordkeeping, and other legal obligations; and
- establish, exercise, or defend legal claims and protect the rights and safety of Efficiency, our customers, users, and others.
5. How we disclose personal information
We may disclose personal information as reasonably necessary to:
- the issuer or customer for whom services are provided and its authorized personnel, advisers, agents, and counterparties;
- service providers supporting hosting, databases, cloud storage and backup, forms, communications, email delivery, security, monitoring, identity or compliance review, document processing, and other business operations;
- banks, payment providers, brokers, depositories, custodians, nominees, mailing providers, tax providers, and other parties involved in an authorized transaction or service;
- government authorities, regulators, courts, law enforcement, or other persons when required or permitted by law; and
- professional advisers, insurers, financing sources, and parties to a merger, financing, reorganization, acquisition, or other business transaction, subject to appropriate protections.
We may also disclose information at your direction or with your consent. We do not sell personal information or share it for cross-context behavioral advertising.
Service providers we currently use
The following providers process personal information on our behalf under contracts that restrict their use of it. All of them process it in the United States.
| Provider | What they do for us | Information involved |
|---|---|---|
| Neon Inc. | Database hosting | Platform records, encrypted at rest; tax identifiers and bank details additionally encrypted at the field level |
| Vercel Inc. | Application hosting and delivery | Requests in transit; configuration |
| Google LLC (Google Cloud, Google Drive, Document AI) | Encrypted backups; text extraction for tax-form review | Encrypted backup files; tax-form images submitted for review |
| Amazon Web Services, Inc. | Secondary encrypted backup copy | Encrypted backup files |
| Resend Inc. | Transactional email | Email address, name, and message content of statements and notices |
| Upstash Inc. | Rate limiting | Request counters keyed by IP address, user ID, or email |
| Functional Software Inc. (Sentry) | Error monitoring | User IDs and request context, with personal data removed |
| DocuSign | Electronic signatures | Signer name, email, and the signed document |
| Twilio Inc. and LiveKit Inc. | Phone and audio for virtual shareholder meetings | Phone numbers, audio, and participation records |
| Anthropic PBC | AI-assisted review of submitted tax forms | Tax-form content submitted for review |
We will update this list when a provider is added or removed.
7. Retention
We retain personal information for as long as reasonably necessary for the purposes described above, including to provide services, preserve books and records, meet contractual obligations, resolve disputes, maintain security and audit evidence, and comply with securities, tax, unclaimed-property, legal-hold, and other legal requirements. Because some transfer-agent and securities records must be preserved by law, we may not be able to delete them on request.
Typical retention periods
| Information | How long we keep it |
|---|---|
| Shareholder register, transactions, certificates, corporate actions, and tax records | As required by securities regulation, and in any case at least 7 years; longer where a legal hold or regulation requires |
| Security audit logs | 3 years active, then archived for a total of 7 years |
| Login sessions | 24 hours |
| Email delivery records | 180 days |
| Encrypted backups | Rolling 12 months for nightly archives; cloud archive copies kept at least 365 days and deleted at 400 days, unless held for an incident or legal matter |
8. Security
We use administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption, monitoring, audit logging, and vendor controls appropriate to the information and service involved. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Your privacy choices and rights
Depending on where you live and subject to applicable exceptions, you may have rights to request access, correction, deletion, or a copy of personal information; to limit or object to certain processing; to opt out of a sale or sharing of personal information; or to appeal a denied request. We do not discriminate against a person for exercising an applicable privacy right.
To submit a request, email support@useefficiency.com. Tell us your relationship to Efficiency and, if the request concerns securities or shareholder records, identify the relevant issuer. We may verify your identity and authority before acting. When we process information for a customer, we may refer the request to that customer.
Deletion requests. Because we keep the shareholder register and related records to meet securities and tax law, we cannot delete information we are legally required to retain while that obligation lasts. We will delete or de-identify what the law allows and tell you what we retained and the legal basis for keeping it. On request we will also provide a copy of the personal information we hold about you.
10. United States processing and international users
Efficiency is based in the United States. We and our service providers may process information in the United States and other locations where privacy laws may differ from those in your jurisdiction. Where required, we use appropriate protections for international data transfers.
11. Children
Our website and services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13 through the website. If you believe a child has submitted personal information to us, contact us so we can evaluate and address the matter.
12. Changes to this notice
We may update this Privacy Notice to reflect changes in our services, data practices, or legal obligations. We will post the updated notice and revise the "Last updated" date. We will provide additional notice when required by law or contract.
13. Contact us
Questions or requests concerning this notice may be sent to support@useefficiency.com.