ECV IL MANCO LTD. (“Entrée Capital”, ECV, “we”, “our” or “us”) respects the privacy of users (“user” or “you”) of its website at www.entreecap.com and its subdomains (the “site”) and our social media pages such as our LinkedIn, Twitter, Facebook, Instagram, and pages (collectively, “social media”) and and is committed to protect the personal information that our users share with us. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our site and social media. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at (the “Terms of Use”), into which this Privacy Policy is incorporated by reference.
1. Your consent:
By entering, accessing or using the Site and/or by providing personal information to us via our Social Media, you agree to the terms and conditions set forth in this privacy policy (the “privacy policy”), including to the collection and processing of your personal information (as defined below). If you disagree with any term provided herein, you may not access or use the site and you should not provide us with any personal information via social media.
For avoidance of doubt, you hereby consent to the collection, processing, transfer and use of your personal information. you also acknowledge and confirm that you are not required to provide us with your personal information and that such information is voluntarily provided to us.
2. Which information we may collect on our users?
We may collect two types of data and information from our Users:
2.1. Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site. You may access and browse the Site without disclosing personal information, although, like most websites and online services, we passively collect certain Non-Personal Information from your devices when you access and browse our Site, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We also use third-party service providers to obtain detailed analytics on the User’s behavior on the Site. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain technologies such as cookies, as further detailed below.
2.2. Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
2.2.1. Personal Information which is provided consciously and voluntarily:
Communications with Entrée Capital: Personal Information is collected from the details the Users provide as part of any communications with Entrée Capital, by any means, including by e-mail, telephone, Social Media or otherwise. Such Personal Information may include your name and contact details and any other information which you may voluntarily provide to us.
Our newsletter and other commercial materials: you may voluntarily provide us with your contact details in order to subscribe to our newsletter and to receive commercial materials from Entrée Capital, including sending an email to: fay@entreecapital.vc
2.2.2. Personal Information collected via technology:
Identifiers: during your use of the Site, we will access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for statistical and metric purposes.
Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your general location for analytics and security purposes.
Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
2.3. Please note:
We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
We may use third-party tracking services and usage logs, to track and analyze data from Users of the Site and Social Media and for purposes of security and fraud prevention. We may also use cookies and other tracking technologies to gather information regarding your use of the Site and the information for which you searched and accessed.
3. How do we collect information about our users?
There are a few primary methods that we use in order to collect information:
3.1. We collect information through your entry and use of the Site. In other words, when you are using the Site we are aware of it and may gather, collect and store the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
3.2. We collect information which you decide to provide us voluntarily. For example, we collect Personal Information when you communicate with us over the phone, via Social Media, etc.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
4. What is the purpose of the collection of information?
4.1. Non-personal Information is collected in order to:
- Use it for statistical and research purposes and for customization and improvement of our Site and/or Social Media.
- Enhance the User’s experience while using the Site and/or Social Media.
- Keep the Site safe and secured and for prevention of fraud.
4.2. Personal Information is collected in order to:
- Enable the operation of the Site and/or Social Media.
- Respond to your inquiry.
- Ensure that the content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone).
- Send you by email, SMS, phone, through web-browser notification or through the post updates, notices, announcements, and additional information related to Entrée Capital’s products and services.
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes.
- Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
- Keep the Site safe and secured and for prevention of fraud and crime.
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site and/or Social Media.
- Maintain our data processing records and general administrative purposes.
5. Cookies
5.1. When you access or use the Site, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, “Cookies”) which may enable us, amongst others, to recognize your device from those of other Users of the Site, to improve the Site’s performance, to deliver a better and more personalized service according to our Users’ individual interests and the device or browser used, to track Users’ use of the Site, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern, to perform other analytics and to develop our Site.
5.2. Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).
5.3. Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site may be limited.
5.4. For detailed instructions regarding the blocking of Cookies, please refer to your browser’s ‘help’, ‘tool’ or ‘edit’ sections or see https://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.
6. Sharing Information with Third Parties
6.1. Entrée Capital respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.
6.2. In addition to using the information collected by us for the purposes described under Section 4 above, we may also share your information in the following cases:
Service Providers: Note, that we collect, hold and/or manage Personal Information through Entrée Capital’ authorized third parties vendors of certain products or services (such as, cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. For more information regarding our Service Providers, please refer to Section 10.
In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of Entrée Capital, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Entrée Capital, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure.
For avoidance of doubt, Entrée Capital may use Non-personal Information and transfer and disclose it to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of the Site.
7. Deletion or Modification of Personal Information
Entrée Capital acknowledges that applicable law may provide you with certain rights relating to your Personal Information, including the right to access, modify and/or delete Personal Information we collect and process about you. If you wish to access or to correct, amend, or delete Personal Information, please send an email to: fay@entreecapital.vc and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
8. Minors
The Site is intended for Users over the age of sixteen (16). Therefore, Entrée Capital does not intend and does not knowingly collect Personal Information from children under this age. We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the Site. If we learn that we collected Personal Information from minors under the age of sixteen (16) we will delete that information as quickly as possible. Please contact Entrée Capital at fay@entreecapital.vc if you have reasons to suspect that Entrée Capital collected Personal Information from minors under the age of sixteen (16) and we will delete that information as quickly as possible.
9. Security
We take reasonable measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. Entrée Capital SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.
10. Third Party Service Providers
While using the Site we may be using third party service providers, who may collect, store and/or process the Personal Information detailed herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. Entrée Capital uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties’ software or services may include without limitation the following categories of service providers.
11. Links to Third Party Websites
Certain links provided in the Site and Social Media permit Users to leave our Site and/or Social Media and enter non-Entrée Capital sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Entrée Capital and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Entrée Capital reserves the right to terminate any link at any time. You further acknowledge and agree that Entrée Capital shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource.
Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.
12. International Data Transfer
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. Any transfer of data will be in accordance with the safeguards permitted under applicable privacy laws.
13. Direct Marketing
You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future activities and/or products. You may withdraw your consent by sending a written notice to Entrée Capital e-mail address that appears in the Site or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.
14. Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the Site and any information collected therein or via Social Media. Entrée Capital reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an email regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by email, whichever is earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.
15. Have Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send an email to the following address: fay@entreecapital.vc and we will make an effort to reply within a reasonable timeframe.
Last Revised: October 27, 2021
