Privacy Policy

Ver. 1.2 – 03/02/2021

At Efficiencie Limited (hereafter referred to as "Efficiencie"), we will never misuse your data and we will always stick to the letter and spirit of the law. We will never sell it, give it away or use it for anything other than to deliver or improve our services to you.

This privacy policy applies to all individuals who supply personal data to us in relation to our services for businesses. This includes the person who signs up to our services on behalf of our business customer, the super administrators who have authority to create and approve user accounts, and the users who access and use our services in the course of their employment / engagement with our business customer.

This privacy policy sets out how we use your personal data in relation to the supply of our e-money and payment services. There is a separate privacy policy that sets out how we use your personal data in relation to the supply of our technology and software services which is available on our website. This privacy policy sets out how we use your personal data as data controller. In addition, we use your personal data to supply our e-money and payment services as data processor on behalf of our business customer.
Our Data Protection Officer can be contacted at privacy@efficiencie.com.

The basis for collecting your data

There are different reasons for collecting your data.

Legal obligation: We have to collect and use some of your data to comply with laws to which we are subject. This is called a 'legal obligation'

Legitimate interest: This means we can collect and use your data for legitimate business objectives pursued by Efficiencie, in a way that most people would think was reasonable. For instance, if you signed up to Efficiencie and gave us your email address, you might reasonably assume we'd use it to update you about your account activity.

In addition to the uses described above, we use your personal information in the following ways:

(a)To identify you when you visit our websites or use one of our mobile apps.
(b)To perform under a contract.
(c)To provide the products and services you request.
(d)To improve our services and product offerings.
(e)To conduct analytics.
(f)To respond to your inquiries related to support, employment opportunities, or other requests.
(g)For internal administrative purposes, as well as to manage our relationship with you.

What data we collect and use

When you use Efficiencie’s services, or you get in touch with us by email, over the phone, or on social media, we collect some of your personal information.

Basic data This includes your name, your address, your email address, your phone number, your job title, the name of your employer, and your username and login information. We also collect information about where you are in the world when you access and use our services, your personal description, and your email avatar (if you have one). We will also hold a copy of the signature used to sign up to our services.

Financial Data We will hold certain financial information about you.Where you make payments onto our Efficiencie account, we will hold your credit and debit card details and information about your bank account.
Where you use your Efficiencie card to make payments and transactions, we will hold information about the payments and transactions you enter into using the card.

Regulatory data We carry out identification checks on our customers and users to make sure we comply with our legal and regulatory obligations and to manage the financial risk to our business.
The checks we carry out are Anti-Money Laundering, Politically Exposed Persons and Sanctions Checks. We use third party providers such as Experian and Equifax to carry out these checks for us. Where we are unable to successfully complete the checks online, we may ask for copies of your identification documents (including your passport and driving licence) so we can complete the checks manually.
The checks we carry out mean we will process information about you to verify your identity and address, including the documentation you provide to verify your identity. We will also check your details against databases to check whether you are on the Politically Exposed Persons or Sanctions lists issued by governments, financial market regulators, and law enforcement bodies from around the world. We carry out all the checks on the person who signs up to our services on behalf of our business customer and on each super administrator. In addition, we carry out Politically Exposed Persons and Sanctions Checks on each user.
We carry out the checks on the natural persons who have a controlling interest directly or indirectly in our business customer and on the natural persons who exercise executive control over the affairs of our business customer through a senior management position such as a Chief Executive Officer, Chief Financial Officer, Managing or Executive Director or President.
If you're sending a large amount of money, or we need you to make sure we're following anti money laundering regulations, we might need to see proof of your income/source of wealth, or some extra ID. And if you run a business, we might need some extra commercial information - like records that show how your business makes its money. We might also collect information about the reason you are sending money using our services.

Special category data We may process some special category data to carry out our identification checks in accordance with our legal obligations.

How we share your information

We share your data with the banks and certain payment service providers to complete your funds transfers and payments in accordance with your instructions. Without sharing your data, we would not be able to carry out your funds transfers or payments.
We share your data with the third-party providers who carry out our Anti-Money Laundering, Politically Exposed Persons and Sanctions Checks and with credit reference and fraud prevention agencies. We share your data with our service providers where it is necessary to administer our relationship with you or in order for a third-party service provider to provide their services to us.
We share your data with other entities in the Efficiencie Group as part of our regular reporting activities on company performance, or in the context of a business reorganisation or group restructuring exercise. The service providers who receive your data include IT software and services providers, hosting services providers, and administrative services providers.
All the recipients of your personal data are required to take appropriate security measures to protect your personal data. They must only process your personal data for specified permitted purposes and in accordance with data protection law.
We may disclose your personal information to third parties:

(a) in the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets;
(b) in order to enforce or apply our terms and conditions which regulate the relationship between you and us and other applicable agreements or to protect the rights, property, or safety of Efficiencie, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(c) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
(d) to prevent and detect fraud or crime;
(e) in response to a warrant, court order, or as otherwise required by law;
(f) to assess financial and insurance risks;
(g) to recover debt or in relation to your insolvency;
(h) to develop and manage our customer relationship with your employer; and
(i) to develop and improve our services and systems.

How we protect your data

All data you provide to us is stored on our secure servers. Any payment transaction will be encrypted using Transport Layer Security technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our services, you are responsible for keeping this password confidential.
We ask you not to share this password with anyone else and not to use this password for other services or products. The transmission of data via the internet is not completely secure. We will do our best to protect your personal data but we cannot guarantee the security of your data during transmission, any transmission is at your own risk.Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
We restrict access of your personal data to those persons who have a business reason for knowing such information. We continuously educate and train our staff about the importance of confidentiality and privacy of customer data.We maintain physical, electronic and procedural safeguards that comply with the relevant applicable laws and regulations, to protect your personal data from unauthorised access.

How long we keep your data

We keep your data for 6 years after the end of the business relationship, unless we are obliged to keep it longer due to legal requirements.

What happens if data is not provided

Where we need personal data to enter into a contract with you or to provide our services or to comply with the law, and you fail to provide the information we request,wemay be unable to provide our services to you.

Your Rights

You can ask to see the information we have about you. You can also ask usto change it, correct it, delete it, restrict how we use it, or object to the way we use it by emailing privacy@efficiencie.com.

Objection: You have a right to object to the processing of your personal information based on our legitimate interests unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you. Please write to us at Efficiencie privacy@efficiencie.com.

Lodge complaints: You have a right to lodge a complaint with the regulator. If you wish to raise a complaint on how we have handled your personal information, please write to or contact us at Efficiencie privacy@efficiencie.com.

Changes to our privacy policy: Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact: Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to privacy@efficiencie.com.