Privacy Policy

Effective Date: AUGUST 23, 2011

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Efficient Frontier, Inc. (referred to further as "Efficient Frontier," “we,” “us” and “our”) has established this Privacy Policy in order to demonstrate its firm commitment to privacy. The following policy is applicable to Efficient Frontier's information collecting, use and disclosure practices for the Efficient Frontier web site, located at http://www.efrontier.com. Your use of this site tells us you have read and accept the practices outlined in this policy.

Efficient Frontier has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information.  TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at .(JavaScript must be enabled to view this email address). If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program only covers information collected through this web site.

Efficient Frontier complies with the U.S. – E.U.  & U.S. – Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union and Switzerland.  Information regarding the U.S. - E.U. & U.S. - Swiss Safe Harbor Frameworks can be found at:  http://export.gov/safeharbor.

This policy does not apply to the practices of companies that Efficient Frontier does not own or control or to people it does not employ or manage.

Efficient Frontier's policy regarding use of your individual identifying information supplied to us or collected via your visit to our web site covers these areas:

Information Collection and Use
Efficient Frontier is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in ways that vary from what is disclosed in this statement. Efficient Frontier collects information from our users at several different points on our Web site. This may include traffic data including user's IP address, domain server, type of computer, and type of Web browser. This is anonymous information that does not personally identify a user but is helpful for marketing purposes or for improving a user's experience on the site. Efficient Frontier also uses "cookies" to customize content specific to user's interests. 

Personal information, such as a user's name, address, company function, contact information and range of paid search spend may be gathered from you on a voluntary basis in order to provide you with services, requested information or customer service. Users need not submit this information to use the site.

Clients also have the ability to use this site to obtain information on their accounts. For clients to access and use these services, Efficient Frontier requires them to provide Efficient Frontier with information that personally identifies them. This may include client's name, mailing address, and e-mail address as well as user name and password. If a client communicates with Efficient Frontier through e-mail or completes an online form or survey, information provided may be collected.

As a part of its services, Efficient Frontier compiles and stores data and information and generates reports related to client's access to and use of Efficient Frontier's services.

Efficient Frontier uses user and client information collected to send users and clients information about our products and services or promotional material from some of our partners, or to contact users or clients when necessary. Efficient Frontier also uses user and client information to provide a better experience on the Web site and to improve our client services.

As we continue to develop our business, we may sell certain of our assets. In such transactions, visitor information likely will be one of the transferred business assets. Also, in the event that Efficient Frontier or substantially all of its assets is acquired, our visitor information may be an asset that is reviewed and transferred. Such a transaction will be disclosed per our "Notification of Changes" guidelines below.

We will retain your information for as long as your account is active, as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Registration
In general, when you visit our Web site and access information, you remain anonymous. Some areas of our Web site may require registration to access, although typically all that is required is your e-mail address and some basic information about you, such as name, company name and job function. Registered clients may have a user name and password to access their company information.

Subscription
Site users have the opportunity to subscribe to Efficient Frontier's mailing list, by filling out an optional form. In order to subscribe, a user may be required to give basic information (such as name and e-mail address). This information is used to distribute newsletters, contact the user about press releases, corporate announcements and the services on our site for which they have expressed interest. No other use of this information is made by Efficient Frontier unless otherwise indicated on this site, or in future communications with the user. Users who no longer wish to receive newsletters, press releases, corporate announcements, or promotional materials may opt-out of receiving these communications by following the instructions included in each e-mail,replying to that e-mail with the word "unsubscribe" in the subject line or by e-mailing us at .(JavaScript must be enabled to view this email address).

Public Forums
Our Web site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us through one of the methods listed below.  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Log Files
We may use IP addresses to analyze trends, administer the site, track users' movements and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Unless otherwise indicated, this information is not shared with anyone outside of Efficient Frontier and/or its designated contractors. When shared with contractors, usage is for the purpose of analyzing user trends and demographics. No IP addresses will be shared with any third party other than for such research and reporting services for Efficient Frontier's internal use.

Cookies
A cookie is a piece of data stored on a user's hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Efficient Frontier uses cookies to enhance the user experience of our web site by means such as storing password or user preference information. If a user rejects the cookie, they may still use our site with the only drawback being the disablement of some of the usability features of our site. Some of our business partners may use cookies on our site. However, we have no access to or control over these cookies.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.)

Information Sharing and Disclosure
Efficient Frontier may partner with third party contractors to help process orders and provide other services, such as sending e-mail communications to you on our behalf. These companies do not retain, share, store or use personally identifiable information for any secondary purposes and are authorized to use your personal information, such as your name and e-mail address, only as necessary to provide these services to us.

We may share aggregated demographic information about our user base with our partners and clients. This information does not identify individual users.

Legal Disclaimer
We reserve the right to disclose personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us.

Clear Gifs
We, and our third party web analytics partners, employ a software technology called clear gifs that help us better manage content on client web sites. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. If you submit your e-mail address through this site, we will associate it to the informationgathered by clear gifs in order to help us with our marketing services.

Our Clients
Efficient Frontier serves as an agent for each of its clients, in that we provide our services for the benefit of the client. Each of our clients uses our services to maximize their advertising campaigns. Each client instructs us as to what types of data it would like us to collect on its behalf. This data may include search engine referral and purchase behavior and information.

Efficient Frontier may track certain actions on clients' Web sites, including Web surfers visiting certain pages on the client's sites or taking specific actions. We use persistent cookies and clear GIFs to determine activity at the client's site.

Testimonials
We post client testimonials on our web site which may contain personally identifiable information.  We do obtain the client's consent via e-mail prior to posting the testimonial to post their name along with their testimonial.

Links
This web site may contain links to other sites. Please be aware that Efficient Frontier is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this web site.

Security
Efficient Frontier has implemented generally accepted standards of technology security in order to protect information from loss, misuse and unauthorized access. Only employees who need the information to perform a specific job are granted access to personally identifiable information. No method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee its absolute security.

Correction/Updating Personal Information
If a user's personally identifiable information changes (such as your zip code or e-mail address), or if a user no longer desires our service, we will endeavor to provide a way to correct, update or remove that user's personal data provided to us. This can usually be done by e-mailing .(JavaScript must be enabled to view this email address). We will respond to your request to information access within 30 days.

Notification of Changes
If we decide to change our privacy policy, we will make commercially reasonable efforts to post those changes on our homepage so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an e-mail or prominent notice on our site prior to the changes taking effect. Users will have a choice as to whether or not we use their information in this different manner.

Contact Us

809 Eleventh Avenue - Building 4
Sunnyvale, CA 94089
Toll Free: 1.877.273.6669
Tel: 1.408.585.2700
Fax: 1.408.585.2702

Efficient Frontier participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce.  As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://watchdog.truste.com/pvr.php?page=complaint&urlfax at415-520-3420, or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://watchdog.truste.com/pvr.php?page=complaint&urlor request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.