October Effect, Ltd. Privacy Policy  

Last updated: December 17, 2025

October Effect Ltd (“we,” “us,” or “our”) is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website or interact with our services, and it outlines your rights regarding that data.

We do not sell or share personal information for marketing or promotional purposes.

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

 

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information. 

We may collect the following categories of personal information:

Identity Information: 

• First and last name
• Contact Information
• Email address
• Phone number
• Mailing or billing address

Technical Information

• IP address
• Browser type and version
• Time zone setting
• Operating system and platform
• Device and usage information

Usage Information

• Information about how you interact with our website, content, and services

Marketing & Communication Preferences

• Your preferences regarding receiving communications from us

How We Use Your Information

We use personal information for the following purposes:

• Service Delivery: To provide requested services and respond to inquiries
• Customer Support: To communicate with you regarding your account or questions
• Website Operations: To maintain and improve website functionality and user experience
• Communications: To send informational or service-related communications
• Analytics: To understand website usage trends and improve our services



SMS Messaging Program

If you opt into our SMS messaging program, you may receive customer care messages such as service updates, appointment reminders, or account-related notifications.

• Message frequency varies
• Message and data rates may apply
• Consent to receive SMS messages is not a condition of purchase
• You may opt out at any time by replying STOP
• For assistance, reply HELP

Mobile information, including text messaging opt-in data and consent, will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data is used solely to provide customer care and service-related communications.

Data Sharing and Disclosure

We do not share personal information with third parties for marketing or promotional purposes.

We may share personal information only in the following limited circumstances:

• Service Providers: With trusted third parties who perform services on our behalf, such as IT support, data hosting, and telecommunications providers
• Legal Obligations: When required to comply with applicable laws, regulations, or legal processes
• Protection: To protect the rights, property, or safety of our business, clients, or others

You may request to: 

1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
   
2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
   
3. Request rectification of your personal information that is in our control.
   
4. Request erasure of your personal information. 
   
5. Object to the processing of personal information by us. 
   
6. Request to restrict processing of your personal information by us.
   
7. Lodge a complaint with a supervisory authority.
   

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the contact information provided on our website.

Opt-Out Options

You may opt out of receiving communications from us at any time:



• SMS: Reply STOP to any text message
• Email: Click the unsubscribe link included in our emails

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 



We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy .

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 



This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:



• Data encryption where appropriate
• Access controls limiting data access to authorized personnel
• Regular review of security practices

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you. 

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 



Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [add applicable email address] .

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" date at the top of this page. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us using the contact information provided on our website.

October Effect, Ltd.

One Columbus Center Suite 651A

Virginia Beach VA 23462

(757)-390-3341