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Echelon Operating, LLC, together with its affiliates and funds (“Echelon”, “us”, “our” or “we”), have created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information (“Personal Data”) we obtain through our website located at www.echelon.xyz (the “Sites”), as well as the Internet Services that we offer (together, the “Services”) to individuals or other legal entities on behalf of which such individuals (“you”) are accessing or using the Services.
If you are located in the European Union (the “EU”) or the United Kingdom (the “UK”), this Privacy Policy is for informational purposes only. If you are located in the United States of America or otherwise outside the EU or the UK, please note that by using or accessing our Services in any manner, you acknowledge that you accept and consent to the practices outlined in the Privacy Policy below.
This Privacy Policy was updated as of September 7, 2022.
This Privacy Policy describes Echelon’s policies and procedures on the collection, use and disclosure of your information when you access or use our Services.
Personal Data refers to any information that identifies or relates to a particular individual, including information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations.
This Privacy Policy does not cover the practices of third parties that Echelon does not own or control or people that we don’t manage.
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you.
The following list details the types of Personal Data that we collect and have collected over the past 12 months.
Usage Data is collected automatically when using the Services.
Usage Data may include information such asy Device’s IP address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, etc.
We use Cookies and similar tracking technologies to track the activity on Our Services and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze our Services. The technologies we use may include:
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with Services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the Services that you have asked for cannot be provided, and we only use these Cookies to provide you with those Services.
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features, or new functionality of the Website to see how our users react to them.
We process Personal Data to operate, improve, and personalize our Services. The Company may use Personal Data for the following purposes:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may share your personal information in the following situations:
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
The security of your Personal Data is important to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
If Echelon is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary to:
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Services in accordance with their Privacy Policies.
We may use third-party Service Providers to monitor and analyze the use of our Services.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Firebase is an analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage: https://policies.google.com/technologies/partner-sites
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at datascience@echelon.xyz.
We may use Email Marketing Services Providers to manage and send emails to you.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/
Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy
We may use third-party Service Providers to provide better improvement of our Services.
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from you and from your device for security purposes.
The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/
This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Collected: Yes.
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Examples: Records and history of products or Services purchased or considered.
Collected: No.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Examples: Interaction with our Services or advertisement.
Collected: Yes.
Examples: Approximate physical location.
Collected: No.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Examples: Current or past job history or performance evaluations.
Collected: No.
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, Personal Information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “How We Use Your Personal Data” section.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed. Instead, it reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may have been disclosed.
When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
We may share your personal information identified in the above categories with the following categories of third parties:
We do not knowingly collect personal information from minors under the age of 16 through our Services, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and Privacy Policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the personal information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at datascience@echelon.xyz.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by email at datascience@echelon.xyz.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to us must:
We cannot respond to your request or provide you with the required information if we cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
You have the right to opt out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt out, please contact us at datascience@echelon.xyz.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Services:
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Our Services does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or Services.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, you can contact us by email at datascience@echelon.xyz.