Data Controller

EMS EFX (“we,” “us,” or “our”), located at 7301 N State Highway 161, Suite 148,
Irving, TX 75039, provides this Privacy Policy for our website, AI-driven digital
brand growth services, proprietary animation engine, exclusive digital mementos,
and invite-only Secure Portal (collectively, the “Services”).

Overview

We comply with the Texas Data Privacy and Security Act (TDPSA)
and, where applicable, the Florida Digital Bill of Rights (FDBR).
As a Texas-based company processing data relating to Texas and Florida residents,
we prioritize data minimization, security, and
consumer rights.

Information We Collect

• Personal Information You Provide: Name, email, phone, billing info, account credentials, professional details (Secure Portal).
• User Content/Inputs: Prompts, images, videos, audio, branding assets for AI/EFX processing.
• Automatically Collected: IP address, device info, browser data, usage logs, cookies.
• Sensitive Data: We do not process sensitive personal data without explicit opt-in consent. If user inputs contain such data, we process only as necessary and with consent.

How We Use Information

• Deliver Services, including AI outputs and Secure Portal management.
• Improve proprietary AI using anonymized or aggregated data only.
• Billing, support, and fraud prevention.
• Targeted advertising, where applicable, with opt-out rights.
• Legal and regulatory compliance.

Sharing & Disclosure

• Service providers under contracts requiring appropriate privacy and security obligations.
• Business transfers such as mergers, acquisitions, or asset sales.
• Legal requirements where disclosure is necessary by law.

Sensitive Data & Consent

Explicit opt-in consent is required before processing sensitive personal data,
including biometrics if used in AI avatars or similar services.

If our practices ever change such that we sell sensitive personal data, we will
provide any notice required by law.

Consumer Rights

Under TDPSA and, where applicable, FDBR, residents may have the right to:

• Confirm processing and access personal data.
• Correct inaccuracies.
• Delete personal data.
• Opt out of targeted advertising.
• Opt out of the sale of personal data.
• Opt out of profiling with legal or significant effects.
• Appeal denials.
• Receive non-discriminatory treatment for exercising rights.

Data Security & Retention

We use reasonable safeguards including encryption, access controls, and secure
processing practices.

We retain data only as long as necessary for service delivery, legal obligations,
dispute resolution, and legitimate business purposes.

Children’s Privacy

Our Services are not intended for children under 13 and are not knowingly directed
to minors without appropriate safeguards.

Changes

We may update this Privacy Policy from time to time. Updated versions will be posted
with a revised effective date.

Data Updates

To ensure the integrity of our AI-driven processes, we provide mechanisms for users to regularly update their personal information. Maintaining current data allows us to provide more accurate service delivery and ensures that communication regarding your projects remains consistent.

Contact

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at our:
Corp Offices: Irving / Las Colinas, TX in Plaza One61.