Privacy Policy

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Published as of 01 August, 2022

Effective Date: 01 August, 2022

Last Updated: 01 August, 2022

ETHAN.AI (“Ethan.ai” or “we”, “us”, “our”, etc.)

INTRODUCTION

This Ethan.ai Terms of Service and End User License Agreement constitutes an agreement between you (Subscriber, User, or Customer) and Us (ETHAN.AI PRIVATE LIMITED) and sets forth the terms and conditions that apply to your access and use of Our Ethan.ai Service, Website and Applications.

ABOUT US: Ethan.ai is a software as a service platform that offers automated wealth data aggregation and portfolio visualization. Security and safety of Our clients’ data and information is top priority. We explain here how We handle and protect your information.

This Policy describes the practices of Ethan.ai with respect to our collection, use and/or disclosure of Personal Information on wb.ethan-ai.com (the “Website”) and through the services, features, content, or applications we offer to our customers (collectively with the Website, the “Services”). This Policy does not apply to employees and individual contractors of Ethan.ai who are subject to a separate policy. Employees of Ethan.ai dealing with Personal Information are expected to be familiar with this Policy. For clarity, this Policy does not apply to non-personally identifiable information, anonymous information, or aggregate information that does not identify any specific individual

DEFINITIONS

The Definitions used in our Terms of Service or End User License Agreement apply to this Privacy Policy.

“Personal Identifiable Information” can be defined as follows:

 

Personal Identifiable Information means information about an identifiable individual who can be directly or indirectly identified, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified.

Information about a corporation, firm, trust, union or other non-individual entity is not Personal Information.

Data and information provided or created by our customers in the course of using our products or services (“Customer Data”) remains the property of our customers and is not used or disclosed by us except as reasonably required to provide our products or services, or as otherwise set out in this Policy

COMMUNICATING WITH US

We offer two specific communication methods that are designed to maintain your anonymity in the course of your interaction with Us.

The communication method is via anonymous email. Upon opening your account, We will ask you to register an email address that will be linked to your Ethan.ai account. We encourage you to set up an email address which contains no information from which your personal identity may be inferred, for the sole use of Ethan.ai. If required, We can guide you on the setup of such an email address.

Aside from the above, you may still communicate with Us via any email address that you regularly use. In such cases, We may receive information that discloses or could be used to establish your identity. We will, however, respect the confidentiality of such information (as with any other information that We receive from you) and will only use and/or retain the information strictly in accordance with Our usage policy (see Use of Your Data and Information below).

USE OF YOUR DATA AND INFORMATION

Personal Financial Data: We use the financial account statements and other financial data that you provide to Us or authorize Us to have access (collectively, your “Personal Financial Data”), in order to deliver the Ethan.ai service, you have subscribed to. We will maintain such data as strictly confidential and will not sell, lease or distribute the same to any third party (other than certain trusted third party service providers involved in the operations of Our business and performing services on Our behalf, with restricted access to customer data and information, on a need-to-know basis only, and in compliance with this Privacy Policy) without your documented approval, unless We are required or requested to do so by law or any regulatory authority for the jurisdiction that We operate in. For the avoidance of doubt, Personal Financial Data for this purpose does not include information that is aggregated with similar data

from other users to produce Meta Data as described below or is otherwise no longer identifiable to any specific Ethan.ai user.

Meta data: We may derive and create data and information about the use of the Services by our customers (“Use Data”) which may be disclosed to third party service providers in order to improve our Services.

We may derive anonymous data from Customer Data or Use Data and eliminate Personal Information from such         Customer Data and Use Data so that such derived data cannot be used to identify a customer or its individual users (“Anonymous Data”);

We may then combine Anonymous Data with similar anonymous data from other customers or users and derive Aggregate Data and then license or sell such Aggregate Data. “Aggregate Data” shall mean anonymous data combined from various sources which cannot be used to identify any customer or user.

We may also derive Anonymous Data for the purposes of creating statistics and analytics data, which will be used by Ethan.ai for its own business purposes, including maintaining and improving the Services.

Personally Identifiable Information: As stated earlier, should you voluntarily provide Us with any of your PII, We treat such information with strict confidentiality. We will not sell, lease, or distribute the same to any third party without your documented approval, unless We are required or requested to do so by law or any regulatory authority for the jurisdiction that We operate in. Such data will be used solely to facilitate communication, and processing of internal administrative and record keeping.

KEEPING YOUR DATA AND INFORMATION SAFE

What We do

 

We may collect and use Personal Information without consent in circumstances that include but are not limited to the following

:

a) Where a reasonable person would consider that the collection of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way, or the individual would not reasonably be expected to withhold consent;

b) Where the collection of the information is pursuant to a statute or regulation that authorizes or requires the collection;

 

c) Where the collection of the information is from a public body and that public body is authorized or required by an enactment of applicable law to disclose the Personal Information to Ethan.ai;

 

d) Where the collection of the information is reasonable for the purposes of an investigation or a legal proceeding;

 

e) Where the information is publicly available;

 

f) Where the collection of the information is necessary in order to collect a debt owed to Ethan.ai or for Ethan.ai to repay to an individual money owed by Ethan.ai;

 

g) In addition to the above, the law generally provides that an individual is deemed to consent to the collection, use or disclosure of Personal Information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information. If an individual provides Personal Information to us voluntarily, we will rely on deemed consent and consider that the individual consents to our collection, use or disclosure of their Personal Information as necessary to carry out the purposes for which they provided the information;

 

h) Where a new purpose for the use or disclosure of Personal Information previously collected arises, Ethan.ai will contact the individual in question to obtain any required consent or to provide any required notification for use and/or disclosure for such new purpose or purposes;

 

i) Where practical, Ethan.ai will try to collect Personal Information directly from the individual. Where necessary, Ethan.ai will collect Personal Information from other sources. When Ethan.ai collects Personal Information about individuals directly from them, except when their consent to the collection is deemed or has otherwise been previously and lawfully obtained, or is not required, we will tell them the purpose for which the information is collected, and, if reasonable to do so, the name of a person who can answer questions about the collection;

 

j) Ethan.ai will in all cases use Personal Information only as permitted or required by applicable law

 

What you should and should not do

You should ensure that your username, password, and if applicable, two factor authentication device required to access the Service is kept secure and confidential at all times and make every reasonable effort to prevent unauthorized third parties from accessing the Service using your user ID, password, and if applicable, two factor authentication device. In public areas, you should exercise caution and not leave your computer unattended whilst logged into your account. You should also avoid using public computer terminals to access your Ethan.ai account, unless you can adequately verify that the terminal is free from spyware and that you can erase all of your information upon exiting the terminal. We will not be liable for any loss or damage arising from unauthorized access to your account due to any failure to comply with these precautions.

OTHER DATA

Ethan.ai may record certain non-personal information such as Website usage and browsing activity, data displayed or clicked on (such as UI elements), and others (such as IP address, cookie ID, and referrer URL). Along with cookies, Ethan.ai may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the Ethan.ai Website. We may grant access to your data and information to certain trusted third-party services providers that We work with, but only to perform the service on Our behalf with restricted access to customer data and information on a need-to-know basis only, and in compliance with this Privacy Policy.

DATA RETENTION

We will delete your original Personal Financial Data within a reasonable time after the relevant financial information has been extracted and processed into Our database for the purpose of generating reports. We will retain your account information for as long as you use Ethan.ai or retain in accordance with applicable law and where we have an ongoing legitimate business need to do so (for example, to provide you with a Service you have requested or to comply with applicable legal, tax or accounting requirements). If you decide to stop the service, We will delete all such data within a reasonable time after the termination of the service, subject to retention for purposes of complying with applicable laws, resolving disputes, enforcing the terms of Our agreement with you and protecting Ethan.ai’s intellectual property rights. When we collect, use or disclose Personal Information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete.

THIRD PARTY WEBSITES AND THIRD-PARTY PLATFORMS

a) Please note that our website may contain links to other websites which are provided as a convenience for visitors to our website only, in addition to third party services, applications, and widgets that may be bundled into, included in, or provided in connection with our services.

b) Any third-party websites, third party services, applications and widgets will have their own privacy policies and practices, and we cannot be responsible for such third parties, their websites, services, applications, widgets, or their privacy practices. Where “Third Party Services” (as defined in our Terms & Conditions) are provided or made available to you, you consent to your name, email address and any other reasonably required information being sent to the applicable third party to enable such third party to make its Third Party Services available or to provide you with its Third Party Services as required or requested by you, and to authenticate or validate you as a customer of Ethan.ai that is entitled to such Third Party Service.

AMENDMENT

By using Ethan.ai, you agree to the terms of this Privacy Policy. We may revise the terms of this Privacy Policy from time to time and will always present the most up-to-date version on Our Website. It is your responsibility to periodically review and keep yourself appraised of the latest terms but, if any revision meaningfully affects your rights, We will take reasonable steps to notify you of such changes. You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy.

Please inform Us of any changes to your email address and other communication preferences and We will take steps to update Our records after receiving such notification.

CONTACT

If you have questions or concerns about this Privacy Policy or about Our use or retention of your PII or Personal Financial Data, please contact Us via email support@ethan-ai.com or any other designated email address provided to you by Us, or through communication with the Designated Partner (if applicable), or via post mail, addressed to ETHAN.AI PRIVATE LIMITED  (weekdays 9:00 – 18:00 Singapore time).