Eferral, Inc. Privacy Policy


Privacy Policy

This privacy policy of Eferral, Inc. (collectively, with its subsidiaries and affiliates, "Eferral, Inc.," “Company”, "we," or "us") describes the privacy practices for Eferral, Inc. in connection with information we collect from you online through Eferral, Inc.'s downloadable mobile applications (the "App"). The purpose of this Privacy Policy is to inform you about the types of information we gather about you, including information gathered when you visit the App, and information we may receive from third parties or affiliates in addition to that online information, how we may use that information, whether we disclose that information to anyone, and the choices you have regarding our use of, and your ability to correct, the information. Eferral, Inc.. strives to help visitors of the App protect their privacy while using our App. By using the App, you expressly consent to the collection, use and disclosure of information, including personal information, as described in this Privacy Policy.

We collect information on behalf of businesses and third party organizations that use the App and/or use services offered through the App to provide incentives, referrals and communicate to customers or potential customers (the "Clients") and for our own use in connection with our operation of the App. We also collect information directly from individuals identified by Clients as sources of potential referrals (the “Referrers”). The Referrers may also provide us with information about potential customers interested in the App and/or purchasing goods and services directly from our Clients and consenting to receiving further information (the “Leads”). We do not rent or sell your personal information to Clients or third party organizations for any purposes, including marketing purposes.

This Privacy Policy governs our use of such information, but does not govern the use, storage and/or further collection of information that may occur at the Client level, which use, storage and further collection will be governed by each Client’s own privacy policy. If made available to us, we will attempt to provide information indicating the location of the Client’s privacy policy. If a privacy policy is not available for a Client, we will provide appropriate contact information for the Client and/or you should seek such information from the Client directly.

HOW WE COLLECT AND USE INFORMATION. We may collect information in several ways by your use of this App, as well as from forms you submit to us, personal correspondence, such as emails or letters that you send to us, information you enter when sending a referral, or any other activity through which you identify yourself to us. We may ask you to voluntarily provide us with personal information on this App: for example, while many of the features of the App are available without registering, you may be asked to create an account on the App if you desire to access certain features. When you visit the App, our servers may log your IP address, the URL of your request and other information that is provided in the HTTP header. Clients and/or our third-party service providers may ask you voluntarily to provide personal information through our App or on their websites and may share such personal information with us, as governed by their respective privacy policies. Our use of information received from a Client and/or a third-party service provider will be dictated by their privacy policies and not this Privacy Policy. We collect two types of information: personally identifiable information and non-personally identifiable information. Personally identifiable information is information that identifies you or can be used to identify or contact you, but does not include the name, title, business address, or telephone number of an employee of an organization ("Personally Identifiable Information"). We also may collect information that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), user IP addresses, browser types, domain names, internet service providers, referring/exit pages, date/time stamp, operating system, clickstream data and other anonymous statistical data involving the use of our App ("Non-Personally Identifiable Information"). Like many other webApp operators, Eferral, Inc.. may use cookies to customize content specific to your interests and track your use of the App. "Cookies" are text files that are placed on your computer and may be used to store your personal information. In addition to cookies, Eferral, Inc.. may use other known or later developed technologies, to assist Eferral, Inc.. in observing the behavior of users visiting the App. These technologies access individual user information but the information is used only to compile aggregated statistics about the App's usage. This App uses Google Analytics (and in the future may use other similar Apps or services), a web analytics service provided by Google, Inc. ("Google"), to better assist Eferral, Inc.. in understanding how the App is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the App, including your computer's IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the App, compiling reports on App activity for Eferral, Inc..'s use, and providing other services relating to App activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the App. The use of cookies by Google Analytics is covered by Google's privacy policy (http://www.google.com/privacy/privacy- policy.html). Personally Identifiable Information we collect may include your name, email addresses, postal addresses, zip/postal code, prior addresses, employer, job title, income, telephone number, credit card information, bank account information and routing numbers, date of birth, gender, age, marital status, username and password and other information either desirable or necessary to provide quality services to our customers and visitors. We may also collect information about you such as your use of the App and communication preferences. If you choose to use our App as a Referrer to send an email, mobile or other electronic message to tell a Network Participant who has voluntarily asked for a Referral, the referred party’s name (and no other information ) will be requested and sent to the Network Participant.   Network Participants may be provided with Non-Personally Identifiable Information about the Lead, such as the promotion code provided to the Lead, but Network Participants are not provided with the Lead’s contact information.

To the extent we are able to do so, we may link your Non-Personally Identifiable Information with your Personally Identifiable Information. We may also link information collected online with information we collect offline or collected online by third parties. Eferral, Inc.. may use the information collected from you to provide services which you have requested from us: including, without limitation, sending your contact information to Clients or Referrals that you are interested in; sending referrals to individuals that you have identified as Leads; and enabling you to use the Company Services. We may also use your personal information to send you targeted messages, publications, news, and information about events, special offers, promotions and benefits. Eferral, Inc.. may use third-party service providers to send and distribute e-mail(s) and to perform other marketing and support functions. We may use information we collect from you to improve the content of this App, to enhance users' experiences when visiting this App, to analyze trends, administer the App, gather demographic information the App's users, track user movements and to customize the content and layout of this App for each individual user.

SHARING OF PERSONAL INFORMATION. Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any information we gather from you on our Site. We may share your personal information with the Clients or Referrers that use the App to provide referrals. We also may share your personal information with our third-party service providers (including payment processors) or with other select third parties who offer goods or services we think may be of interest to you. From time to time, we may partner with other organizations or companies to provide co-sponsored or co-branded promotions, services or events and may share your personal information with our co-sponsor. We also may provide your personal information to service providers or contractors to perform functions on our behalf, such as, but not limited to, companies or individuals hired to: communicate news, deliver Eferral, Inc..'s promotional materials via e-mail and direct mail, to develop, enhance, market or provide any of Eferral, Inc..'s products, to process credit card payments and to assist Eferral, Inc.. with sending communications and performing other marketing and support functions. These third parties may use technologies to measure the effectiveness of ads and emails and use information about your visits to our App so that we may provide you with a better experience on our App. Also, Eferral, Inc.. may use third-party social media platforms, including third-party social media webApps, to communicate with you. We also may share with third parties, including, without limitation, our corporate partners, aggregated demographic and statistical information that is not personally identifiable (including, for example, the number of users who searched for certain types of Clients, the daily number of unique visitors to the App, how many users clicked on a particular advertisement and how many users were using a certain internet service provider).

Eferral, Inc.. also may disclose an individual's personal information:

to a person who in the reasonable judgment of Eferral, Inc.. is seeking the information as an agent of the individual;

to third parties providing payment processing services to Eferral, Inc.. and its Clients, including but not limited to Stripe Paypal or Venmo; in situations where sharing or disclosing your information is required in order to offer you products or services you desire;

to a third party or parties, where disclosure is required or permitted by law, a judicial proceeding, a criminal investigation, a court order, or legal process;

if, in the reasonable judgment of Eferral, Inc.., it is necessary to enforce compliance with our internal policies or the Application User Agreement, to prevent illegal activity or suspected fraud, or to protect our App, customers, or others; and to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of Eferral, Inc..'s assets.

Eferral, Inc.. may be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order, summons or a subpoena. We also may disclose such information in response to a law enforcement agency's request.

Through the App, Eferral, Inc.. may make available areas that allow for user interaction, including blogs, forums, bulletin board services, chat areas, or other message and communications features. Some of these forums may require registration. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information.

CHILDREN'S INFORMATION. The App is not intended for children and Eferral, Inc.. does not knowingly solicit or collect personal information on the App from children under the age of 18. If Eferral, Inc.. learns that, despite these measures, a child under the age of 18 has submitted personally identifiable information to Eferral, Inc.. through the App, it will take reasonable measures to delete such information from its records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

HOW WE STORE YOUR INFORMATION. Eferral, Inc.. is committed to protecting the security of any personal information you provide to us. We maintain commercially reasonable safeguards to maintain the security and privacy of personal information that you provide to us. In spite of these protections, Eferral, Inc.. cannot guarantee the security of any data submitted over the Internet. After your information reaches Eferral, Inc.., it is stored on servers (or in the case of information received from you in person, in writing or over the phone, in physical storage areas) protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. We may store and process your personal information in the United States or Canada or any other country in which we or our agents maintain facilities. By using the App, you consent to the transfer of your information among these facilities, including those located outside your home country.

THIRD-PARTY WEBSITES. This Privacy Policy applies solely to information collected by Eferral, Inc.. This Privacy Policy does not apply to other webApps that are accessible through this App, including but not limited to any third-party websites that process payments on behalf of Eferral, Inc... Please be aware that third-party webApps that process payments for Eferral, Inc.. and websites for our advertisers, sponsors, affiliated entities, Network Participants and other third parties that are accessible through this App may have their own privacy and data collection policies and practices. Eferral, Inc.. is not responsible for the privacy practices of such Apps and will not be responsible for any actions or policies of such third parties. We encourage our users to be aware when they leave the App and to read the privacy statements of each and every website that you visit.

INFORMATION FOR CLIENTS. If you are a business or third party organization using the App, you agree to post a privacy policy on your website that complies with the laws applicable to your business. You also agree to obtain consent from your employees, customers and referrers for the use and access of their Personally Identifiable Information by Eferral, Inc.. and other third parties. In addition, if you are collecting any sensitive Personally Identifiable Information from your customers (including information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexuality), you agree to obtain affirmative, express consent from your customers for the use and access of sensitive Personally Identifiable Information by Eferral, Inc.. and other third parties.

RETENTION AND DESTRUCTION OF YOUR PERSONAL INFORMATION. We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We will continue to store archived copies of your Personally Identifiable Information and Non- Personally Identifiable Information for legitimate business purposes and to comply with the law. Our Client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away.We will continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to improve our App and our services

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed or completely reformatted.

ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION. You can see, review and change most of your personal information by logging into your account on Company and editing the My Profile link or by contacting us at the addresses below. If your personal information changes or is inaccurate, you must change it promptly.

There may be circumstances where your personal information is not able to be accessed, reviewed and changed by logging into your account on Company. With some exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If we collected personal information on behalf of a third party we may have conveyed that information directly to the third party. If so, we may not have it as a part of our own files and you will have to go to the third party to look at the information.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

CONTACT US. If you would like to update or correct your information or modify your communication preferences, or if you have questions regarding our Privacy Policy or the use of information collected, you can contact us by email at the following:


POLICY CHANGES. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by means of a notice on the App. If we add any new features or tools to our services, they will also be subject to this Privacy Policy. By using the services on our App or continuing to use the services on our App after notice of changes have been published, you are consenting to the changes.


CALIFORNIA PRIVACY RIGHTS.  Your Privacy Rights — Notice to California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information us to a third party for the third party's direct marketing purposes. To make such a request, please write:


Eferral, Inc.

10601G Tierrasanta Blvd #116

San Diego, CA  92124

Attention: Privacy Manager

Eferral, Inc. Privacy Policy