What Types Of Personal Information Do We Collect?
We may collect information about you through the Website as described below:
How Do We Collect this Information?
In addition, we may receive personal information about you from third parties, such as:
How Do We Collect this Information?
We may use aggregate information to measure general Website usage patterns and characteristics of our user base, and we may include such aggregate information about our user base in reports to our commercial vendors. We may also disclose aggregated user statistics (for example, a certain percentage of our users live in a certain area) without your permission in order to describe our audience to other third parties. However, this aggregate information does not reference names, phone numbers, e-mail addresses, or other personal information, and it is not traceable to a specific recipient or user e-mail address.
With Whom Will We Share Your Information?
We have policies that limit access to your personal information to only those people who need it to perform their jobs and provide services to you, and we have physical, electronic and procedural safeguards that comply with applicable laws to protect your information from unauthorized access.
We may disclose the information we collect to third parties that assist us in providing financial services to you, which include, as applicable, the relevant fund’s administrator, distributors, brokers and custodians. From time to time, we disclose your information to persons or entities whom we have asked to assist us to operate our business or provide services to you (“Service Providers“). For example, we may contract with Service Providers to provide certain services including without limitation data management, web hosting, web development, and analytics tools. We provide our Service Providers with the information needed for them to perform these services. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of your information in order to protect your personal information from unauthorized access, destruction, use, modification, or disclosure and in accordance with applicable laws. We may also disclose information with other non-affiliated third parties who perform services on our behalf or who assist us in providing services to you, such as attorneys and accountants, and as otherwise permitted by law. These third parties may be based in countries outside the European Economic Area (”EEA”) which may not offer the same level of protection of the information transmitted.
We also may share personal information with entities controlling, controlled by, or under common control with EnTrust Global. In the event that EnTrust Global is merged, or in the event of a proposed or actual transfer of the business or assets associated with the Website, we may disclose or transfer your personal information and non-personal information in connection for such transaction to the acquirer of the assets, including for due diligence purposes and to complete the transaction.
In certain instances, we may disclose your personal information when we have reason to believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to EnTrust Global or its affiliates, or to others. We may also disclose your personal information when we believe the law or legal process requires such disclosure, to cooperate with regulators or law enforcement authorities, or to protect our rights.
We use various technologies to collect other types of information, including personal information, automatically. The use of your personal information submitted through the Website is necessary for our legitimate business interest in the proper administration of our Website and business and monitoring and improving our Website and services. For example, in order to measure the usefulness and efficiency of our Website pages, we automatically track certain information from all visitors to our Website. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information. We will retain your personal data for as long as you use our Website and for a minimum period of seven years thereafter.
EnTrust Global also uses analytics providers, such as Google Analytics to help EnTrust Global evaluate the Website. To opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.
Data Storage and Retention
Your personal information will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. EnTrust Global reserves the right to retain and use your personal information for as long as necessary to comply with its and its affiliates’ legal obligations and business requirements and/or to resolve ongoing disputes and enforce its and its affiliates’ agreements.
Transfers of Personal Information
Your personal information may be transferred, processed and/or stored in a country other than the one in which your personal information is collected. When transferring your personal information to the United States or other countries, EnTrust Global has implemented procedures to ensure that appropriate safeguards are in place to protect the personal information regardless of where it is being transferred.
We use encryption and authentication tools to protect the security of personal information that you share with us. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect personal information, we cannot and do not guarantee or warrant the security of any information you transmit to or from the Website, and you do so at your own risk.
Links To Third-Party Websites
GDPR (implemented across all European Union member states from 25 May 2018) applies to the collection, processing and storage of personal data undertake by organisations within the European Economic Area (EEA), as well as to firms outside the EEA that handle personal data relating to individuals in the EEA.
The GDPR has two key purposes: (a) to set guidelines for the collection, processing and protection of personal data and (b) to give individuals certain rights in relation to their personal data (such as to access and correct it and object to further processing).
You may exercise the following rights by contacting your usual EnTrust Global representative:
You also have the right to make a complaint at any time to data protection regulator.
If you do not provide us with certain information when requested, your use of the website may be limited.
Personal Information Rights for California Residents
The California Consumer Privacy Act (as amended, restated, modified and/or supplemented from time to time, including pursuant to the California Privacy Rights Act, the, “CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their personal information. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what EnTrust Global will do in response.
Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).
If you are an individual who resides in California and whose personal information is collected and processed by EnTrust Global, you may have the right to:
Non-Discrimination for Exercising Your Personal Information Rights
Questions or Concerns and Exercising Your Data Subject Rights
If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal information EnTrust Global currently has about you. For example, EnTrust Global may require identifying documents such as passport, utility bill or drivers license.
You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact Bruce Kahne at the email address or phone number provided above.