Privacy Notice

1. Introduction

Innovasoft Tech Holdings Ltd (hereinafter "we", "us", or "our") operates the website https://www.efficientstack.com/ (the "Website") and is the controller of the information collected or provided via the Website.

Please read this Privacy Notice carefully, as your use of the Website signifies that you have read, understood, and agree to all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see "Contact Information" below for information on how to contact us.

2. Scope

This Privacy Notice applies to information we collect on the Website and in your communications with the Website.

3. The Data We Collect About You

Personal data, or personal information, means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include data that has been anonymized or aggregated.

We may collect the following kinds of personal data:

• Online Forms and Communications Data: We collect your name, email address, telephone number, job title, and any other information you submit through online forms on the Website, as well as information you provide via email or telephone, such as details shared in the context of requests or other inquiries.
• Activity data: We process information about how you use the Website, including the pages you visit and search history. This also includes what you click on, messages that you send and metadata about content and messages.
• Technical data: Includes information about the network that you connect your device to, including your IP address, device characteristics, user agent, and information from cookies and similar technologies.

4. The Sources from Which We Collect Personal Information

We use various methods to collect data about you including:

• Direct interactions: Information that you provide when filling in forms, reporting a problem, or requesting further services.
• Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit the Website.

5. Purposes for Which We Use Your Personal Information

We use personal information for the following purposes described below:

• Provision of services: To present the Website and its contents and to provide you with information or services that you request from us.
• Customer management: To provide support and notices to entities or natural persons that receive our services ("Customers") about their account and notices about changes any products or services we may offer or provide from time to time.
• Communications and handling of requests: We process online form and communications data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.
• Advertising: To communicate with you about products or services that may be of interest to you.
• Analytics: To determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
• Functionality and security: To diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
• Compliance: To enforce our Terms of Service and to comply with our legal obligations and to comply with complaint handling obligations.
• Information you provide: In any other way we may describe when you provide the information or for any other purpose with your consent provided separately from this Privacy Notice.

6. Cookies and Automatic Data Collection Technologies

As you navigate through and interact with the Website, we use automatic data collection technologies to collect Website activity data. The technologies we use for this automatic data collection may include use of cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website. Please visit our Cookie Notice on how we use cookies and similar technologies when you visit the Website.

7. Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us.

• You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of the Website because such information may be required for a specific function, such as asking a question.
• You can opt-out of receiving marketing emails from us using the opt-out link provided in our emails. If you are a Customer, we may continue to send you other types of important emails e.g., e-mails about your transactions, account, or orders.

8. Disclosure of Your Personal Information

We disclose your personal information when necessary to deliver the services or for other purposes set out in this Privacy Notice. When we disclose your personal information, we usually rely on the performance of our contract with you, our legal obligation to do so, our legitimate interest (e.g., operating the Website), so long as it doesn't outweigh your interests or your consent, except when expressly stated otherwise below in the paragraph "To comply with the law or protect our rights or the rights of third parties".

Disclosure of your personal information may also involve transfers of your personal information outside the European Economic Area ("EEA"). To the extent that we need to transfer Personal Information outside the EEA, we will do so according to the section "Transfers of Your Personal Information to Other Countries" or when necessary for the performance of the contract between us.

The parties to whom we may disclose your personal information include:

• Our Corporate Group: We may disclose any of the categories of personal information that we collect to members of our corporate group to the extent this is necessary for the purposes described in this Privacy Notice, and generally to operate our business, which includes customer support and facilitating business development. You acknowledge that in some cases, members of our corporate group might be established or run their services outside the EEA.
• Our contractors and/or employees: To provide our services to you, our employees and/or contractors may receive access to your personal data only on a need-to-know basis. Such employees and contractors abide by confidentiality obligations.
• Service providers: To our authorized service providers that perform certain services on our behalf. These services may include risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, analytics, security or supporting the Website's functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes. Where required under applicable laws, we entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.
• Legal successors: We may disclose all categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Such transactions may be in our legitimate interest, particularly our interest in making decisions that enable our business to develop.
• To comply with the law or protect our rights or the rights of third parties: We access, preserve and may share your personal information with regulators, law enforcement, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to:
  
  
  1. satisfy any applicable law, regulation, legal process, or governmental request;
  2. enforce applicable Terms & Conditions, including investigation of potential violations thereof;
  3. detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues;
  4. protect against harm to the rights, property or safety of our company, our users, our employees, or others;
  5. to maintain and protect the security and integrity of the Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose your information to third parties for the above purposes where necessary to comply with our legal obligations, to perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.

9. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your personal information only where:

• You provide your consent to do so for a specific purpose: for example, when you allow us to send you e-mail marketing. You may withdraw your consent at any time, but withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal;
• It is necessary to perform our contractual obligations per our Terms of Service;
• It is necessary to comply with legal obligations: for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation;
• It satisfies a legitimate interest which is not overridden by your data protection interests: for example, to keep the Website safe and secure from fraud and illegal activities;
• It is used to protect your or others' vital interests: for example, in case of emergency or to prevent a crime or fraud;
• It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing the same information for different purposes. If you reside outside the EEA, Switzerland or the United Kingdom ("UK"), the legal bases on which we rely may differ from those listed above.

10. Transfers of Your Personal Information to Other Countries

We may share the information we collect globally, across our corporate group and with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Service and this Privacy Notice to fix, analyse, and improve our products and services. Whenever we transfer personal information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where applicable, we rely on decisions of the European Commission, known as "adequacy decisions," recognising that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA.

In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

11. Retention of Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider several factors, including what personal data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete your personal information from our systems.

For more information on data retention periods, please see the section "Contact Information" below on how to contact us.

Where permissible, we will also delete your personal information upon your request as explained in the section "Your Rights Related to Your Personal Information".

12. Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your Personal Data:

• Right of access: You have the right to receive information on the personal data we hold about you and how such personal data is used, as well as a copy of your personal data;
• Right to rectification: You have the right to rectify inaccurate personal data concerning you;
• Right to be forgotten: You have the right to delete your personal data;
• Right to data portability: You have the right to receive the personal data provided by you in a structured, commonly used, and machine-readable format and to transmit this personal data to another data controller;
• Right to object: You have the right to object to the use of your personal data where such use is based on our legitimate interests or on public interests;
• Right to restriction of processing: You have the right in some cases, to restrict our use of your personal data; and
• Right to file a complaint: If you are in the EEA or the UK, you also have a right to file a complaint with your local data protection authority.

If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time with effect for the future. However, please note that, in such cases, you may no longer able to use or access one or several functionalities on the Website.

You can exercise your rights by sending an e-mail to privacy@efficientstack.com. Please note that we have one (1) month to respond to your request.

Prior to processing a request for access or deletion of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

13. California Rights and Choices

The California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, such Consumers have the right to:

• Opt-out of the sale of their personal information, should we sell their personal information;
• Be informed of certain information concerning our collection and use of their personal information;
• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

You can exercise your rights by sending us an email us at privacy@efficientstack.com with the subject line "CCPA Request." If you need assistance regarding the exercise of your rights, you can also send an e-mail at privacy@efficientstack.com to help you with the process.

14. Resident's Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange your personal information with anyone for money.

15. Changes to Our Privacy Notice

We keep our Privacy Notice under regular review. The scope is to address any new legal requirements, technical developments, or adding more clarifications in the case needed.

Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the "Last Modified" date mentioned in the header of this Privacy Notice.

16. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@efficientstack.com.

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

Our Data Protection Officer can be contacted at the following email address: dpo@efficientstack.com.