PRIVACY POLICY

This Privacy Policy was revised as of March 30, 2025. It will be updated as needed to reflect any changes in the way we handle your personal information or any changes in applicable law.

The Data Controller responsible for the website is:

EFESO Management Consultants, Inc.
2200 Post Oak Boulevard, 10th Floor

Houston, Texas 77056

Phone:  346-200-7220

Email:  [email protected]

As the Data Controller, EFESO is responsible for what information we collect from you and how we use it and protect it.  This privacy policy describes how we collect, use, store and protect your personal information across the jurisdictions where we operate.  Efeso has offices located in many parts of the world, and the EFESO entity in your jurisdiction may be the main data controller for information related to you.

 

Our guiding principles:

We at EFESO Management Consultants, Inc., together with our subsidiaries and affiliates (collectively, “EFESO”) are committed to protecting the privacy and security of our clients, website visitors, and business partners.  Your data is therefore processed with great care and in strict compliance with applicable data protection laws.  Organizational and technical security measures have been taken to protect this website against the risks present in processing personal data. Our partners who support us in the provision of this website must comply with these provisions as well.

You are not required to provide us any information in order to use our website but certain functionality in the website or in other services we provide may not be available to you.

Contents:

1. Personal information we collect from or about you

We collect, use, and store information which you provide to us as well as information that your browser automatically transmits to us whenever you interact or participate with EFESO Sites, including when and how you manage your cookie preferences. The information we collect from you may include the following:

  • Personal Identification Information: for example your name, job title, place of employment, mailing address, telephone number, and email address
  • Website Usage Data: the IP address used to access our website, browser type, device type, location data, and usage patterns collected through cookies or similar technology
  • Business Information: information you provide during consultations, proposals or other engagements related to our services

We may also collect, use, and store information received from you through correspondence, such as emails, faxes, phone calls, or texts.

We may also collect, use, and store information about you received from third parties, such as business partners or vendors.

We do not intentionally or knowingly collect information from individuals under the age of 16.  If we become aware that we have inadvertently collected such data, we will promptly take steps to delete it.

2. Purposes for collecting personal information

We use the information we collect to provide and improve our services, to communicate with you, to process transactions, and to comply with legal requirements.  Specifically, we may use your personal information for the following purposes:

  • To provide the functionality and capabilities of our website
  • To provide and improve our services
  • To communicate with you about our services, projects, and promotional materials and to manage our business relationship with you
  • To advertise and market our services and to measure and improve our marketing and sales capabilities
  • To understand usage behavior on our website
  • To maintain, improve and protect our website
  • To enforce the terms of use of use of our website and to protect our legal rights
  • To comply with any and all applicable laws

3. Sharing of your personal information

We do not sell your personal information.  We may share your personal information with third parties in the following circumstances:

  • To EFESO subsidiaries and affiliates
  • To third party service providers and personnel, including for example IT service providers and marketing platforms
  • To law enforcement authorities or government officials as required by law, regulations, or legal process (e.g., court orders, subpoenas), or otherwise to comply with applicable law
  • To a successor or different business entity in the event of a merger, acquisition, or other business combination or reorganization or a transfer of all or any portion of our business
  • To enforce the terms of use of our website and to protect our legal rights

4. Legal basis for Processing Personal Data

We process your personal data under the following legal bases:

  • Consent: We may collect, use, and process your personal information with your explicit consent.
  • Contractual Necessity: We may collect, use, and process your data to fulfill a contract you have entered into with us.
  • Legitimate Interests: We may collect, use, and process your information based on our legitimate business interests, such as improving our services, marketing, or conducting internal research.
  • Legal Obligations: We may use and process your information to comply with applicable laws.

5. Specific Protections Under Applicable Law

Texas Law:

We maintain appropriate safeguards to prevent identity theft and fraud with respect to information we collect from Texas residents.  If you are a Texas resident, you may have the right to request access to, correction of, and deletion of your personal information, subject to certain exceptions.

California Law:

If you are a California resident, you may have specific rights under the California Consumer Privacy Act (CCPA), including the right to:

  • Request access to your personal information
  • Request deletion of your personal information
  • Opt-out of the sale of your personal data, if applicable
  • Non-discrimination for exercising your privacy rights

Canada Law:

  • We obtain your consent before collecting or using your personal information except where otherwise permitted by law.
  • PIPEDA Compliance: We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, ensuring your personal data is processed transparently, securely, and for specific purposes.

Mexico Law:

Under Mexico law, particularly the Federal Law on the Protection of Personal Data Held by Private Parties, we are required to protect your persona information and provide clear information about our data processing practices.  If you are a resident of Mexico, you may have the right to:

  • Access, correct or delete your personal data
  • Object to the processing of your personal data
  • Withdraw consent at any time, subject to certain legal limitations

Brazil Law:

We comply with the General Data Protection Law which provides protections for personal data.  If you are a resident of Brazil, you may have the right to:

  • Access or correct your personal data
  • Request deletion of personal data when it is no longer necessary for the purposes for which it was collected
  • Object to the processing of your personal data
  • Request data portability to another service provider

6. International Data Transfers

Given our international operations, your personal information may be transferred to, and processed in, countries outside of your residence country, including the United States, Canada, and Latin American countries.  We will ensure that appropriate safeguards are in place to protect your data in line with applicable data protection laws, such as standard contractual clauses and other legal mechanisms.

7. Your rights with respect to your information and how to protect them

 Depending on your jurisdiction, you may have the following rights with respect to the information we have collected from or about you:

 The right to request a copy of the information we have about you

  • The right to request information from us as to whether and to what extent we collect information about you, how we use it and store it, and with whom we share it
  • The right to request that we correct inaccurate or incomplete information
  • The right to object to or restrict the transfer of your data
  • The right to ask us to delete your information so long as we have no legal obligation to retain it
  • The right to request that we provide you with your data in a portable format so long as the processing is handled using automated procedures and is technically feasible\
  • The right to withdraw any consent you have previously given for your data to be processed with effect for the future at any time.

8. Cookies and Tracking Technologies

 We use cookies and similar technologies to collect information about your usage of our website and services.  This helps us improve your experience and understand how our services are used.  You can control cookie settings through your browser or other tools.

9. How long do we retain your data

 EFESO keeps your personal information only for as long as necessary to accomplish the business uses for which the information was collected or to meet our legal or contractual obligations, and in compliance with EFESO’s data retention policy.

If you request that EFESO delete your personal information, EFESO will make reasonable attempts to do so subject to our right to keep a copy of such personal information for the purposes mentioned above.

10. To Exercise Your Rights

To exercise any of your rights with respect to your personal information, or if you have any questions relating to data protection or exercising your rights, please contact us directly by email to [email protected] or by phone call to: 346-200-7220.

11. To Appeal a Decision Made by Us

If you have made a request to us with respect to the handling of your personal information and your request was denied, you have the right to appeal the results of your request.  Please write to the email address noted above, [email protected], and note in the subject line of your email “Request to Appeal. If your appeal is denied, you may have the right to complain to your state’s attorney general or other applicable authority.