Privacy Policy · Information Handling · Data Governance

Information entrusted to us
should be handled deliberately.

This Privacy Policy explains how Efficient Consulting & Management USA LLC may collect, use, process, disclose, retain and protect information obtained through this website, inquiries, Institutional Review requests and related communications.

ECM USA seeks to collect information proportionate to the purpose for which it is required and to use that information in connection with legitimate business, review, engagement, compliance, security and administrative activities.
Collection Purpose-Led Information may be collected when you interact with ECM USA, submit forms or use the website.
Use Business & Review Purposes Information may support communications, qualification, mandate review, security and business administration.
Disclosure Controlled & Contextual Information may be processed by service providers or disclosed where appropriate or legally required.
Control Privacy Requests Applicable privacy rights and requests are considered according to relevant law and circumstances.
Scope of This Policy

Privacy begins with understanding the context.

This Privacy Policy applies to information collected through ECM USA's website, website forms, direct inquiries, Institutional Review requests and related communications with prospective clients, clients, counterparties, professional contacts and other website users.

It also describes certain general information-handling principles that may apply when ECM USA evaluates a prospective engagement or administers an existing professional relationship.

Additional contractual, confidentiality, data-processing, compliance or information-handling provisions may apply to formal engagements, specific mandates, counterparties or particular jurisdictions.

Important: where a signed agreement, confidentiality agreement, data-processing arrangement or applicable law imposes more specific requirements, those requirements may supplement or govern the handling of information in the relevant context.
Information We May Collect

Different interactions require different information.

The information ECM USA receives depends on how a person interacts with the website and whether the interaction progresses from a general inquiry toward institutional qualification or formal engagement.

01

Identity & Contact Information

This may include a person's name, title, organization, business email address, telephone number, country or jurisdiction and other contact details voluntarily provided to ECM USA.

02

Business & Mandate Information

This may include company information, project or transaction descriptions, mandate objectives, financing requirements, transaction values, sectors, jurisdictions, timing, counterparties and other information submitted in connection with an inquiry or review request.

03

Qualification Information

Where a matter progresses, ECM USA may request information relevant to KYC/KYB, ownership, authority, beneficial ownership, source of funds or wealth, corporate records, professional standing, counterparties and engagement readiness.

04

Website & Technical Information

Website technologies and service providers may process technical information such as browser or device information, IP address, page interactions, referral information, timestamps and similar operational or analytical data.

05

Communications

ECM USA may retain correspondence and related information exchanged through email, website forms, meetings, telephone discussions or other professional communications where appropriate for business or recordkeeping purposes.

06

Documents & Supporting Materials

Where appropriate to a review or engagement, ECM USA may receive corporate records, financial information, feasibility materials, project documents, transaction records and other supporting documentation supplied by authorized parties.

How Information May Be Used

Information should serve a defined business purpose.

ECM USA may use information where appropriate to administer inquiries, assess potential mandates, provide contracted services, maintain security and conduct legitimate business operations.

01

Respond to Inquiries

To review and respond to communications, requests, questions and prospective-client inquiries.

02

Institutional Review

To assess suitability, readiness, mandate context, professional boundaries and potential next steps.

03

Qualification & Compliance

To support applicable identity, authority, KYC/KYB, risk, counterparty and engagement-readiness processes.

04

Deliver Services

To perform agreed advisory, analytical, documentation, feasibility or transaction-management services.

05

Protect ECM USA

To identify fraud, impersonation, misuse, security threats, misrepresentation or attempts to circumvent controls.

06

Business Administration

To maintain appropriate records, administer relationships, operate the website and support legitimate internal business requirements.

Website Forms

Inquiry and review forms serve different purposes.

01
General Contact The General Contact form is intended for ordinary communications and inquiries. Information submitted may be used to understand and respond to the communication.
02
Institutional Review Request The Institutional Review form collects additional information intended to help ECM USA conduct a preliminary assessment of a prospective client, project, transaction or mandate.
03
Form Processing Website submissions may be transmitted or processed using third-party website infrastructure and form-processing services engaged to support website functionality.
04
Further Information If a matter progresses, ECM USA may request additional information through appropriate channels rather than relying solely on the initial website submission.
Disclosure & Processing

Some information requires supporting infrastructure.

Website Providers Website hosting, infrastructure and related providers may process information required to operate the website.
Form Processing Form-processing providers may transmit, process or store information submitted through website forms.
Professional Advisors Information may be shared with legal, tax, accounting or other professional advisors where appropriate and subject to applicable obligations.
Mandate Participants In a formal engagement, information may be shared with authorized counterparties or service providers where appropriate to the agreed mandate.
Legal Requirements Information may be disclosed where ECM USA reasonably believes disclosure is required by applicable law, legal process or competent authority.
Protection & Security Appropriate disclosure may occur where reasonably necessary to protect rights, systems, users or legitimate business interests or to investigate suspected wrongdoing.
Commercial Use of Personal Information

Client information is not a commodity.

ECM USA does not operate a business model based on selling personal information supplied by prospective clients, clients or professional contacts as a standalone commercial product.

Information may nevertheless be processed by third-party service providers that support website operations, communications, administration, security or professional services, subject to their applicable terms and privacy practices.

Use of third-party infrastructure does not mean that ECM USA has sold information merely because information must be processed by a service provider in order to deliver the relevant service or website functionality.
Information Security

Security is managed, not presumed.

ECM USA seeks to use reasonable administrative, organizational and technical measures appropriate to the nature of information under its control and the context in which that information is processed.

However, no website, email system, online transmission, cloud platform or electronic storage environment can be represented as completely secure in all circumstances. Users should therefore exercise appropriate care when transmitting information electronically.

Users should not provide passwords, private keys, one-time passcodes, unrestricted banking credentials or other authentication information through ECM USA's website forms or ordinary email communications.

ECM USA may establish more controlled information-sharing procedures where a prospective or active mandate requires confidential, commercially sensitive or enhanced due-diligence documentation.
Retention

Information is retained according to context.

ECM USA may retain information for periods reasonably necessary to fulfill the purpose for which it was collected, administer a relationship, maintain appropriate business records, comply with contractual or legal obligations, address disputes, protect legitimate interests or satisfy applicable professional and compliance requirements.

Retention periods may therefore vary according to the category of information, the status of an inquiry or engagement, applicable requirements and the need for appropriate records.

General inquiries and correspondence
Institutional Review submissions
Qualification and compliance records
Engagement and mandate documentation
Contractual and financial records
Security and fraud-prevention records
Privacy Requests

Applicable rights depend on law and circumstances.

Depending on the jurisdiction, nature of the information and applicable law, an individual may have rights concerning personal information held about them.

ECM USA will consider legitimate privacy requests in accordance with applicable requirements and may need to verify the identity and authority of the person making the request before acting upon it.

Access Request information concerning personal data held, where applicable.
Correction Request correction of inaccurate or incomplete personal information.
Deletion Request deletion where applicable and where retention is not otherwise required or justified.
Restriction Request limitation of certain processing where such a right applies.
Objection Raise an objection to certain processing where applicable law provides that right.
Other Applicable Rights Exercise additional rights that may apply under relevant privacy legislation.
Cross-Border Context

ECM USA operates in a cross-border environment.

ECM USA's business and prospective mandates may involve persons, companies, professional advisors, service providers, counterparties and projects located in different jurisdictions.

Information may therefore be processed or accessed in jurisdictions different from the jurisdiction in which the person providing the information is located, including where third-party technology or professional service providers operate internationally.

Privacy and data-protection laws vary among jurisdictions. Where applicable requirements govern a particular transfer or processing activity, ECM USA may implement or rely upon appropriate arrangements consistent with those requirements.

Access to ECM USA's website from a particular jurisdiction does not, by itself, establish that every privacy regime applicable in that jurisdiction governs every aspect of ECM USA's operations.
Children

This website is intended for professional and business use.

ECM USA's website and institutional services are directed toward businesses, organizations, professionals, principals and other persons acting in a commercial or professional capacity. They are not designed or intended as services directed to children. ECM USA does not knowingly seek personal information from children through its institutional inquiry processes.

Policy Updates

This policy may evolve with the business.

ECM USA may revise this Privacy Policy from time to time to reflect changes in website functionality, service providers, business operations, professional requirements, legal developments or information-handling practices.

The version published on this website represents the current website Privacy Policy. Material changes may be communicated through the website or by other appropriate means where circumstances warrant.

Privacy Contact

Questions about your information?

Questions concerning this Privacy Policy or requests relating to personal information may be submitted to ECM USA through its official contact channels.

Please provide sufficient information for ECM USA to understand the request. Additional information may be requested where reasonably necessary to verify identity, authority or the information to which the request relates.

Organization Efficient Consulting & Management USA LLC United States
Information Governance

Appropriate information.
Appropriate purpose. Appropriate control.

ECM USA's information-handling approach is intended to support responsible communication, institutional review, professional engagement and business administration while maintaining appropriate boundaries around sensitive information.

This Privacy Policy describes ECM USA's general website privacy practices and does not replace more specific contractual, confidentiality, compliance or data-protection requirements that may apply to a particular engagement, jurisdiction or category of information.