Privacy Policy

Effective date: October 11, 2026 (effective when published). This Privacy Policy applies to the Empire Consulting Firm (ECF) mobile application for Apple iOS and Google Android, our website at empireconsultingfirmllc.com, and associated client and staff portals. Please review this notice alongside any separate written service agreements and any required consumer-report authorizations.

1. Who we are and services covered

Empire Consulting Firm LLC ("ECF," "we," "us," or "our") provides financial consulting and client-support services that may include credit-report review and dispute assistance, ChexSystems and Early Warning Services (EWS) assistance, personal or business funding consultation, and business-management support. This policy covers the website, mobile app, and supporting systems. Not every service or third-party integration is active for every client.

2. Information we collect

The categories below depend on how you use ECF and the services you request.

• Contact and account information: your name, email address, phone number, mailing address, date of birth, account role, assigned specialist, selected services, account status, and sign-in/verification records. Our authentication provider processes sign-in credentials and verification codes. Certain optional identity details, such as the last four digits of a Social Security number, may be used only in an authorized workflow when applicable.
• Consultation inquiries: the contact information, requested service, preferred contact method or appointment details, and messages you submit through the public website or customer-support channels.
• Credit, banking-report, and service information: information in consumer reports and dispute materials you provide or that ECF accesses through an authorized provider connection, such as tradelines, inquiries, collections, scores where identified, report dates, correspondence, case activity, consent records, and specialist-reviewed outcomes. Funding and business-management profiles may include business information and financial-readiness details you provide.
• Documents and communications: PDFs, photographs, credit reports, identity or other supporting documents you choose to upload, messages with your assigned ECF team, support requests, referral information, and work history associated with your case.
• Device, technical, and security information: app and device identifiers required for service operation, operating system/app version, authentication and activity logs, IP-related security information, error or diagnostic records when available, and push-notification delivery tokens when enabled. Website hosting systems may collect standard browser and server-log information.

Do not send passwords, complete Social Security numbers, complete bank account numbers, or identity-document scans through the public consultation form or ordinary email. Ordinary ECF mobile registration does not request a full Social Security number. If a provider-mediated identity check is enabled, its separate instructions and disclosures will apply. Sensitive details that appear within files you voluntarily upload may still be processed for the requested service.

3. How we obtain information

We receive information from your registration, website inquiries, forms, uploaded documents, secure client/staff messages, referrals, and communications with ECF. We may also receive service information from your authorized specialist and third-party providers after any necessary identity verification, consent, or contractual steps. Information may be generated in the operation of the app, including sign-in history, case updates, audit records, and notification tokens.

4. Why we use information

• To establish, verify, secure, and administer user accounts, service enrollments, and authorized access by ECF staff;
• To respond to inquiries, consultations, and support requests and deliver service-related communications;
• To receive and review authorized financial and consumer-report information, organize supporting evidence, and manage dispute, funding-readiness, banking-report, and business-support work;
• To communicate with your assigned ECF team, share relevant documents and progress updates, and send requested or service-related notifications;
• To maintain necessary records, prevent fraud and unauthorized access, investigate security incidents, and comply with applicable legal or contractual requirements; and
• To provide ECF specialists with human-reviewed workflow planning, education, drafting support, and internal quality checks where those features are enabled.

5. Consumer reports and authorization

Creating an ECF account or choosing a service does not automatically authorize ECF to order a new consumer report. Access to or retrieval of credit, banking, or other consumer reports requires applicable authorization and any necessary provider-specific identity verification and terms. A report-connection status shown in the mobile app may mean setup is pending rather than that a live report has been imported. If an authorized report-provider connection is enabled, ECF will use information for the service you authorized. Contact us to ask about withdrawing an authorization, subject to applicable law and provider requirements; withdrawal may restrict future report access but does not undo already-completed lawful processing.

6. Providers and other disclosures

We disclose information to people and service providers only as reasonably needed for the purposes described in this policy, subject to their roles, technical integration, contractual requirements, and the service in use. Provider categories and examples include:

• Website hosting and infrastructure: website hosting, network, and security operators (including IONOS where used) that process hosting and technical logs.
• Application hosting and authentication: Supabase for account authentication, application databases, and supporting services.
• Email and mobile delivery: Resend for transactional emails; Apple Push Notification service (APNs), Google/Firebase Cloud Messaging, and Expo notification services where used for mobile delivery. Notification providers may process the technical information required for delivery.
• Authorized consumer-report and dispute operations: providers such as ConsumerDirect/SmartCredit when a connection is approved and active, and applicable report recipients, bureaus, furnishers, collectors, or agencies when an authorized and reviewed dispute is submitted.
• Mailing services: providers such as Lob, only when ECF has enabled an authorized mailing workflow for your matter.
• AI-assisted internal tools: when enabled, OpenAI or other providers may process limited non-identifying workflow-stage and service metadata to help ECF specialists prepare internal guidance. The current staff-work-coach design excludes client names, full reports, account numbers, dates of birth, and Social Security numbers from its AI advice requests, and requires human review before client-facing use. Other AI integrations, if later activated, will require separate assessment and an appropriate update to these disclosures.

ECF may disclose information when required by law or legal process, when necessary to address fraud or security issues, or with your direction or consent. We do not sell personal information collected through the ECF website or app. ECF does not use your credit-report or dispute information to offer third-party behavioral advertising.

7. Security, biometric sign-in, and notifications

ECF uses safeguards designed to protect data, including authenticated access, network encryption, database access controls, controlled document access, and audit records. Staff access is intended to be limited according to role and client assignment. No system or transmission method can guarantee absolute security.

If you choose biometric sign-in on a supported device, Face ID, Touch ID, or fingerprint verification is performed by the device's operating system. ECF does not obtain your raw facial image or fingerprint template from that biometric check. The app may use device-protected storage for locally saved sign-in information. You can disable push notifications using your device settings; sensitive credit details should be reviewed inside the authenticated app rather than on a lock screen.

8. Retention, account deletion, and data rights

We retain personal data for as long as reasonably needed to deliver requested services, secure accounts, respond to disputes, maintain required business and audit records, meet legal or contractual obligations, and resolve related matters. Different categories—including account/profile records, case correspondence, financial dispute evidence, system logs, and backups—may have different retention requirements. We delete or de-identify information once it is no longer required, subject to lawful exceptions and backup lifecycle constraints.

You may initiate deletion of your entire ECF app account and its associated data, not merely deactivation. Inside the ECF app, go to Profile → Account & Data and select the deletion-request option. You can also request deletion without the app using our dedicated page:

Request ECF Account Deletion

When we receive a request, we may ask for reasonable proof that you control the account. We will process deletion of data no longer necessary, including eligible account information, uploaded documents, messages, and account-linked records, and explain any legally required or otherwise permitted retained categories. Some dispute, compliance, fraud-prevention, security, or transaction records may need to be retained for limited lawful purposes. We will notify you of the outcome by email where possible. If outside service providers hold information for ECF, we will address applicable deletion obligations with those providers. Deleting an ECF app account does not necessarily cancel a separate legally binding service agreement; contact ECF if you also wish to end a separate service relationship.

Depending on your location and applicable law, you may also request access to, correction of, or information about your personal data, or ask to withdraw an applicable consent. We may verify your identity and may decline or limit requests only where permitted by applicable law. We will not ask for your password or full Social Security number through ordinary email.

9. Children's privacy

The ECF app and financial services are intended for adults aged 18 or older and are not directed to children. If you believe a child has provided personal information through ECF, please contact us so we can review it.

10. Changes to this policy

We may update this Privacy Policy when services, vendors, legal requirements, or information practices change. We will post revisions here with an updated effective date and provide additional notice when required.

11. Contact and privacy requests

Empire Consulting Firm LLC
Website: empireconsultingfirmllc.com
Website and privacy correspondence: Steven.blanc@empireconsultingfirmllc.com
Application support: support@empireconsultingfirmllc.com
Account deletion: ECF account deletion instructions

This public privacy notice describes ECF's data practices and is not a substitute for consumer-report consent, an engagement agreement, or jurisdiction-specific disclosures that may be required for a particular service.