Legal & Privacy
Privacy Policy
Last updated: June 30 2026efrain ("we," "us," "our") is a digital marketing agency operated by Efrain, based in Montreal, Quebec, Canada, serving industrial safety and material handling distributors. This Privacy Policy explains how we collect, use, store, and protect personal information through efrain.ca (the "Site") and in the course of providing our services, in accordance with Quebec's Act respecting the protection of personal information in the private sector (Law 25).
Designated person responsible for the protection of personal information:
Efrain — efrain@efrain.ca
Personal information we collect:
Contact information: name, email address, province, and other details submitted through contact forms, email, or onboarding
Payment information: processed directly by Stripe; we do not collect or store full payment card details
Site usage information: pages visited, time on site, browser/device type, approximate location, referral source, via Google Analytics
Advertising and conversion data: via Google Ads, for measuring ad performance and remarketing
Email engagement data: opens, clicks, subscription status, via Brevo
How we use it: to respond to inquiries, deliver and invoice services, send marketing/service emails (unsubscribe anytime), analyze and improve Site performance, optimize ad campaigns, and meet legal/accounting obligations. We do not sell your personal information.
Third-party providers: Google Analytics, Google Ads, Google Drive, Brevo, and Stripe support our operations. Some store or process data outside Quebec, including in the United States. We rely on these providers' own contractual and security commitments as part of assessing that your data receives adequate protection during transfer.
Retention: Client and lead data (name, email, province) is retained for 1–2 years after the relationship ends or a lead goes inactive, then deleted or anonymized, unless a longer period is legally required.
Cookies: The Site uses cookies through Google Analytics and Google Ads to measure traffic and ad performance. Using the Site means you consent to this; you can disable cookies in your browser at any time.
Your rights under Law 25: access, correction, withdrawal of consent, deletion (subject to legal retention limits), and portability of your personal information, as well as the right to file a complaint with the Commission d'accès à l'information du Québec (CAI). Contact efrain@efrain.ca to exercise any of these rights.
Security: We take reasonable technical and organizational measures to protect your information, including relying on providers with their own industry-standard security practices.
Confidentiality incidents: In the event of an incident presenting a risk of serious injury, we will notify the CAI and affected individuals as required under Law 25.
Changes: We may update this policy from time to time; the "Last updated" date above reflects the most recent revision.
Terms of Use
By accessing or using efrain.ca (the "Site"), operated by Efrain, based in Montreal, Quebec, Canada, you agree to these Terms of Use. If you do not agree, please do not use the Site.
Services: efrain provides Google Ads management, email marketing, Amazon marketplace setup, and market intelligence services, primarily to industrial safety and material handling distributors in Canada. Specific client engagements are governed by separate service agreements, which take precedence over these Terms in case of conflict.
Use of the Site: You agree not to damage, disable, or impair the Site, attempt unauthorized access to it, use bots or scrapers without our written consent, or submit false information through any form.
Intellectual property: All content on the Site, including text, graphics, logos, and the "efrain" name and mark, belongs to Efrain or its licensors and is protected by copyright and trademark law. No reproduction or derivative use without written permission.
Payments: Purchases are processed through Stripe, and by purchasing you also agree to Stripe's applicable terms. Fees are as quoted at time of purchase or set out in your service agreement; non-refundable except as agreed in writing.
Third-party tools: The Site uses or links to Google Analytics, Google Ads, Brevo, and Stripe. We are not responsible for their content, policies, or practices.
No warranty: The Site is provided "as is," without warranties of any kind, and we do not guarantee it will be uninterrupted, secure, or error-free.
Limitation of liability: To the fullest extent permitted by law, efrain and Efrain personally are not liable for indirect, incidental, special, or consequential damages arising from use of the Site, except where such liability cannot be excluded under Quebec or Canadian law.
Indemnification: You agree to indemnify and hold harmless efrain and Efrain from claims arising from your misuse of the Site or violation of these Terms.
Governing law: These Terms are governed by the laws of Quebec and applicable federal laws of Canada. Disputes are subject to the exclusive jurisdiction of the courts of Quebec.
Changes: We may revise these Terms at any time; continued use of the Site after changes are posted means you accept the revised Terms.
Data Policy
This Data Policy describes, in operational terms, how efrain collects, classifies, stores, and secures data. It complements the Privacy Policy above.
Data we handle: identity data (name, company, title), contact data (email, province), transactional data (via Stripe), usage data (via Google Analytics), marketing data (via Brevo), advertising data (via Google Ads), and client project files (via Google Drive). We do not collect sensitive personal information such as health data or government IDs, and payment card data is handled entirely by Stripe.
Where data is stored: Google services (Analytics, Ads, Drive) store data primarily in the United States / global Google infrastructure; Brevo is EU-headquartered; Stripe operates on U.S./global infrastructure. Cross-border transfers rely on each provider's own compliance frameworks (e.g., Stripe's and Google's standard contractual protections, Brevo's GDPR-based safeguards) as part of ensuring adequate protection consistent with Law 25.
Data minimization: We collect only what's needed to qualify a lead, deliver a service, or maintain a client relationship — never more.
Retention schedule: Active clients — duration of engagement plus 1–2 years after; inactive leads — up to 1–2 years from last contact, then deleted or anonymized; financial/invoice records — retained per CRA/Revenu Québec requirements.
Security measures: Access to client data is restricted to Efrain as sole operator; third-party processors are chosen based on their own security certifications (e.g., Stripe's PCI-DSS compliance); no payment card data is stored on efrain-owned systems; account credentials for third-party tools are managed individually and never embedded in Site code.
Data subject requests: Send requests for access, correction, deletion, or portability to efrain@efrain.ca. We verify identity before actioning any request and respond within the timeframe required under Law 25.
Subprocessor changes: If we add or change a subprocessor in a way that materially changes how data is handled, we will update this policy accordingly.
