Last Updated May 9, 2019
Entoro Capital, LLC, and its affiliates, which include Entoro Securities, LLC and OfferBoard, LLC have adopted and implemented this privacy policy as part of our commitment to protecting your personal information from misuse. We encourage you to read this Policy to learn more about the ways we collect, use, disclose, and protect the information we gather from this web site. If you are not comfortable with any of the practices or policies described in this Policy, we ask that you discontinue use of our Site. Please be aware that we may periodically update or revise this Policy without notice. Accordingly, please check this Policy frequently for changes. Please note that information gathered in connection with any services provided via the Site may be governed by separate terms. In the event that you receive such services, you agree that those other terms shall supersede any conflicting terms contained in this Policy.
Please note that information gathered in connection with any services provided via the Site may be governed by separate terms. In the event that you receive such services, you agree that those other terms shall supersede any conflicting terms contained in this Policy.
In order to better serve your particular needs, the Company (and third parties working on the Company's behalf) may collect information from you while visiting our Site. Some of this information is collected automatically through various methods including, but not limited to cookies. The Company may also obtain information directly from you and, depending upon the nature of transactions you may conduct, from third party sources.
We may also collect anonymous information, which does not personally identify you, when you visit our Site. The anonymous information includes the pages you view on our Site, the search terms you enter into our search utility, your IP address and the operating system, browser software and Internet service provider you use.
We may use the standard "cookie" feature of major browser applications and other data capture mechanisms that allow us to store data about your visit. Cookies help us learn which areas of our site are useful and which areas need improvement. You may configure your browser to prevent cookies from being set on your computer. If you do so, you may still view most of the Site, although you may not be able to enjoy all of our services.
Information We May Collect: We collect certain information directly from you, required by regulatory authorities and certain information required for performing our services. We do this to help identify you as a client, provide our services, and tell you about products or services you may want. The information we collect may include: (a) Identity information – such as your name, legal entity, Tax ID number, Social Security number, address and officers; (b) Information from third parties – we may also collect information from consumer reporting agencies such as verifying your identity through public records.
The information that is collected from you is within the guidelines and regulations of the USA Patriot Act of 2001, which requires the Company to obtain, verify and record information that identifies its clients and their affiliates.
How We Treat Your Information: While providing acquisition & divestiture services, as well as other offerings and services offered by the Company, we may share certain information described above with companies or investors in the ordinary course of providing our services. The sharing of this information will be subject to the confidentiality and sharing provisions as set forth in our engagement letter with you. We may provide information to regulatory authorities and law enforcement officials in accordance with applicable law or to others when we believe in good faith that the law requires it. In the event of a sale of all or part of our business, we may share customer information related to that business as part of the transaction. We do not sell or share your information with marketers who may want to offer you their own products and services. Neither do we share information we receive about you from a consumer-reporting agency. You do not need to take any action for this benefit.
Securing Your Information: Keeping your information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect your information. Employees and agents are authorized to access your information only when they need it to provide you with products and services or to maintain your accounts.
All securities transactions are processed through Entoro Securities, LLC, a member of FINRA/SIPC. As required by Federal law or regulation, we must: (a) Obtain a copy of the certificate of incorporation, partnership agreement, or other document evidencing the establishment of the entity; and (b) Verify that a client, prospective client or investor and the principal officers of such client or investor do not appear on a list provided to us by the government, such as the Treasury Department OFAC “Specifically Designated Nationals and Blocked Persons” List (SDN List) and is not from, or engaging in transactions with people or entities from, embargoed countries and regions listed on the OFAC website.
The Site is not intended for children under eighteen (18) years of age. The Company does not market any products or services to children under eighteen (18) years of age or knowingly collect any information from children under eighteen (18) years of age.
In order to better serve your particular needs, the Company and certain companies and individuals working on the Company's behalf will have access to all or a portion of the various types of Site visitor information we may collect. When we share access to personal information with companies or individuals working on the Company's behalf, we generally endeavor to protect such personal information by requiring those parties to enter into an agreement with the Company to safeguard the confidentiality of personal information. We may also disclose information about the use of our Site in aggregate, statistical form.
As permitted by law, the information we collect, including personally identifiable information, may also be disclosed to third parties if the Company, in its sole discretion, believes disclosure is necessary to comply with legal or regulatory processes or requests or to protect the rights, property, or personal safety of the Company, its affiliates, and/or the respective customers, members, directors, officers, employees, agents, and representatives of the Company and its affiliates; other Site users; and/or the public.
An email received by a recipient is not a solicitation. Any offering securities is a private placement transaction without registration with the U.S. Securities and Exchange Commission of any other securities’ regulatory authority. As a consequence, transfer of the stock may be restricted by applicable securities laws, depending on the investor’s jurisdiction. There may be no current public market for trading in the stock and there are no assurances that a liquid secondary market will develop for trading the securities. Except for the drag-along rights, and as otherwise required by applicable securities laws, there are no current restrictions on transfer of the securities.
We use a secure server and security protocol to safeguard information we collect from you. To help ensure the security of your personal and financial information that you submit to us via our Site (other than via an e-mail message), we use security software to encrypt the information before and during its transmission through the Internet. We allow information to be submitted for transmission only if your browser is compatible with our security software. If your browser is not compatible, you will receive a message indicating your transaction cannot be completed because of the security risk.
E-mail messages are not secure. Our security software does not encrypt e-mail messages. Please keep in mind that transmitting information via the Internet is never completely secure and that, therefore, any information submitted may be intercepted, viewed, collected, used, altered, copied or disclosed by others. We are not responsible for the security or confidentiality of communications you send to us (or that we send to you) through the Internet using e-mail messages.
We take seriously the issue of safeguarding your privacy online. However, please note that you should exercise discretion with respect to the submission of any personal or financial information.
This Site contains links to Web sites of third parties. Please note that when you click on one of these links, you will be accessing a website the Company does not control and which may be governed by privacy policies and practices that differ from ours. The Company is not, and will not be, responsible for the privacy policies or practices of third parties or the content or security of any third-party Web sites. These links are provided solely as a convenience to you and not an endorsement by the Company of the contents of such third-party Sites or resources. The Company is not, and shall not be held responsible for the legality, timeliness, accuracy, completeness or appropriate nature of any information, data or other content, advertising, offerings, products, or services located on or through any other third-party Sites or resources, or any loss suffered by you. If you decide to access a linked Site, you do so at your own risk.
Any information you submit to us via our online forms or via e-mail is provided on a voluntary basis. When you access our Site, the collection, use, and distribution of your information will be handled according to the terms and policies outlined in this Privacy Policy, unless superseded by the appropriate Other Terms (as discussed above). By using this Site, you consent to collection and use of your information as described in this Policy, including personally identifiable information the Company may collect. If you object to any of the policies outlined in this Policy, we ask that you do not submit information to the Company or access our Site. We may update or modify this Policy at any time. Any such updates or modifications will be effective upon posting on this Site, and your continued use of the Site will constitute your consent to any updated or modified Privacy Policy.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The company aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Entoro relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
In the event of a significant business disruption, either internal or external, Entoro Capital, LLC (“the Company”) and its affiliates, plan to respond in a timely fashion and resume business operations by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our company’s business continuity plan is designed to permit us to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
The Business Continuity Plan Addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Significant Business Disruptions: The Company’s plan takes into account two kinds of Significant Business Disruptions, internal and external. Internal significant business disruptions affect only the Company’s ability to communicate and do business, such as a fire or loss of electrical power in the office or building. External significant business disruptions prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes a wide-scale, regional disruption in essential services.
Internal Significant Business Disruptions: In the event of a disruption in the Company’s business operations due to an internal significant business disruption, the Company will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location. If personnel or operations must be moved to an alternate location, the Company anticipates that it will resume regular operations as soon as possible.
External Significant Business Disruptions: In the event of a disruption in the Company’s business operations due to an external significant business disruption, the Company will attempt to continue to conduct business as usual by moving its operations to an alternative location outside the affected area, if possible, or by providing customers with alternative communication arrangements, as indicated below, to conduct business. The Company will attempt to resume business within 24 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances.
In all cases, the Company will resume normal business operations as soon as it is able to do so based on the type and the extent of the disrupting event.
Communications: In the event you are unable to reach the Company at our main number, please proceed as follows:
Contact information: Any questions regarding the Company’s Business Continuity Plans should be addressed to: James C. Row, Entoro Capital, LLC, at 720 N Post Oak Road, Suite 400, Houston, TX 77024.
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