Skip to content

EU & Swiss Privacy Policy

Effective date: August 1, 2025

Welcome to the Ecoflex Manufacturing LLC. (hereinafter, “Ecoflex,” “Company,” “us,” “our,” or “we”) EU & Swiss Privacy Policy (the “Policy”).

This Policy governs how Ecoflex processes the Personal Information of individuals located in the United Kingdom ("UK"), European Union (“EU”), European Economic Area (“EEA”), and Switzerland (collectively, the “Data Subjects”) that are visiting our website, www.Ecoflex-Mfg.com, and the other websites under the Ecoflex-Mfg.com domain (collectively, the “Site”), and our customers who use our SaaS product, tools, and related services together with the Sites, the (“ERP Portal”).

This Policy explains how we collect, use, disclose, and protect Data Subjects’ information as part of the Service in accordance with data-protection laws in the UK, EU, EEA, and Switzerland (collectively the “Data Protection Laws”). Any discussion of your use of the Service in this Policy is meant to include your visits and other interactions with the ERP Portal, whether or not you are a user of Ecoflex’s SaaS product.

Capitalized terms that are not defined in this Policy have the meaning given in our Terms of Service or Global Privacy Policy including any relevant agreement, policy, or addendum incorporated therein and any amendments or modifications thereto.

By accessing and using our ERP Portal, you signify your acceptance of this Policy. If you do not agree with or you are not comfortable with any aspect of this Policy, our Global Privacy Policy, or the Terms of Service, you should immediately discontinue access or use of our ERP Portal. In the event of a conflict between the Global Privacy Policy and this Policy, this Policy supersedes the Global Privacy Policy.

‍This version of our Privacy Policy covers how we collect, use, disclose, and protect the data of those in the United Kingdom (UK), European Union (EU), European Economic Area (EEA), and Switzerland. It takes precedence over the Global Privacy Policy if there are any conflicts between the two.
‍
Your use of Ecoflex Manufacturing website and/or ERP Portal means you agree to these policies and terms. If you do not agree, you should not use our service.

  1. Our relationship with you

In order for you to understand Ecoflex’s data protection obligations and your rights to your Personal Information under this Policy, it is important that you identify which relationship(s) you have with Ecoflex.

  • A “User” is an individual providing Personal Information to us via our website or other services, products, or ERP Portals, such as by signing up for our newsletter or making an account and posting on the Forums. Ecoflex is in a “data controller” relationship with Users.
  • A “Client” is a specific type of User that has engaged us to act as an agent or, as a “Data Processor” by obtaining services made available via ERP Portal. Ecoflex is in a “data processor” relationship with Clients.
  • A “Customer” is a specific type of User that has engaged us to act as end-user or, as a “Data Processor” by obtaining products and/or services made available via Ecoflex Manufacturing’s website. Ecoflex is in a “data processor” relationship with Customers.
  • Ecoflex does not have a direct relationship with Client’ End Users. A “Client End User” is an individual that provides their Personal Information to our Clients. We do not control the purposes nor the means by which this Personal Information is collected, and we are not in a direct relationship with Client End Users. For details about how Personal Information about Client End Users is handled, please review our Clients’ privacy policies instead of this one, and contact them for further information.

Hereinafter we may refer to Clients, Customers and Users collectively as “you.”

  1. Notice

Ecoflex provides notice to you through posted privacy policies and may provide additional "just-in-time" disclosures about the data collection, use, and sharing practices of specific ERP Portal. The Global Privacy Policy generally describes our privacy practices, while this Policy is specific to Users and Customers located in the UK, EU, EEA, and Switzerland.

As a data processor, Ecoflex is not able to provide notice to or obtain consent from Client End Users. To the extent required by law, Ecoflex supports Clients’ data-protection compliance efforts, but it is up to the Client to ensure the appropriate data protection safeguards are in place before processing Personal Information from Client End Users.

  1. Collection of Personal Information

As described in the Global Privacy Policy, Ecoflex collects various types of Personal Information about you while you are using the ERP Portal. Information that is anonymized or aggregated is not “Personal Information.”

In general, we collect the following types of Personal Information:

  • Registration data: full name, email address, and optional social media account information.
  • Profile data: biographical information, avatar, portfolio of work, skills, and/or freelance availability.
  • Financial data: bank account information, payment card information, transaction history, and/or company billing information.
  • Transaction data: information about the transactions you make on our ERP Portal, such as the names of your customers, the products, and services you purchase, product and/or service discounts, when products and/or services are shipped, and/or timestamps of certain actions.
  • Online identifiers: geolocation/tracking details, browser fingerprint, OS, browser name and version, security card identification details, and/or IP addresses.
  • Interaction data: survey responses, forum or blog posts, authentication data, security questions, public social networking posts, user ID, click-stream data, and other data collected via cookies and similar technologies. Please read our Cookie Policy for more information.

Any information that is disclosed in the forums or our blog becomes public information. This means that your posts are available to the public and may appear in search engines or other publicly available ERP Portals and may be “crawled” or searched by third parties. Your public posts can also be read, collected, or used by others to send you unsolicited messages. Be careful when posting on public parts of our ERP Portal and website and do not post any information that you are not comfortable sharing publicly.

  1. Purposes of processing

Under Data Protection Laws, we are required to notify you about our purposes of processing your Personal Information, as well as the legal basis for such processing.

Unless otherwise permitted by law, we may process your Personal Information:

  • If you consent to the processing
  • To satisfy our legal obligations
  • If it is necessary to carry out our obligations arising from any contracts, we entered with you or to take steps at your request prior to entering into a contract with you
  • In the public interest
  • In your vital interests, or
  • For our legitimate interests, such as to protect our property, rights, or the safety of Ecoflex, our customers, or others

Purpose of processing

Legal basis

To ensure network and information security.

‍We process your Personal Information to:

  • Enhance the security of our ERP Portal
  • Combat spam or other malware or security risks
  • Monitor and verify identity or service access
  • Comply with applicable security laws and regulations

Without processing your Personal Information, we may not be able to ensure the security of our ERP Portal.

Processing is necessary for compliance with a legal obligation.

To enforce Ecoflex’s terms and agreements.

We have Terms of Service and other policies that define how you can use our ERP Portal. To ensure that you and others are using our ERP Portal and website in accordance with such terms and policies, we may process your Personal Information to:

  • Investigate, prevent, and mitigate any potentially prohibited or illicit activities
  • Enforce our agreements with third parties, and/or
  • Invoice and collect fees and/or payments based on your use of our Ecoflex Manufacturing website and ERP Portal.

We collect information about your account usage and monitor your interactions with our ERP Portal. We may use any of your Personal Information collected on our ERP Portal and website for these purposes. The consequence of not processing your Personal Information for such purposes is the termination of your account, as we cannot operate our Ecoflex Manufacturing website and ERP Portal in accordance with our terms.

Processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering into a contract.

To provide our ERP Portal.

We process your Personal Information to provide the ERP Portal. For example, when we bill a client for our products or services, we collect registration, sales, financial, transaction, and interaction data to send the invoice to the client and obtain payment. We cannot provide you with an ERP Portal without such information.

Processing is necessary for the performance of a contract to which the Data Subject is a party or to take steps at the request of the Data Subject prior to entering into a contract.

To provide Service Communications.

We may reach out to you to send you administrative or account-related information to keep you in the loop about our ERP Portal, alert you of relevant security issues or updates, or provide other transaction-related information to you. While we generally use your registration data for this purpose, we may send personalized Service communications to you based on other Personal Information, such as interaction, payment, or transaction data. Without such communication, you may miss important developments relating to your account that may affect how you can use our ERP Portal.

Processing is necessary for the performance of a contract to which the Data Subject is a party or to take steps at the request of the Data Subject prior to entering into a contract.

To ensure quality control.

We process your Personal Information for quality control and staff training to make sure we continue to provide you with accurate information. Without our quality-control measures, you may experience issues while using the ERP Portal. For example, you may not be able to bill clients accurately or in a timely fashion, or you may encounter interruptions on our ERP Portal.

Processing is necessary for the ongoing performance of a contract to which the Data Subject is a party or to take steps at the request of the Data Subject prior to entering into a contract.

To provide customer service.

When you contact our customer service channel, we process your Personal Information to respond to your questions, disputes, feedback, or issues with our ERP Portal. We may process your Personal Information in response to another customer’s request, as relevant. Without processing your Personal Information for such purposes, we cannot respond to your requests.

Processing is necessary for the performance of a contract to which the Data Subject is a party or to take steps at the request of the Data Subject prior to entering into a contract.

To enhance your experience on our ERP Portal.

We process your Personal Information to provide a personalized experience on our ERP Portal and to implement your feedback or the preferences you request. For example, you may share parts of your social media account information with us for authentication. Without such processing of your Personal Information, we may not be able to ensure your continued enjoyment of part or all our ERP Portal.

Processing is necessary for the purposes of the legitimate interests pursued by Ecoflex.

For research and development purposes.

We process your Personal Information to better understand you and the way you use and interact with our ERP Portal. For example, interaction data can provide helpful insights that assist us with measuring, customizing, or improving current ERP Portal. In addition, such information can help us develop new ERP Portals for your enjoyment. Without such processing, we cannot ensure your continued enjoyment of our ERP Portal.

Processing is necessary for the purposes of the legitimate interests pursued by Ecoflex.

To facilitate acquisitions, mergers, or other business transactions.

We may process any of your Personal Information as is necessary in the context of acquisitions, mergers, or other business transactions. We will try to notify you in advance if we intend to process your Personal Information for this purpose. You will have the option of terminating your account if you do not wish to have your Personal Information processed for such purposes.

Processing is necessary for the purposes of the legitimate interests pursued by Ecoflex.

To engage in marketing activities.

We may send you marketing communications from time to time. Such marketing communications may contain information about our events, partner events, or promotional offers. We may use your interaction and/or transaction data to provide you with targeted marketing communications. You can opt out of our marketing communications at any time and free of charge.

Processing is necessary for the purposes of the legitimate interests pursued by Ecoflex.

We will only use your Personal Information for the purposes above or for compatible purposes.

If we wish to share your Personal Information with third parties that are not described in this Policy or the Global Privacy Policy, we may request your permission as required by Data Protection Law. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. However, if you limit the way we use your Personal Information, certain features or ERP Portal may not be available to you.

  1. Third party sources of information

We only collect Personal Information about you from third parties that you voluntarily choose to connect with our ERP Portal. For example, you can share Personal Information with us when you access our Site or Service through a third-party connection, or when you log in or connect an application to Ecoflex. We process this information for the purpose of performance of our contracts with you. For more information, please see Section 2 of the Global Privacy Policy.

  1. Third party recipients

Ecoflex conducts the majority of data processing activities required to provide you with the ERP Portal. However, we do engage third-party service providers (“Sub-Processors”) to assist with supporting our ERP Portal, including vendors in the following areas:

  • Credit card or payment processors
  • Cloud storage providers
  • Customer support tools
  • Product development tools
  • IT and security service providers, and
  • Marketing or analytics tools
  • Product recycling, reconditioning, and/or re-bottling service providers.

Each service provider is vetted and bound by contractual obligations that are equivalent to the provision of this Policy or more stringent. See the “Accountability for Onward Transfers” section below for more information about our agreements with third parties.

  1. Retention

We are committed to keeping your Personal Information secure on our ERP Portal. We limit our storage of your Personal Information to the amount of time necessary to fulfill the purposes for which we collected the Personal Information, including for the purposes of satisfying any legal, accounting, or reporting obligations, or to resolve disputes. Although retention laws and requirements vary by jurisdiction, we have some standard retention periods for parts of your Personal Information which are described below:  

  • Contact information collected for marketing purposes, such as your name and email address, is retained on an ongoing basis until you unsubscribe from our marketing communications. Thereafter we will add your contact information to our suppression list indefinitely to respect your “unsubscribe” request.
  • Browser interaction data, such as cookies and trackers, is kept for a period of up to four years from expiry of the cookie or date of collection.
  • Product analytics data is kept for up to 5 years and automatically deleted on an ongoing basis.

If you have questions about retention periods that apply to any other data, please contact us at privacy@Ecoflex-mfg.com.

  1. International transfers

Ecoflex uses approved data transfer mechanisms to transfer your Personal Information in and out of the United States and other jurisdictions. In relation to transfers of Personal Information to the U.S., Ecoflex transfers Personal Information pursuant to EU-U.S. and Swiss-U.S. Data Privacy Framework as well as the UK Extension to the EU-U.S. Data Privacy Framework. Ecoflex has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Ecoflex has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. Furthermore, Ecoflex does assume liability for onward transfer to third parties and shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.    

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Ecoflex commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.   If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution  for more information or to file a complaint.  Ecoflex provides alternative dispute resolution provider and appropriate recourse free of charge.

  1. Accountability for onward transfer

Ecoflex complies with the Data Privacy Framework Accountability for Onward Transfer Principle for all onward transfers of Personal Information from the UK, EU, EEA, and Switzerland, including the onward transfer liability provisions. Ecoflex contractually obligates third-party agents, service providers, and processors to provide the same level of protection as required by the Data Privacy Framework and under the Data Protection Laws. In addition, we limit and specify the purpose(s) for processing your Personal Information consistent with any notice provided to you and your consent.

Upon request by the United States International Trade Administration or Department of Commerce, Ecoflex will provide a summary or representative copy of the relevant privacy provisions of its agreement with service providers, processors, and third-party agents.

In certain situations, Ecoflex may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with a judicial proceeding or court order, or as otherwise required by law. In such an event, we will notify you unless we are prohibited by a binding legal order or applicable law.

  1. Security

We are committed to protecting the security of your Personal Information by using reasonable and appropriate physical, electronic, and administrative safeguards. Please refer to Section 6 of the Global Privacy Policy for more detailed information about our security safeguards.

  1. Direct marketing

Direct marketing includes any communications to you that are only based on advertising or promoting products and services. Transactional communications about your account or our ERP Portal and website are not considered “direct marketing” communications.

We will contact Clients by electronic means, including email, or via your sales representative based on our legitimate interests or the Client’s consent. When we rely on legitimate interest, we will only send you information about our ERP Portal and website that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

Ecoflex’s in-house sales team may use your Personal Information and ERP Portal and website data to recommend products, services, and/or special offers.

If you do not want us to use your Personal Information in this way, or to pass your Personal Information on to third parties for marketing purposes, please go to the email settings for your account to opt out, click an unsubscribe link in your emails, or contact us at privacy@Ecoflex-mfg.com You can object to direct marketing at any time and free of charge.

  1. Your rights

You have the rights to your Personal Information that are described below. You can exercise your rights by contacting us at privacy@Ecoflex-mfg.com so that we may consider your request under applicable law. When we receive an individual rights request via email, we may take steps to verify your identity before complying with the request to protect your privacy and security.

  • Right to withdraw consent. When we rely on your consent for processing your Personal Information, you have the right to withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of Ecoflex’s processing based on consent before your withdrawal.
  • Right of access to and rectification of your Personal Information. You have a right to request a copy of your Personal Information stored with Ecoflex. We will provide a copy to you without undue delay subject to some fee associated with gathering of the information, as permitted by law. We may limit or deny your request if providing you with a copy could adversely affect the rights and freedoms of others. You may also request us to correct or update any inaccurate Personal Information stored by us.
  • Right to erasure or “the right to be forgotten”. You have the right to request erasure of your Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented to, but no longer consent to; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. Your right to erasure is subject to limitations by relevant Data Protection Laws.
  • Right to data portability. If we process your Personal Information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your Personal Information in a structured, commonly used, and machine-readable format, and to have us transfer your Personal Information directly to another data controller, at your cost and where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
  • Right to restriction of processing. You have the right to restrict our processing of your Personal Information where one of the following applies:
  1. You contest the accuracy of your Personal Information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your Personal Information.
  2. The processing is unlawful, and you oppose the erasure of your Personal Information and request the restriction of its use instead.
  3. We no longer need your Personal Information for the purposes of the processing, but it is required by you to establish, exercise, or defend legal claims
  4. You have objected to processing, pending the verification of whether the legitimate grounds of Ecoflex’s processing override your rights.

Restricted Personal Information shall only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

  • Notification of erasure, rectification, and restriction. We will communicate any rectification or erasure of your Personal Information or restriction of processing to each recipient to whom your Personal Information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information. If we have made your Personal Information public and we are required to erase the Personal Information, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your Personal Information that you have requested the erasure of any links to, or copy or replication of your Personal Information.
  • Right to object to processing. Where the processing of your Personal Information is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We can continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  • Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your Personal Information, including profiling, which produces legal or similarly significant effects on you. There may be exceptions or limitations to this right as defined under relevant Data Protection Laws.

 

  1. Limitations to your rights

Your rights to your Personal Information are not without limits. Access may be denied when:

  • Denial of access is required or authorized by law
  • Granting access would have a negative impact on other's privacy
  • Doing so protects our rights and properties, or
  • Where the request is frivolous or vexatious
  1. Recourse, enforcement, & liability

We will investigate and work expeditiously to resolve any complaints or disputes in accordance with this Policy and the Data Privacy Framework. If you have an inquiry or complaint regarding our privacy policies or practices, please contact us first at privacy@Ecoflex-Mfg.com.

If you have an unresolved complaint or dispute arising under the requirements of the Data Privacy Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism free of charge. Our independent dispute resolution mechanism is JAMS. For more information and to file a complaint, visit the JAMS website. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Data Privacy Framework Panel.

You also have the right to lodge a complaint with a competent supervisory authority.

  1. Children's data

We recognize that some Data Protection Laws vary based on the age of consent. Depending on the jurisdiction, the age of consent can be between 13 to 18 years old. We do not knowingly request to collect Personal Information from any Data Subject under the age of consent as defined by the jurisdiction in which the Data Subject resides. If we are aware of or suspect that a Data Subject is under the age of consent, we will terminate the Data Subject’s account. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individual under the age of consent using our ERP Portal.

  1. Changes to this Policy

We reserve the right to modify, update, or change this Policy from time to time in the usual course of business, so we encourage you to review this page periodically. Notwithstanding, when we change this Policy in a material manner, we will update the effective date at the top of this page and provide you with reasonable advance notice before the updates to this Policy become effective. Ecoflex may provide such notifications to you via email notice, written or hard copy notice, and/or through posting of such notice on the ERP Portal. We reserve the right to determine the form and means of providing notifications to you. You may be required to click-to-accept or otherwise agree to the updated Policy, but in any event your continued use or access of the ERP Portal and website after the effective date of the updated Policy shall constitute your agreement to the updated Policy. The Policy will be effective as of the date specified in the effective date at the top of this page and will apply to your use of the ERP Portal and website from that point forward. If we update this Policy in a non-material manner after the effective date, we will update the last modified date at the top of this page. If you choose not to agree to this Policy or any future updated Policy, you may not use or access (and must discontinue any use or access to) the ERP Portal and website. Ecoflex is not responsible for any automatic filtering you or your network provider may apply to email notifications we send to the email address you provide us.

  1. Contact us

If you have any questions regarding this Policy or about the privacy practices of Ecoflex, please contact us by email at privacy@ecoflex-mfg.com, or at:

Ecoflex Manufacturing, LLC.
Box 107-626

2201 Long Prairie Road

Flower Mound, Texas 75022 USA