Entoro Insurance Services privacy policy

1.    Summary
‍1.1.   This privacy policy (the "Privacy Policy") explains what personal information Entoro Insurance Services, LLC and its affiliates and subsidiaries (collectively referred to as "Entoro Insurance Services," "we," "us," or "our") collects, uses, discloses and stores. This Privacy Policy may be supplemented or replaced by additional privacy statements or terms provided to you.  

2.    Scope
‍2.1.  This Privacy Policy provides you with guidance on your rights and obligations in relation to your personal information.
2.2.  This Privacy Policy applies to all personal information collected by Entoro Insurance Services when providing our services to you, including without limitation, by way of our website https://entoro-insurance.com (the "Entoro Insurance Services Website").
2.3.  This Privacy Policy establishes and communicates the key principles that Entoro Insurance Services follows in protecting the personal information that we collect.
2.4.  This Privacy Policy only applies to information that is collected by Entoro Insurance Services; it does not apply to any information collected by other Entoro Insurance Services Website users, such as through email communications between you and another user. Entoro Insurance Services does not guarantee the privacy or security of the personal information you provide to others.

3.    Policy Modification
‍3.1.  Entoro Insurance Services reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.
3.2.  If we make material changes to our Privacy Policy, we will take reasonable steps to notify you prior to the changes taking effect, such as by posting a notice on the Entoro Insurance Services Website or sending you a notification via email.
3.3.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. Each time you access the Entoro Insurance Services Website, the current version of the Privacy Policy will govern your use. The effective date of the latest version of our Privacy Policy is provided in the header of this Privacy Policy.

4.    Collection of Personal Information
‍4.1.  Entoro Insurance Services collects personal information that you submit to the Entoro Insurance Services Website, including personal details required to open an account to access certain portions of the Entoro Insurance Services Website. The type of personal information we collect depends on your relationship with us and the services we deliver to you. Such personal information may include:
4.1.1.    Name and contact details, such as, first and last name, email address, postal address, telephone number,
4.1.2.    Work-related information, such as, company name and affiliation, job title, work email address and contact information, and other employment or education information,
4.1.3.    Account credentials, such as passwords and other security information for authentication and access,
4.1.4.    Financial information, such as, bank account, credit and debit card numbers for processing of payments, and tax identifiers such as VAT number (if applicable),
4.1.5.    Marketing preferences,
4.1.6.    Usage information, such as transactional details and other behavioral information about how you navigate within the Entoro Insurance Services Website and which elements of the Entoro Insurance Services Website and our services you use the most and information regarding the services you wish to obtain,
4.1.7.    Computer, device and connection information, such as IP address, browser type, version and location, and
4.1.8.    Any other information you voluntarily submit in communications with Entoro Insurance Services.
4.2.  Entoro Insurance Services also carries out background checks on its prospective users, which involves processing personal information about the prospective user and certain individuals connected to the prospective users (such as a board member or an owner of a controlling interest in the business) when we onboard them or their business. To carry out these checks and to onboard certain prospective users, we primarily collect the following types of personal information:
4.2.1.    Business information, specifically business telephone number (landline and mobile) and email address, job title, the company name or business trading name, proof of authority for individuals to open a Entoro Insurance Services account on behalf of the organization, and business/operational address.
4.2.2.    Identification information related to individuals:
4.2.2.1.        Physical address,
4.2.2.2.        Government issued identification card,
4.2.2.3.        Government issued identifier,
4.2.2.4.        Date of birth,
4.2.2.5.        Photograph, and
4.2.2.6.        Bank account number.
4.3.  If Entoro Insurance Services is not provided with all requested personal information, Entoro Insurance Services may be unable to register an account holder, provide the requested Entoro Insurance services, information or otherwise respond fully to a request.

5.    Method of Collection
‍5.1.  We may collect personal information from the following sources:
5.1.1.    Direct interaction, such as when you open an account on any part of the Entoro Insurance Services Website or upload information on your profile when logged into your account,
5.1.2.    Data from third parties, such as information on third-party websites or other information you may have made publicly available, or information provided by third party sources, including but not limited to government entities and data resellers,
5.1.3.    Automated tracking technologies, such as information automatically collected about your interaction with the Entoro Insurance Services Website and our services using various technologies such as cookies, web logs and beacons and internet tags.
5.2.  In some cases, Entoro Insurance Services may collect personal information from someone other than the individual concerned (e.g., from the person opening the account holder's account). If you provide to Entoro Insurance Services personal information about another person, Entoro Insurance Services is relying on you having addressed all relevant consents, notifications and other requirements to enable Entoro Insurance Services to process the personal information for Entoro Insurance Services' purpose of collection.

6.    CookiePolicy
‍6.1.  We use cookies, web logs and beacons, internet tags and other technologies to optimize the Entoro Insurance Services Websites and analyze website traffic. Where required by applicable law, if we have obtained your informed consent in advance, we may use third party cookies, notably social media plugins, to enable you to share ideas and information related to us instantly and for our own marketing purposes.
6.2.  Cookies or similar technologies, including web beacons described below, (referred to collectively as "Cookies") are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and making it more user-friendly. Third party Cookies may collect information to analyze personal browsing behavior. Web beacons/pixels or internet tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device, web beacons are embedded invisibly on web and app pages. We may use web beacons in connection with the Entoro Insurance Services Website to, among other things, track the activities of Entoro Insurance Services Website visitors and users, help us manage content, and compile statistics about usage of the Entoro Insurance Services Website. We and our service providers also use web beacons in emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
6.3.  We may use Cookies belonging to one of the four categories listed below.
6.3.1.    NecessaryCookies - these mandatory Cookies are needed for the Entoro Insurance Services Website to function properly.
6.3.2.    FunctionalCookies - these Cookies add additional functionality to the Entoro Insurance Services Website.
6.3.3.    PerformanceCookies - these Cookies support analytic services that help us to improve the Entoro Insurance Services Website’s functionality and user experience.
6.3.4.    InterestCookies - these Cookies can be applied to collect insights, to issue personalized content and advertising on the Entoro Insurance Services Website and other websites. Users may opt out of many Interest Cookies. For example, you may goto the Digital Advertising Alliance ("DAA") ConsumerChoice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies’Interest Cookies listed on the DAA ConsumerChoice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites or online services. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
6.4.  If you do not wish to receive anyCookies, you may set your browser to refuse Cookies, but this may affect your ability to take full advantage of the services and resources on the Entoro Insurance Services Website.
6.5.  We use Cookies, automated devices and applications, such as Google Analytics, to evaluate usage of the Entoro Insurance Services Website. We use these tools to help us improve the Entoro Insurance Services Website's performance and user experiences. These entities may use Cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
6.6.  Currently, our systems do not recognize browser "do-not-track" requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling Cookies).

7.     Our Use of Personal Information
‍7.1.  The principal purpose of the collection your personal information is to offer you an optimum, efficient and personalized experience. The personal information collected is used for the purposes for which you have provided it and might be further used as described in this Privacy Policy, for statutory or other legitimate purposes only. Entoro Insurance Services uses personal information for the following purposes, as permitted by applicable law:
7.1.1.     To provide our services or the Entoro Insurance Services Website’s functionality to you and to provide related activities, such as registering you for use of limited-access portions of the Entoro Insurance Services Website, arranging access to your registered account, and providing you with related benefits or customer service.
7.1.2.     To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about the Entoro Insurance Services Website or our services.
7.1.3.     To complete your transactions, verify your information, and provide you with related benefits or customer service.
7.1.4.     To send administrative information to you, such as changes to our terms, conditions, and policies.
7.1.5.     To manage and perform our contractual relationship with you and/or comply with a legal obligation.
7.1.6.     To administer, maintain and improve the Entoro Insurance Services Website, and to improve our services, offerings and resources,
7.1.7.     To issue, conduct, compile, manage and analyze reports, questionnaires and surveys, and to produce reports and/or ratings based on responses,
7.1.8.     To analyze personal information for business reporting and providing personalized services.
7.1.9.     To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information, content and/or offers tailored to your interests.
7.1.10. To comply with a legal obligation to which we are subject, 
7.1.11. To verify that our internal processes function as intended in connection with auditing purposes, and to address legal, regulatory, or contractual requirements,
7.1.12. To create aggregated, pseudonymized or de-identified data sets. We may use such data sets for any purpose, including product improvement and development, marketing, advertising, trend analysis and other purposes;
7.1.13. To prevent and monitor fraud and abuse, to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or property, or violations of this Privacy Policy, your customer agreement, or any applicable terms of use/service; for example, to detect and prevent cyberattacks or attempts to commit identity theft or money laundering and to check your authority to represent your company and your and your company's qualifications to make use of services available on the Entoro Insurance Services Website,
7.1.14. For other business administration purposes, including authenticating your identity, maintaining our records, to monitor your compliance with your agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or ‎‎merger, as described below; and
7.1.15. For other purposes with your consent or where permitted or required by applicable law.

8.     Disclosure of Personal Information 
‍8.1.  Entoro Insurance Services will share personal information with:
8.1.1.     Our affiliates or subsidiaries for the purposes described in this Privacy Policy.
8.1.2.     Service providers and business partners under contract with Entoro Insurance Services to help with our business operations and to facilitate services they provide to us.
8.1.3.     Parties assisting Entoro Insurance Services in providing you with our services and the Entoro Insurance Services Website, or otherwise to improve our services or the Entoro Insurance Services Website. 
8.1.4.     Other users of the Entoro Insurance Services Website as necessary to provide our services or the Entoro Insurance Services Website to you or to administer a transaction requested by you.
8.2.  Entoro Insurance Services may also share personal information in connection with a sale or transaction involving all or a portion of the business to representatives of a prospective purchaser, and where required by applicable law.
8.3.  We may also share and disclose de-identified, pseudonymized, or aggregated information for the purposes of research and promotional activities. For example, we may disclose aggregated data from Entoro Insurance Services Website visitor or activity reports, event registrations, completed reports, questionnaires and surveys, and make such data available on the Entoro Insurance Services Website or through other mediums.
8.4.  Entoro Insurance Services may also disclose personal information with your consent or where permitted or required by law.
8.5.  There may also be instances when Entoro Insurance Services will disclose your personal information to:
8.5.1.     Honor a request that you have made to Entoro Insurance Services or through the Entoro Insurance Services Website.
8.5.2.     Comply with the law or in response to a court order, government request, or other legal process (this may include laws outside of your country of residence).
8.5.3.     Protect the interests, rights, safety, or property of Entoro Insurance Services or others.
8.5.4.     Protect against fraud, money laundering or for risk management purposes.
8.5.5.     Respond to adverse third parties (i.e., adverse parties and their counsel and other agents) in the context of litigation.
8.6.  Entoro Insurance Services requires any unaffiliated third parties to treat personal information as confidential. Entoro Insurance Services will not provide personal information to third parties for their own marketing purposes without your consent.

9.     Storage and Security of Personal Information 
‍9.1.  We seek to use reasonable organizational, technical and administrative measures designed to protect personal information within our organization. We require our employees and data processors to respect the confidentiality of any personal information held by Entoro Insurance Services.
9.2.  Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services or the Entoro Insurance Services Website you understand that your information will be transferred to countries outside of your country of residence which may have data protection rules that are different from those of your country. 
9.3.  The criteria Entoro Insurance Services use to determine our retention periods include.
9.3.1.     The length of time we have an ongoing relationship with you and provide our services or the Entoro Insurance Services Website to you (for example, for as long as you have an account with us or keep using the Entoro Insurance Services Website or our services);
9.3.2.     Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
9.3.3.     Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

10.    How You Can Access or Change Your Personal Information
‍10.1.    Please take care to ensure details provided to us are kept up to date. Where we provide functionality on the Entoro Insurance Services Website to update or change details, please use that functionality. 
10.2.    Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion) and/or as otherwise permitted by applicable law.

11.     Withdrawal of Consent
‍11.1.     To withdraw any consent provided for us to process personal information, please contact us using the details in the "Contact Us" section below. If consent is withdrawn it may have consequences such as we may no longer be able to provide certain services or communications, or you may not be able to continue accessing certain portions of the Entoro Insurance Services Website. Even if consent is withdrawn, we may still process personal information where permitted or required under law. Please include sufficient details so we can understand the nature of your request. We may need to request personal information in order to verify your identity.

12.     Links to Other Websites
‍12.1.     Entoro Insurance Services provides, through the Entoro Insurance Services Website, access to third-party websites where content is not controlled by Entoro Insurance Services. If you disclose your information to such third-party websites, different rules may apply to their use or disclosure of your personal information. Entoro Insurance Services does not guarantee the privacy or security of the personal information you provide to others. We therefore encourage you to evaluate the privacy and security policies of the other user before sharing your information. You should also review the privacy statements of websites that have links within the Entoro Insurance Services Website to which you choose to navigate so that you understand how those websites collect, use and share your information. Entoro Insurance Services is not responsible for the privacy statements or other content on websites outside of the control of Entoro Insurance Services.

13.    Contact Us
13.1.  If you have a concern or complaint about our processing of your personal information including about our compliance with applicable data protection laws, please contact us. We can be contacted in connection with privacy matters including as contemplated by this Entoro Insurance Services Privacy Policy as follows: Attention: Data Protection Officer Entoro Insurance Services, LLC. 720 N Post Oak Road, Suite 400, Houston, TX 77024 info@entoro-insurance.com
13.2.  We will consider and promptly respond to the issues raised. Please include sufficient details so we can understand the nature of your concern. We may need to request personal information in order to verify your identity.