Privacy Policy

📄PRIVACY POLICY

Version 2.0 | Effective Date: April 6, 2026 | Last Updated: April 6, 2026

Business Name: EFS TechFlow

Legal Structure: Sole Proprietorship

Owner & Privacy Officer: Emad Said
Address: Edmonton, Alberta, Canada
Email: [email protected]
Phone: 587-407-2047

Website: www.efstechflow.ca

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1. INTRODUCTION AND SCOPE

EFS TechFlow is committed to protecting your personal information and respecting your privacy rights. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with our website at www.efstechflow.ca, our digital automation and marketing services, and any other EFS TechFlow touchpoints.

1.1 Applicable Laws. This Policy is designed to comply with:

(a) Alberta's Personal Information Protection Act (PIPA) — the primary

privacy law governing EFS TechFlow's operations within Alberta;

(b) Canada's Personal Information Protection and Electronic Documents

Act (PIPEDA) — governing cross-provincial and international data flows;

messages, SMS, and email marketing;

(d) Canada's Criminal Code provisions on private communications (s.184–s.196),

relevant to voice and call recording services.

1.2 Scope. This Policy applies to:

(a) All visitors to www.efstechflow.ca and any EFS TechFlow funnel or

landing page;

(b) All individuals who contact EFS TechFlow, submit a form, or book

a consultation;

services are delivered through managed platform environments;

(d) All individuals whose personal information is processed through

EFS TechFlow's client campaigns, chatbots, AI voice systems, or

marketing automation tools.

1.3 Personal Information. "Personal information" means any information about an identifiable individual, as defined under PIPA and PIPEDA. This includes names, contact details, voice data, location data, and device identifiers.

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2. INFORMATION WE COLLECT

EFS TechFlow collects personal information only for identified purposes and only to the extent necessary for those purposes.

2.1 Information You Provide Directly:

(a) Contact information: name, email address, phone number, mailing address;

(b) Business information: business name, industry, location, website URL;

forms, booking tools, or chatbots;

(d) Account and billing information: payment details processed through

secure third-party payment processors (EFS TechFlow does not store

full payment card numbers);

(e) Communications: emails, messages, and notes from interactions with

our team.

2.2 Information Collected Automatically:

(a) Technical data: IP address, browser type and version, operating system,

referring URLs, and pages visited;

(b) Cookie and tracking data: see Section 11 (Cookies and Tracking) for

full details;

collected via analytics tools.

2.3 Information Collected Through AI and Automated Services:

(a) Voice and call data: where EFS TechFlow deploys AI voice receptionist

services, calls may be recorded or transcribed. Call recording will be

announced at the start of the call. Transcripts and voice data are

processed to deliver the service and improve AI performance;

(b) Chatbot conversation data: messages exchanged with AI chatbots deployed

by EFS TechFlow may be stored to enable follow-up and improve service;

behalf of clients, message content and delivery status are processed;

(d) Lead qualification data: information collected by AI systems during

call or chat interactions, including service interests, contact

preferences, and appointment details.

2.4 Third-Party Data Provided by Clients:

When EFS TechFlow clients upload contact lists or provide personal information

about their own customers for processing through EFS TechFlow-managed systems,

EFS TechFlow acts as a data processor for that information. Clients represent

that they have obtained all required consents for such data, and EFS TechFlow

processes it only on client instructions.

2.5 Data Minimisation. EFS TechFlow collects only the minimum personal information

necessary for each identified purpose. We do not collect sensitive personal

information (such as health, financial, or biometric data) unless expressly

required for a contracted service and with your explicit consent.

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3. HOW WE USE YOUR INFORMATION

EFS TechFlow uses personal information only for the purposes identified at the time of collection or for purposes a reasonable person would consider appropriate given the context.

3.1 Service Delivery:

(a) Providing, configuring, and managing digital automation and marketing

services;

(b) Responding to inquiries, booking consultations, and providing support;

(d) Training and improving AI systems used to deliver services, using only

data associated with our own operations (not client customer data).

3.2 Communications:

(a) Sending service-related communications (confirmations, invoices, notices);

(b) Sending marketing communications where you have provided opt-in consent

in accordance with CASL;

consent and each message includes a clear opt-out mechanism.

3.3 Compliance and Safety:

(a) Complying with applicable laws, court orders, and regulatory requirements;

(b) Enforcing our Terms of Service;

or misuse of our services.

3.4 Business Operations:

(a) Improving our website and service offerings;

(b) Conducting analytics to understand service performance (using

aggregated, de-identified data where possible);

retained per Canada Revenue Agency requirements.

3.5 Automated Processing. EFS TechFlow's AI voice and chatbot systems make automated decisions in the course of service delivery (such as routing calls, qualifying leads, and sending follow-up messages). These automated actions are based on instructions configured by EFS TechFlow or our clients. You may request human review of any automated decision that materially affects you by contacting our Privacy Officer.

3.6 We do not sell, rent, or trade your personal information to any third party.

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4. LEGAL BASIS FOR PROCESSING

For the purposes of Alberta PIPA and PIPEDA, EFS TechFlow relies on the following bases for collecting and using personal information:

(a) Consent: express consent obtained through forms, verbal confirmation,

or opt-in mechanisms;

(b) Contractual necessity: processing required to fulfil a service agreement

with you;

(d) Legitimate interest: analytics and security monitoring, where not

overridden by your privacy interests.

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5. DISCLOSURE TO THIRD PARTIES

5.1 EFS TechFlow does not sell your personal information. We may share personal information with the following categories of third parties:

(a) Service providers: cloud hosting, CRM infrastructure, payment processors,

analytics platforms, and email/SMS delivery services — all engaged under

contractual terms requiring them to protect your information and use it

only for the services they provide to us;

(b) Legal authorities: where required by law, court order, or to protect

the rights, safety, or property of EFS TechFlow or others;

EFS TechFlow's business, your information may be transferred to a

successor, subject to equivalent privacy protections.

5.2 All third-party service providers are required by contract to maintain

protections comparable to those described in this Policy. EFS TechFlow

remains accountable for personal information disclosed to third-party

processors.

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6. INTERNATIONAL DATA TRANSFERS

6.1 EFS TechFlow's services are operated primarily from Edmonton, Alberta, Canada. However, some of our third-party service providers are located in the United States and may process personal information on servers located outside Canada.

6.2 Where personal information is transferred outside Canada, EFS TechFlow ensures that the receiving parties provide a comparable level of protection through contractual safeguards consistent with Alberta PIPA (s.13) and PIPEDA Principle 1 (Accountability).

6.3 By using our services, you acknowledge that your personal information may be processed in a jurisdiction (including the United States) where privacy laws may differ from those in Canada. We take steps to ensure your information remains protected regardless of where it is processed.

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7. DATA RETENTION AND DELETION

7.1 General Retention. EFS TechFlow retains personal information only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to resolve disputes.

7.2 Client and Service Data. Personal information related to active clients is retained for the duration of the service relationship plus three (3) years, to allow for dispute resolution and compliance purposes.

7.3 Financial Records. Financial and transactional records are retained for a minimum of seven (7) years to comply with Canada Revenue Agency requirements, regardless of any deletion request for other data.

7.4 Marketing Consent Records. Records of CASL and SMS opt-in consents are retained for a minimum of three (3) years following the last marketing communication, in accordance with CASL enforcement guidance.

7.5 Voice and Call Data. Call recordings and transcripts processed through AI voice services are retained for up to 90 days unless a longer period is required for service delivery or expressly requested.

7.6 Deletion Requests. To request deletion of your personal information, email [email protected] with subject line "Data Deletion Request." We will respond within 30 days and complete the deletion within 60 days, subject to legally required retention periods listed above.

7.7 Backup Systems. Data in backup systems may persist for up to 60 days following deletion from primary systems before being purged through our standard backup rotation process.

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8. YOUR PRIVACY RIGHTS

Under Alberta PIPA and PIPEDA, you have the following rights with respect to your personal information:

8.1 Right to Access. You may request access to the personal information EFS TechFlow holds about you, and to be informed of how it has been used and to whom it has been disclosed.

8.2 Right to Correction. You may request correction of any inaccurate or incomplete personal information we hold about you.

8.3 Right to Withdraw Consent. You may withdraw consent to any non-essential processing at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal. Note that withdrawal of consent may limit our ability to provide certain services.

8.4 Right to Unsubscribe. You may opt out of marketing communications at any time by:

— Clicking "Unsubscribe" in any email;

— Replying STOP to any SMS;

— Emailing [email protected].

8.5 Right to Object to Automated Processing. You may request human review of any automated decision that materially affects you.

8.6 Right to Data Portability. Upon request, we will provide your personal information in a commonly used, machine-readable format.

8.7 Exercising Your Rights. Contact our Privacy Officer:

Emad Said | [email protected] | 587-407-2047

We will acknowledge all requests within 10 business days and complete

them within 30 days (with up to a 30-day extension for complex requests,

with notice provided).

8.8 Filing a Complaint. If you believe EFS TechFlow has not handled your personal information appropriately, you have the right to file a complaint with:

— Office of the Information & Privacy Commissioner of Alberta (OIPC):

www.oipc.ab.ca

— Office of the Privacy Commissioner of Canada (OPC):

www.priv.gc.ca

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9. DATA SECURITY

9.1 EFS TechFlow implements administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information we hold. These measures include access controls, encryption in transit and at rest, and vendor security reviews.

9.2 We use third-party infrastructure providers that maintain industry-standard security certifications, including SOC 2-compliant data centres. These certifications belong to our vendors, and EFS TechFlow ensures through contractual obligations that appropriate security standards are maintained.

9.3 No method of transmission over the internet or method of electronic storage is completely secure. While we use commercially reasonable means to protect your information, we cannot guarantee absolute security.

9.4 Access to personal information within EFS TechFlow is restricted to those who need it to deliver the contracted services. Any contractors or service providers engaged by EFS TechFlow are bound by confidentiality obligations.

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10. DATA BREACH NOTIFICATION

10.1 EFS TechFlow has an incident response procedure to detect, assess, and respond to personal information breaches.

10.2 If a breach occurs that poses a real risk of significant harm to affected individuals, EFS TechFlow will:

(a) Notify the Office of the Information & Privacy Commissioner of Alberta

(OIPC) without unreasonable delay, as required under Alberta PIPA;

(b) Notify the affected individuals without unreasonable delay and as soon

as feasible following confirmation of the breach and the identities of

affected individuals;

Canada as required under PIPEDA.

10.3 "Without unreasonable delay" and "as soon as feasible" are the applicable Canadian legal standards. EFS TechFlow does not commit to a fixed-hour notification deadline beyond what the law requires, as doing so would create a higher standard than applicable law demands.

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11. COOKIES AND TRACKING TECHNOLOGIES

11.1 EFS TechFlow uses cookies, pixels, and similar tracking technologies on our website and associated pages. These may include:

(a) Essential cookies: required for the website to function (session management,

security);

(b) Analytics cookies: used to understand website traffic and user behaviour

(e.g., Google Analytics or similar);

campaigns (e.g., Facebook/Meta Pixel, or similar);

(d) Chatbot and widget scripts: loaded by embedded chat or voice widgets

and may collect device and interaction data.

11.2 By using our website, you consent to the use of essential cookies. For non-essential cookies (analytics, marketing), we rely on implied consent where permitted under PIPA or seek express consent where required.

11.3 You may manage cookies through your browser settings. Disabling certain cookies may affect website functionality. Most browsers allow you to view, delete, and block cookies.

11.4 EFS TechFlow does not use cookies to collect sensitive personal information.

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12. AI AND VOICE SERVICE PRIVACY

12.1 Call Recording and Voice Data. EFS TechFlow deploys AI voice receptionist services for itself and its clients. Where calls are recorded or transcribed:

(a) An automated announcement is played at the start of each call to notify

the caller;

(b) Recordings are processed to deliver the service (route calls, capture

leads, book appointments);

to improve service accuracy;

(d) Voice data is not shared with third parties except as necessary for

service delivery, and is not used to build biometric profiles.

12.2 AI Chatbot Data. Conversations with AI chatbots embedded on EFS TechFlow's website or client websites may be stored and reviewed for service quality purposes. Chatbot interactions are subject to this Privacy Policy.

12.3 AI Training. EFS TechFlow may use de-identified or aggregated interaction data to improve our AI models and service configurations. We will not use identifiable personal information from client customer interactions to train our models without explicit consent.

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13. CHILDREN'S PRIVACY

EFS TechFlow's services are intended for adults and business clients. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected personal information from a minor without appropriate parental consent, we will delete it promptly. If you believe we may have collected information from a minor, please contact our Privacy Officer.

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14. CASL COMPLIANCE AND COMMERCIAL MESSAGES

14.1 EFS TechFlow will not send commercial electronic messages (CEMs) — including marketing emails and SMS — without your express consent obtained in accordance with CASL.

14.2 All commercial messages sent by EFS TechFlow will:

(a) Clearly identify EFS TechFlow as the sender;

(b) Include a working unsubscribe mechanism;

14.3 You may withdraw consent to receive commercial messages at any time by using the unsubscribe mechanism in any message or by contacting [email protected]. Unsubscribe requests are processed within 10 business days.

14.4 EFS TechFlow maintains records of all CASL and SMS opt-in consents for a minimum of three (3) years.

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15. POLICY UPDATES

15.1 EFS TechFlow may update this Privacy Policy from time to time. The version number and effective date at the top of this document will reflect the most current version.

15.2 For material changes, EFS TechFlow will provide prominent notice on our website and, where feasible, direct communication to affected individuals at least 14 days before the change takes effect.

15.3 Continued use of our services following a material change constitutes acceptance of the updated Policy, subject to applicable law. Where applicable law requires explicit consent for a material change in data use, we will seek such consent before implementing the change.

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CONTACT OUR PRIVACY OFFICER

For any questions, concerns, or requests related to this Privacy Policy or your personal information:

Emad Said, Privacy Officer

EFS TechFlow

Edmonton, Alberta, Canada

Email: [email protected]

Phone: 587-407-2047

Website: www.efstechflow.ca

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