Privacy Policy

ENTENDRE 

PRIVACY NOTICE

Last Updated: [5/1/2023]

Welcome! We are Entendre Finance, a Web3 accounting platform for businesses’ on-chain activity. This Privacy Notice explains how Entendre Finance, Inc. (“Entendre“, “we“, “us“or “our“) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites, including https://entendre.finance (the “Site“) and other websites we own and operate that link to this Privacy Notice, the mobile application (the “App“), and the related content, platform, services, products, and other functionality offered on or through our online services, including our web3 operating system (collectively, the“Services“). It does not address our privacy practices relating to Entendre employees and other personnel.

Data privacy laws sometimes differentiate between “controllers“ and “processors“ of personal information. A “controller“ determines the purposes and means (i.e., the why and how) of processing personal information. A “processor“, which is sometimes referred to as a “service provider,“ on the other hand, processes personal information on behalf of a controller and is subject to the controller’s instructions and corresponding contractual restrictions. Entendre acts as the controller of Personal Information for the data processing activities described in this Privacy Notice, unless otherwise noted. This Privacy Notice does not generally apply to the company’s processing activities in its capacity as a processor or service provider. 

What is Personal Information?

When we use the term “personal information“ in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Our Collection of Personal Information

We collect personal information in connection with your visits to and use of the Services. This collection includes information that you provide in connection with the Services, information from third parties, and information that is collected automatically such as through the use of cookies and other technologies.

Blockchain Participants: Please note that by virtue of the public nature of the blockchain, including the Ethereum Blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain securitized tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please review how privacy and transparency on the blockchain works.

Personal Information Collected from Individuals

We may collect the following personal information submitted to us by individuals through the Services:

Contact Information , including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

Account Information , including first and last name, company name, employer, job title, business email address, user ID and password, company crypto wallets, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. Plaid’s use of your personal information is governed by their privacy policy, which is available here: https://plaid.com/legal/#end-user-privacy-policy.

Payment Information . If you sign up for one of our Services requiring payment (i.e., subscription), we collect the information provided in connection with such payment. Depending on your subscription type, you may be able to pay via credit card, or cryptocurrency and we may collect the financial information associated with such payment (e.g., routing and account number, wire transfer information details). Please note that we use third party payment processors, including Ayden, Paypal, and Stripe, to process payments made to us. As such, we do not retain any personally identifiable financial information in connection with payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. To view Stripe’s privacy policy, please click here. 

Inquiry and Communications Information , including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.

Newsletter and Marketing Emails Information , including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you.  If you wish to stop receiving email messages from us, simply click the “unsubscribe link“ provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Feedback Information .  We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.

Business Representative Contact Information . If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g. email, phone, address), job title, and any other information related to the performance of the agreement with us. 

Employment Application Information , including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services) and location data (such as general geographic location based on the log data we or our third-party providers collect). 

To manage cookies, an individual may change their browser settings to:

1. notify them when they receive a cookie, so the individual can choose whether or not to accept it;
2. disable existing cookies; or
3. automatically reject cookies.

Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it. 

For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Data Collection and Online Advertising section of this Privacy Notice.

Personal Information from Third Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, we may receive your information if you are added as a user to a business account. If you engage in one of our communications hosted on third-party platforms, such as Twitter or Discord, we will also be able to see any public communications made within that platform. 

Social Media: When an individual interacts with our Services through various social media networks, such as when someone follows us or shares our content on Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services and our marketing activities.

Service Providers: Our service providers that perform services solely on our behalf, such as communications and marketing providers, blockchain analytics providers, and crypto subledgers, collect personal information and often share some or all of this information with us. 

Information we receive from authentication services you connect to our Services: Some parts of our Services may allow you to login through a third party social network or authentication service such as Google, Apple or Microsoft. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, and profile picture, as well as information about your organization, such as such as company name and logo. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Services.  We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices). 

Information We Receive from Third-Party Platforms/Services You Connect to Our Services.  We may receive personal information about you or information about your business from third parties and combine that with information we collect through our Services.  For example, if you choose to connect your business account to a third-party service, such as QuickBooks, Xero, Workday, Coinbase, or Kraken, we may collect information about you and your business, including your profile information, information about your end users, transaction-related information, company financial data such as chart of accounts, and any other information collected by the platform.  The data we receive from third-party sites is dependent upon the third party’s policies and your privacy settings on that third-party site.  You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Services.  

Information from Other Sources: We may also collect information about individuals that we do not otherwise have from, for example, publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, or through transactions such as mergers and acquisitions. Such information may include contact information, social media account information, general location, domains, cryptocurrency wallet address and related information, the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information (including cryptocurrency assets), and interest-in-services information, employment-related information, and interest-in-services information. We may combine this information with the information we collect from an individual directly. 

Third Parties Related to Employment Applications: If you apply for a job with Entendre, we may receive information from your current or past employers, recruiters, third-party social media platforms and other third parties we use to obtain information about job applicants.

Our Use of Personal Information

We may use personal information we collect to: 

1. Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations and to deliver the Services you have requested;
2. Verify your identity and entitlement to products or Services, when you contact us or access our Services;
3. Manage our business and its day-to-day operations; 
4. Communicate with individuals, including via email, chat, phone, video call, text message and social media;
5. For marketing and advertising purposes, including to market to you or offer you through email, direct mail, and updates on products or services we think that you may be interested in;
6. Test, enhance, update and monitor the Services, or diagnose or fix technology problems, including without limitation to improve our machine learning models;
7. Facilitate customer benefits and services, including customer support; 
8. Identify and analyze how individuals use our Services;
9. Conduct research and analytics on our customer and user base and our Services;  
10. Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
11. Help maintain the safety, security and integrity of our property and Services, technology assets and business;
12. Evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process, if you are applying for employment.
13. To fulfill or enforce our legal or contractual obligations and requirements (including in relation to our      Terms of Service), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
14. Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
15. For any other lawful purpose, or other purpose that you consent to or for which you provide your information.  Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries.

We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time. 

Our Disclosure of Personal Information

We disclose personal information in the following ways: 

1. Affiliates: We may share personal information with other companies owned or controlled by Entendre, and other companies owned by or under common ownership as Entendre , which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
2. Blockchain Participants: If you participate in our Services, by virtue of the public nature of the blockchain, the holdings and transactions associated with your wallet ID will be publicly available and accessible to blockchain participants and other third parties, as well as any other information you choose to provide or make public.
3. Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available. 
4. Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries. 
5. Other Service Providers:  In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, crypto subledger services, employment application-related services, payment processing services, and administrative services. 
6. Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the section Third Party Data Collection and Online Advertising for more information.
7. Business Partners:  From time to time, we may share personal information with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to train their machine learning models.
8. Other Users: In certain instances, we may share your information with other users in order to facilitate the Services. For example, if you submit a proposal, we may share your proposal publicly and feature the proposal on our site.
9. Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.  
10. Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement: 
    1. (i) in connection with the establishment, exercise, or defense of legal claims; 
    2. (ii) to comply with laws or to respond to lawful requests and legal process; 
    3. (iii) to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    4. (iv) to detect, suppress, or prevent fraud; 
    5. (v) to protect the health and safety of us and others; or 
    6. (vi) as otherwise required by applicable law.

With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications. 

Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see Online Ads of the Control Over Your Information section below, to learn how you can opt out of interest-based advertising.

We may engage in the following: 

1. Social Media Widgets and Advertising.  Our Services may include social media features, such as the Twitter, Discord, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
2. Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. 
3. Third Party Partners.  We work with a variety of third-party partners to provide advertising services. For example, we may utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at  https://google.com/ads/preferences, or by visiting NAI’s online resources at  http://www.networkadvertising.org/choices.

For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below. 

Control Over Your Information

You may control your information in the following ways:

Email Communications Preferences.  You can stop receiving promotional email communications from us by clicking on the “unsubscribe“ link provided in such communications or by adjusting your communication preferences in your account settings.  You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

Cookies: To manage cookies, an individual may change their browser settings to:

1. notify them when they receive a cookie, so the individual can choose whether or not to accept it;
2. disable existing cookies; or
3. automatically reject cookies.

Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it. 

Modifying Account Information. If you have an account for our Services, you have the ability to modify certain information in your account, including your contact information and billing and invoicing information as well as user roles within the account. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at help@entendre.finance. We may not be able to modify or delete your information in all circumstances, especially in relation to information on the blockchain. 

Access to Your Device Information. You may control the Services’ access to your device information through your “Settings“ app on your device.  For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.

Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu. 

SMS Text Messaging. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from Entendre directly relating to your use of the Services, such as for account login (e.g. we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Service.

Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices  or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking“ (iOS) or “opt-out of interest-based ads“ (Android).  You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. 

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services.  It means that the online ads that you do see from DAA program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices. 

State-Specific Disclosures

California - Your California Privacy Rights: If you are a California resident, California Civil Code Section 1798.83 – also known as California’s “Shine the Light“ – permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. We do not share your personal information with third parties for their own direct marketing purposes.  

Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@entendre.finance with the subject line “Nevada Opt Out Request“ to submit such a request.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@entendre.finance.