Privacy Policy

Efficient Frontier Solutions LLC and its parents, subsidiaries, and affiliates (together “EFS,” “we” or “us”) is committed to protecting your privacy. This privacy policy (“Privacy Policy”) applies to our website, including any of its mobile versions or mobile applications (individually and collectively, the “Site”) and describes how we collect, use, share and otherwise process Personal Data (as defined below) about visitors to our Site, contact persons for our clients and/or prospective clients, contact persons for our suppliers of goods or services, or any other individuals about whom EFS obtains Personal Data.

In this Privacy Policy, “Personal Data" means information that (either in isolation or in combination with other information held by EFS) enables you to be identified as an individual or recognized directly or indirectly.

By accessing or using EFS’s Site and services, you signify that you have read, understood, and agree to our collection, use, and disclosure of your Personal Data as described in this Privacy Policy.

1. Collection of Data

We collect Personal Data you provide to us in a variety of ways from different sources in connection with the day-to-day management of our business and our commercial relationships, either directly from the data subjects, or from clients, colleagues and publicly available sources. Where EFS receives data from its clients about employees of clients or other individuals, the client is responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.

The categories of Personal Data we collect may include, without limitation:

• Basic contact and profile information. We may collect personal information, such as your name, phone number, address, business information, title, job responsibilities, gender, age, zip code, address, e-mail address, contact details and information about family life, (excluding special categories of data) including family, children, hobbies and interests.
• Special categories of data. In limited circumstances, we may collect information you provide to us as necessary for a specific service we are providing to you, such as religious or other beliefs, racial or ethnic origin, sexual orientation, health data and details of trade union membership.
• Registration data. Newsletter requests, event/seminar registrations, subscriptions, downloads, and username/passwords.
• Client service data. Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.
• Payment and transaction information. We may collect information such as payment information including your credit/debit card number. We use this information to complete your transaction, detect and prevent fraud.
• Marketing data. Personal Data about individual participation in conferences and in-person seminars, credentials, associations, interests, and preferences.
• Transaction data. Personal Data contained in documents, correspondence or other materials provided by or relating to transactions conducted by our clients.
• Compliance data. Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.
• Comments, chat and opinions. When you contact us directly (e.g., by email, phone, mail or by completing an online form), we may record your comments and opinions. We use this information to respond to your question or comment, to evaluate and improve our services.

Job applicant or contractor data. Data provided by job applicants or independent contractors in connection with employment or project opportunities.

1. We collect Personal Data when you voluntarily provide it to us.

You can choose not to provide the requested data, but you might not be able to take advantage of certain Site features.

1. We automatically collect data about your browser or device and your use of the Site.

When you access and use the Site, our technology and tools may automatically collect and record certain data (which does not identify you as an individual) about your use of the Site (your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring web page, pages visited, search terms and other information relating to your use of the Site, browser or device).

We also use various tracking technologies (such as cookies, clear GIFs, and/or pixel tags) to collect data about your use of and access to the Site. Cookies are small bits of information that may be placed on your computer by websites you visit, applications you use, or advertisements you view. Cookies alone tell us nothing about who you are. Pixel tags generate a generic notice of a visit to the Site. Pixel tags are used in conjunction with cookies to anonymously track the activity on the Site by a particular browser on a particular site. You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of our Site , and you may be required to re-enter your log-in details.

This Site uses Google Analytics 4 (cookies _ga and _ga_*) and Vercel Web Analytics and Speed Insights (cookieless, aggregated page-view and performance data) to understand how the Site is used, and HubSpot tracking (cookies hubspotutk, __hstc and __hssc), which records the pages you visit and links them to your contact record if you submit a form. Google, Vercel and HubSpot receive this data as our service providers.

1. Third-parties may also automatically collect data about you.

Some embedded content on the Site may be served by third-party content providers. Please note that these companies may also use cookies, pixels, tags or other similar technologies to collect data about you, both on the Site and throughout the Internet. Data collection and use by those third-parties is subject to the privacy policies of those third-parties.

1. Our “Do Not Track” (DNT) Policy

Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or similar mechanism transmitted by web browsers. To learn more about browser tracking signals and DNT, please visit http://allaboutdnt.org.

2. Use of Collected Data

We collect and use the types of data described above to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience. We may use the data to:

• Fulfill our obligations with respect to the reason you volunteered the data (e.g., to respond to an inquiry, your job application, manage our business operations, provide assistance with marketing strategy, operational efficiency, content creation, etc.);
• Allow you to participate in certain features of the Site;
• Improve the Site or our products, events and services;
• Optimize your experience on the Site (e.g., troubleshooting technical programs, storing your preferences, etc.);
• Notify you about changes to the Site (including this Privacy Policy);
• Carry out our obligations and enforce our rights arising from arrangements between you and us; and
• For any other purpose with your consent or as permitted by law.
• Protect the security and effective functioning of our Site and information technology systems we use basic data, registration data, transaction data, and device data. It is necessary for our legitimate interests to monitor how our Site are used to detect and prevent fraud, other crimes and the misuse of our Site. This helps us to ensure that you can safely use it.

Additionally, we may use the data for marketing purposes to:

• Provide you with additional information regarding products, events and services from EFS, and its subsidiaries and affiliated companies via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
• Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising.

You can learn more about online advertising HERE.

3. Legal Basis for Processing Personal Data

To the extent you provide us with Personal Data, we are processing your Personal Data under the following lawful basis:

1. Consent: by clicking the Sign Up button on the Site you consent to permit us to process your Personal Data for the purposes set forth in this Privacy Policy.

1. Processing necessary for compliance with legal obligations.

4. Third-Party Websites and Third-Party Embedded Content

We do not control the privacy policies of third-party websites, our affiliates, service providers, and business partners which may be accessed, directly or indirectly, through your use of the Site. Any data you provide to, or that is collected by, third-party sites may be subject to the privacy policies of those sites (including third-party content embedded on the Site), if any. It is up to you to review the terms of use and privacy policy of third-party websites or third-party content originators.

5. How We Share Data

1. Affiliates and Subsidiaries. We may share your data collected on this Site with our subsidiaries or affiliated companies.

1. Service Providers. We may provide collected data to our service providers. They may use your data to perform services for us and may have access to, store and process your Personal Data to provide services on our behalf.

1. Sponsors or Event Partners. In the instance of ticketed events, we may share your Personal Data with sponsors or event partners.

1. Law Enforcement and Safety. We may also share or disclose your data to comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property or safety of our users and other third-parties. We may disclose data to government or law enforcement officials or private parties as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, to comply with laws, regulations or ordinances or to prevent or stop illegal, unethical or actionable activity.

1. Business Transfer. In the event that EFS undergoes a merger, acquisition by another company or sale of its assets, your data will, in most instances, be part of the assets transferred.

1. Financial institutions. We share Personal Data with financial institutions in connection with invoicing and payments.

6. Your Rights under the GDPR

If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, you have the following rights under the General Data Protection Regulation (“GDPR”).

1. Right to be informed about the collection and use of your Personal Data.
2. Right to access your Personal Data.
3. Right to have any inaccurate or incomplete Personal Data corrected without undue delay.
4. Right to have your Personal Data erased, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
5. Right to restrict the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, our processing is unlawful, or we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
6. Right to Personal Data portability allowing you to move, copy or transfer your Personal Data easily from one organization to another.

Right to object to the processing of your Personal Data. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

If you wish to exercise any of these rights under the GDPR, please email us at hello@nicksonnenberg.com or write to us at the address below with such request. We will respond to any requests without undue delay and no later than one-month after receipt of your request.

7. Opting-Out of Data Use or Withdrawing Consent

As described above, we collect Personal Data about you when you voluntarily provide it to us, collect other data about you and your use of the Site automatically when you interact with us. If you do not want us to use your collected data as described above or if you wish to withdraw your consent to permit us to process your Personal Data, please email us at hello@nicksonnenberg.com or write us at the address below with such request.

If you no longer wish to receive communications from EFS, you can opt-out from receiving such messages in the future by following the instructions in the emails or contacting us at hello@nicksonnenberg.com.

With respect to the Site’s use of cookies, pixels, tags, and other similar technologies, by adjusting settings on your browser, you may elect not to allow cookies to be placed, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data about you.

You may remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). Please note that these opt-out tools are device and browser specific, so you must repeat the opt-out from each of your browsers and devices.

You may also adjust your advertising preferences on various social media websites by adjusting your Settings on the platform.

8. Protection and Retention of Data

We use appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable.

Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

We retain data only as long as necessary in light of the reasons it was collected as set forth in this Privacy Policy, or until you inform us you wish to have your data deleted, whichever comes first. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

9. Foreign Jurisdictions; Personal Data Transfers

The data that you provide to us or we obtain as a result of your use of this Site will be collected, stored, and processed in a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection laws, including the United States. We may transfer your Personal Data outside the EEA in order to store it and enable us to provide advertising, products or services to you. Where your Personal Data is transferred outside the EEA, including the US, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this Privacy Policy. By using this Site and/or providing us with your Personal Data, you (a) consent to the transfer and/or processing of any Personal Data outside the EEA, including to the U.S., (b) acknowledge that U.S. law may not be equivalent to the data protection laws of your location and (c) understand that we will collect, transfer, store, process and/or deal with your Personal Data in accordance with this Privacy Policy.

10. Children and Parents

We respect children’s privacy. We do not target or knowingly or intentionally collect personally identifiable information from children under the age of 13. By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian. If you are under the age of 13, you may not use the Site. If you become aware that your child has provided us with personal information without your consent, please email us at hello@nicksonnenberg.com.

11. Your California Privacy Rights

This section applies to California residents whose personal information is processed by EFS pursuant to the California Consumer Privacy Act (“CCPA”), including how we protect the personal information we process and control relating to you and the rights you may have in relation to this personal information. For purposes of this section, “personal information” has the meaning provided by the CCPA and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with you, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA or the Driver’s Privacy Protection Act of 1994. This section does not apply to personal information we collect when we are acting as a “service provider” to process information pursuant to a contract with one of our business customers.

Your California Rights and Choices. In addition to the rights and obligations stated in this Privacy Policy, as a California resident, you may be able to request to exercise the following rights:

The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information;
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold, if any, and the categories of third parties to whom the information was sold, if any; and
• The business or commercial purposes for collecting or selling the personal information, if any.

The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our services or engage with you in the same manner.

To submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your California Consumer Rights, please submit a request by:

Emailing: hello@nicksonnenberg.com with the subject line “California Rights Request,” or

Mailing:

Efficient Frontier Solutions LLC

Attention: California Privacy Rights

228 Park Ave S, PMB 26774

New York, NY 10003-1502

California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please submit a request using one of the California consumer rights request methods designated above.

12. Data Controllers

The data controller for the Personal Data that you provide or that is collected by EFS or its affiliates is as follows:

Nicholas Sonnenberg

228 Park Ave S, PMB 26774

New York, NY 10003-1502

13. Miscellaneous

From time to time, we may update this Privacy Policy to reflect, among other things, changes in the law or our data collection and use practices and such modifications shall be effective upon posting by EFS. Your continued use of the Site after an updated Privacy Policy signifies your acceptance of the updated Privacy Policy. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If we make a material change to this Privacy Policy, as determined in our sole discretion, we will notify you via email.

14. Contact Us

If you have any general questions about this Privacy Policy or other aspects of the Site or would like to correct, update or erase data provided to us, please email us at hello@nicksonnenberg.com or write to us at:

Efficient Frontier Solutions LLC
Attention: Privacy Policy
228 Park Ave S, PMB 26774
New York, NY 10003-1502