Privacy Policy
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.
What this Privacy Policy covers
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.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
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.
Contact Information (e.g. email address, first name and last name, phone number)
Demographic Data (e.g. race, gender)
Device/IP Data (e.g. IP address)
Geolocation Data (e.g. IP-address-based location information)
Other identifying information that you voluntarily provide (e.g. identifying information in emails sent to us)
Usage Data (e.g. pages visited and interactions)
Usage Data
Usage Data is collected automatically when using the Services.Usage Data may include information such as Your 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.
Tracking Technologies and Cookies
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 or Browser Cookies.A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.
Flash Cookies.Certain features of our Services may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Services. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons.Certain sections of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
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:
Necessary / Essential Cookies
Type: Session CookiesAdministered by: UsPurpose: 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.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent CookiesAdministered by: UsPurpose: 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.
Tracking and Performance Cookies
Type: Persistent CookiesAdministered by: Third-PartiesPurpose: 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.
How We Use Your Personal Data
We process Personal Data to operate, improve, and personalize our Services. The Company may use Personal Data for the following purposes:
To provide and maintain our Services, including to monitor the usage of our Services.
To improve and develop the Services, including testing, research, analysis, and development.
To manage your account as a user of the Services. The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.
To contact you about the Services, including general information, news, announcements, updates, or offers.
To provide you with support and assistance for the Services.
To create and manage your requests and user accounts.
To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Services users is among the assets transferred.
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
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.
How We Share Your Personal Data
We may share your personal information in the following situations:
With Services Providers:We may share your personal information with Services Providers to monitor and analyze the use of our Services, to contact You.
For business transfers:We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
With Affiliates:We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that e control or that are under common control with us.
With business partners:We may share your information with our business partners to offer you certain products, Services, or promotions.
With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With your consent: We may disclose your personal information for any other purpose with Your consent.
Retention and Security of Your Personal Data
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.
Disclosure of Your Personal Data
Business Transactions
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.
Law enforcement
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).
Other legal requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of Echelon
Prevent or investigate possible wrongdoing in connection with the Services
Protect the personal safety of users of the Services or the public
Protect against legal liability
Detailed Information on the Processing of Your Personal Data
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.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Services.
Google Analytics
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
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/privacyWe also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245For 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
Email Marketing
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 contact@echelon.xyz.We may use Email Marketing Services Providers to manage and send emails to You.
Mailchimp
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/
Hubspot
Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy
Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Services.
Invisible reCAPTCHA
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/
CCPA 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.
Categories of Personal Information Collected
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.
Category A: Identifiers.
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.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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.
Category C: Protected classification characteristics under California or federal law.
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.
Category D: Commercial information.
Examples: Records and history of products or Services purchased or considered. Collected: No.
Category E: Biometric information.
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.
Category F: Internet or other similar network activity.
Examples: Interaction with our Services or advertisement.Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
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.
Category K: Inferences drawn from other personal information.
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:
Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from the forms you complete on our Services, preferences you express or provide through our Services.
Indirectly from you. For example, from observing your activity on our Services.
Automatically from you. For example, through cookies we or our Services Providers set on your device as you navigate through our Services.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Services, or other third-party vendors that we use to provide the Services to you.
Use of Personal Information for Business Purposes or Commercial Purposes
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:
To operate our Services and provide you with our Services.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Services.
To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Services, we will use that personal information to respond to your inquiry.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
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.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
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:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
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.
Sale of Personal Information
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:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above categories with the following categories of third parties:
Services Providers
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or Services We provide to You
Sale of Personal Information of Minors Under 16 Years of Age
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 contact@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.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
The right to notice.You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request.Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
The categories of personal information we collected about you
The categories of sources for the personal information we collected about you
Our business or commercial purpose for collecting or selling that personal information
The categories of third parties with whom we share that personal information
The specific pieces of personal information we collected about you
If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
The categories of personal information categories sold
The categories of personal information categories disclosed
The right to say no to the sale of Personal Data (opt-out).You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us at contact@echelon.xyz.
The right to delete Personal Data.You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
The right not to be discriminated against.You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
Denying goods or Services to you
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to you
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection 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 contact@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:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We cannot respond to your request or provide you with the required information if we cannot:
Verify your identity or authority to make the request
And confirm that the personal information relates to you
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 contact@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.
Website
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 NAI’s opt-out platform: http://www.networkadvertising.org/choices/
The EDAA’s opt-out platform http://www.youronlinechoices.com/
The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
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.
Mobile Devices
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:
“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
“Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Children’s Privacy
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.
Links to Other Websites
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.
Changes to this Privacy Policy
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.
Contact Us
If you have any questions about this Privacy Policy, you can contact us by email at contact@echelon.xyz.