At EFA we are dedicated to protecting your Personal Data and your privacy. We are committed to ensuring that you can make informed decisions and feel comfortable about sharing certain personal information with us. Please read this Privacy Policy to understand with whom we share your Personal Data and for what reasons. If you are a direct customer of EFA, we will notify you of any changes to our Privacy Policy, but the latest policy will always be published on our website at

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

EFA Software means “the EFA Platform, EFADRIN and any bespoke software developed for our customers”

GDPR means “The General Data Protection Regulation as applicable in the European Union from 25th May 2018”

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

What information we collect

  • Information that you provide us when you meet us.
  • Information that is provided to use by your company.
  • Any forms of communication; telephone, email, fax and letters.
  • Information from publicly available sources and third parties.
  • Your name and contact information such as your business address, email address and telephone number.
  • An understanding of your goals and objectives in using our services.

How we use Personal Information we collect

  • To analyse your usage of EFA software in order to generally improve our services.
  • To notify you of specific actions in using the EFA software as agreed with your company.
  • To update you on our services from time to time.

How we protect your personal data

  • Your personal data will only be stored on our secured server. Any transmission of such data over the internet required for the operation of the EFA software will be encrypted.
  • We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
  • Please note however that where you are transmitting information to us over the internet, for instance by email, this can never be guaranteed to be 100% secure.
  • We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

How long do we keep your information?

  • We will hold your personal data on our systems for as long as you are a user of EFA and for as long afterwards as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it.
  • We securely destroy all financial information once we have used it and no longer need it.

Your rights

Under GDPR/DPA 2017 you have the following rights:

  • To obtain access to the personal data that we hold about you.
  • To be provided with information about how your personal data is processed
  • To have your personal data corrected
  • To have your personal data erased in certain circumstances
  • To object to or restrict how your personal data is processed
  • To have your personal data transferred to yourself or to another business in certain circumstances


  • We use cookies to store and collect information about your use of our website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience.

Legal interest:

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

  • For marketing to you. In this respect, see the separate section on marketing below;
  • For training our staff or monitoring their performance.
  • For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis.
  • Seeking advice on our rights and obligations, such as where we require our own legal advice.
  • In this respect we may share your personal data with the following:
    • Our advisers or agents where it is necessary for us to obtain their advice or assistance.
    • Third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business

Legal obligations

We may also process your personal data to comply with any of our legal obligations.

In this respect, we will use your personal data for the following:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering or other laws.
  • As required by tax authorities or any competent court or legal authority. In this respect, we will share your personal data with the following:
    • Our advisers where it is necessary for us to obtain their advice or assistance.
    • Our auditors where it is necessary as part of their auditing functions.
    • With third parties who assist us in conducting background checks.
    • With relevant regulators or law enforcement agencies where we are required to do so.


We may send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email, SMS (or similar service) or other digital methods of communication.

If you are unsure about any items within our policy please contact our Data Protection Officer, Mr. Martin Poletiek, as follows:


Telephone: +852 3151 7287