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.
1. Your consent:
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: firstname.lastname@example.org
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.
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.
5.1. 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.
5.3. 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 http://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
6.2. 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.
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: email@example.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
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 firstname.lastname@example.org 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.
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
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.
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.
15. Have Questions?
Last Revised: October 27, 2021