Privacy Policy

Privacy Notice

Last updated: February 6, 2020

Entocapital.com takes the privacy and security of your personal information very seriously, and we’re committed to protecting and respecting your privacy.

When we use “Entocapital.com”, ‘we’, ‘our’ or ‘us’ throughout this Policy, we’re referring to our corporation Ento Capital Management Ltd. and any one of our entities. Our legal entities are registered in United Arab Emirates and all may act as data controller of your personal information.

Our Privacy Policy explains which personal information we collect from you, how we store it and use it. It also covers how we treat information you give to us, and information we take from third parties. It contains important information about your rights. We hope you read the Policy carefully so you understand and feel comfortable with how we treat your personal information. By engaging with us in the ways set out in this Policy, you confirm that you have read and understood the entirety of this Policy, as it applies to you.

  1. Who we are

This Privacy Policy is provided on behalf of Ento Capital Management Ltd. and our other legal entities.

  1. Collecting your information

We collect and process your information in these circumstances:

  • When you give us your personal information by phone, email, and via our website and via our email marketing website Constantcontact.com, in writing or otherwise. This includes but isn’t limited to information you give us when you register an account, register for email alerts, request literature or signup for newsletters. The information you give us can include your name, address, email address and other contact information. It will also include the information you provide during the KYC verification process, including a copy of your passport, a copy of your identification documents, proof of your address and documents which evidence your source of wealth, in addition to any other documents required by us in order to complete the KYC verification process and other details.
  • When you visit our premises: Because of our security policies and procedures in our office premises, we will collect images of visitors using CCTV footage.
  • When you visit our website: When you visit our websites, we automatically collect information which includes: the Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, your browser and browser plug-in type and version, and your operating system and platform. We also collect information each time you visit for fraud detection and prevention purposes to monitor for potential breaches to your account, and to identify any malicious software that may affect users of our website and services.
  • When we receive your information from third party service providers: We may receive information about you from third party service providers such as credit reference agencies, payment service providers, or analytics providers.

If we don’t receive all of the personal information, we’ve requested from you, then we won’t be able to provide all of our products and services to you.

  1. How we use your information

We use your personal information in the following ways:

  • To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
  • To comply with our legal and regulatory obligations, co-operate with our regulators and law enforcement agencies and to prevent and detect crime.
  • To improve the quality of our services and to train our staff.
  • To let you know about any changes we make to our service.
  • To process any job application you submit, or that an agency submits for you.
  • To tell you (by mail, email, telephone or otherwise) about products and services we think you could be interested in, based on our products you already have or have shown an interest in. You can opt out of this communication at any time.
  • To confirm your identity and address, which may include using automated decisions when we carry out financial crime checks.
  • To request your feedback on our services via a third party we’ve chosen (we’ll only share your name and email address).
  • Gathering data for analysis and research, and to provide management information or other services internally and to third parties.
  • To administer our site and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes.
  • To improve our sites to make sure that our content is as effective as we can for you and for your computer.
  • As part of our efforts to keep our site safe and secure and to prevent and detect money laundering, financial crime and other crime.
  • To monitor, record, store and use any telephone, email or other communication with you. We’ll update your records with any new information you or a third party give us, and we’ll add it to any information we already have.
  • When you call we collect the Calling Line Identification information and keep a copy of the call for training and security purposes. We’ll also use your information to help improve our efficiency and effectiveness.
  • To deal with any enquiries or issues you have about how we collect, store and use your information, or any requests made by you for a copy of the information we hold about you.
  • For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.
  1. Information security

We take the security of your personal data very seriously, and we use appropriate technologies and procedures to protect your personal information.

We review our policies regularly and update them whenever needed to protect you, and to meet our business needs, changes in technology, and regulatory requirements.

Here are examples of the ways we protect your data:

  • We have appropriate technical and organisational measures in place to protect you against accidental loss and unauthorised access, use, destruction or disclosure of your data.
  • We have a business continuity and disaster recovery plan that is designed to help us offer our services and protect our people and assets no matter what happens.
  • We place appropriate restrictions on access to personal information.
  • We implement measures and controls, including monitoring and physical measures, to store and transfer data securely.
  • We complete data protection impact assessments in accordance with legal requirements and our business policies.
  • We provide data security training for our employees.
  • We use a stringent approach to vendor risk management.

The internet is an open medium and we can’t guarantee that any information you send to us by email or via our sites won’t be intercepted or tampered with. Any transmission is at your own risk. To help protect your personal information and minimise the risk of it being intercepted by unauthorised third parties, we have secure servers so that when you submit information to us through our site it is protected. Once we’ve received your information, we use strict procedures and security features to try to prevent unauthorised access.

  1. Our legal basis for using your information

Our legal basis for collecting and using your personal information depends on the exact type of information and how and when we collect it. However, we’ll normally only collect personal information from you or another third party where one of the following applies:

  • we need your personal information to perform a contract with you (for example in connection with your investment;
  • it’s in our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
    • run, grow and develop our business;
    • ensure a safe environment for our staff and website visitors;
    • marketing, market research and business development;
    • provide client services; and,
    • for internal group administrative purposes.
  • we have a legal obligation to collect your personal information (such as for tax reporting or to comply with all regulatory requirements which apply to us).
  1. How and when we share your information

We’ll share your personal information with other members of our group to help us to improve our products and to contact you to tell you about new or improved products and services which we think you could be interested in.

We also share your information with third parties, including sub-contractors including but not limited to payment service providers, our professional advisors such as lawyers, auditors, and insurers, our bank and to service and software providers that help us improve and optimise our sites.

Our reasons for sharing your information with these service providers include to uphold our part of any contract we enter into with them or you and to operate our services.

We will also disclose your information to third parties:

  • where it is in our legitimate interests to do so to run, grow and develop our business:
  • if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • if substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal information: in order to comply with any legal obligation, any lawful request from government, judicial bodies or agencies to make sure we comply with our legal and regulatory obligations; with law enforcement officials; and as may be required to meet national security or law enforcement requirements or prevent illegal activity; to work with fraud prevention agencies, other companies and organisations to prevent or detect financial and other crime.
  • in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.

When we share your information with third parties, we make sure the appropriate safeguards are in place to protect your personal information.

We will never sell, trade, or rent your personal information to anyone.

  1. international data Transfers

We usually store your information on our secure servers in the UAE and Canada.

If you are a resident of the EEA, we may transfer your personal information to be held on our servers in Canada, a country which has been found by the European Commission to provide adequate protection for personal data.  In addition, we may transfer your personal information to be held on our servers in the UAE, which is a country which has not been found by the European Commission to provide adequate protection for personal data. For transfers to the UAE, we take necessary contractual measures to ensure that your personal information receives an adequate level of protection (including, for example, standard contractual clauses). For further information about our international data transfer practices, and to consult the said contractual measures, please contact us using the contact details below.

  1. How long we store your personal information

We keep the personal information we collect from you and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to hold your personal information, we will either delete or anonymise it. If we can’t do this (for example, because your personal information is stored in backup archives), we’ll securely store your personal information, only use it for a purpose we’ve already communicated to you, and isolate it from any further processing until archives are deleted.

  1. Marketing

We may collect and use your personal information for undertaking marketing by email, telephone and post.

We may send you certain direct marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.

You have the right to ask us not to process your personal information for marketing purposes. You can do this by contacting us by post or email using the details in the “Contact Us” section below. You can also unsubscribe from emails by following the unsubscribe instructions included in every email.

  1. Your rights
    • Right of access: You have the right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and (if you are a resident of the EU) details of what safeguards are in place if we transfer your information outside of the European Economic Area.
    • Right of to update your information: If any of the information we hold is inaccurate, you can ask us to make any necessary amendments.
    • Complaints: If you have any complaints or concerns about our handling of your personal information please do get in touch with us and we will do our best to resolve these. contact us.

If you are a resident of the EU you have the right to complain about our collection and use of your personal information to the Information Commissioner’s Office or the data protection authority in the country where you usually live or work.

In certain specific circumstances you also have following further rights:

  • Right of deletion: You have a right to ask us to delete any personal information which we are holding about you.
  • Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information.
  • Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.
  • Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
  • Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request, unless we tell you we are entitled to a longer period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Please contact us at using the details below if you would like further information or if you would like to exercise any of your rights you can contact us using the details below.

  1. Using our website

This Policy applies when you use our website and its content.

If you visit our website you acknowledge that the practices described in this Policy apply. Our sites can, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please remember that they have their own policies and that we do not accept any responsibility or liability for their policies or how they collect and use your information.

Our websites let you share via third party social media applications, such as Facebook and Twitter. These social media apps can collect and use information about how you use our site. Social media companies can collect and use any personal information that you provide via social media apps according to their own privacy policies, and you should read these carefully before you submit any personal information to our website. We don’t have control over, or responsibility for, those companies or how they use your information.

  1. Children

We do not and will not knowingly collect information from any unsupervised child under the age of 13. If you are under the age of 13, you may not use our sites unless your parent or guardian has provided us with their consent for your use of our sites or our site (as applicable).

  1. Cookies

When you access our website or content, we or companies we work with may place small data files called cookies on your computer or other device. We use these technologies to:

  • Recognize you as an account holder;
  • Customize our website, content, and advertising;
  • Measure promotional effectiveness; and
  • Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.

We also use local shared objects, commonly referred to as “Flash cookies,” to help ensure that your account security is not compromised, to spot irregularities in behaviour to help prevent fraud, and to support our sites and services.

We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of the website. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.

  1. Updating this Privacy Policy

We will update or amend this Policy from time to time, to comply with law or to meet our changing business requirements. You can see when our most recent update to this Privacy Policy was by checking the “Last updated” note at the top of this Privacy Policy. If we need to make substantial changes to this Policy, we will notify you, if we hold your contact details, by post or by email, before we make any changes unless we are required to make the change sooner (for example regulatory reasons).

  1. Contacting us

If you have any questions about your privacy with us or this Policy, you can email us, write to us or call us at admin@entocapital.com.