Privacy Policy
1. Introduction
Eno River Capital (“we,” “us,” “our”) values your privacy and is committed to protecting your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data when you visit our website (enorivercapital.com) or engage with our services. We adhere to the highest standards of data protection and privacy practices in compliance with applicable laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).
2. Scope of This Policy & Data Controller Responsibility
This Privacy Policy applies to all users of our website and to all personal data processed via enorivercapital.com. Eno River Capital is the data controller with respect to personal data collected through this website and determines the purposes and means of the processing of personal information. If you have any questions about how your information is collected, used, or shared, please contact us at [email protected].
3. Categories of Data We Process
We may collect and process the following categories of personal data:
a) Usage Data
This includes data collected about your interactions with our website, such as IP address, browser type and version, operating system, referring URLs, page views, time spent on pages, clickstream patterns, and session data.
b) Account Data
Information that you provide when creating an account or engaging our services, such as your full name, residential address, email address, and telephone number.
c) Profile Data
Information relating to your preferences, engagement history, service interests, behaviors, and any customizations you make on our website.
d) Communication Data
Information contained in communications you send to us, including contact inquiries, customer support requests, or satisfaction surveys, along with our responses and correspondence history.
e) Technical Data
Information regarding the devices you use to access enorivercapital.com, including internet connection, device identifiers, operating system, browser details, language settings, and time zone.
f) Transaction Data
Details relating to transactions conducted through our website or services, such as invoice information, payment details, shipping and delivery information, and any related records.
g) Preference Data
Information you have expressly provided regarding your communication preferences, including marketing consents, service updates opt-ins, or interest in specific products or solutions.
4. Legal Bases for Processing
We process your personal data on one or more of the following legal bases:
– Legitimate Interests: For the administration and improvement of our website and services, fraud prevention, and ensuring network and information security, provided that such interests are not overridden by your data protection rights.
– Performance of a Contract: To fulfill obligations under any agreement entered into with you.
– Consent: When you have given informed and explicit consent, such as for non-essential cookies or marketing communications.
– Legal Obligation: When processing is required to comply with legal, regulatory, or tax obligations.
5. Your Data Protection Rights
Under GDPR and CCPA, subject to certain limitations, you may exercise the following rights:
– Right to Access: Request access to the personal data we hold about you.
– Right to Rectification: Request correction of any inaccurate or incomplete information.
– Right to Erasure: Request deletion of your personal data under certain circumstances.
– Right to Restriction of Processing: Request limitation on how we process your information.
– Right to Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format, and transmit it to another controller.
– Right to Object: Object to processing where we rely on legitimate interests or for direct marketing purposes.
– Right Not to Be Subject to Automated Decisions: You have the right to not be subject to decisions based solely on automated processing.
To exercise any of your rights, please contact us at [email protected] and we will respond in accordance with applicable regulations.
6. Security Measures
We implement robust technical and organizational measures to secure your personal data, including:
– End-to-end data encryption during transmission and at rest
– Strict access control and authentication procedures
– Role-based access to sensitive systems
– Periodic data integrity and vulnerability audits
– Encrypted backups with regular recovery testing
– Ongoing staff training in data protection policies and best practices
7. International Data Transfers
Where personal data is transmitted to and processed in countries outside the European Economic Area (EEA) or United States, we utilize lawful mechanisms such as Standard Contractual Clauses, adequacy decisions, or your explicit consent to ensure adequate protection and compliance with regional requirements.
8. Data Retention
We retain personal data only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. Retention periods are as follows:
– Usage Data: up to 12 months for analytics and website optimization
– Account Data: retained while the account is active and up to 24 months post-deactivation
– Profile & Preference Data: retained as long as interaction continues or until consent is withdrawn
– Communication Data: up to 36 months for customer service quality and dispute resolution
– Technical & Transaction Data: up to 7 years, to comply with tax and regulatory obligations
9. Cookie Policy
enorivercapital.com uses cookies and similar technologies to enhance user experience, personalize content, perform analytics, and deliver targeted advertising. The types of cookies we use include:
– Essential Cookies: Required for the operation and security of our website
– Functional Cookies: Enable personalization and site preferences
– Analytics Cookies: Help us understand user behavior and improve usability
– Performance Cookies: Support performance metrics and debugging
10. Managing Cookies & Compliance
In compliance with GDPR and CCPA, visitors to enorivercapital.com are presented with a cookie consent banner on first visit. You may accept or reject non-essential cookies at any time, and update your preferences via our cookie settings panel. Most browsers also allow you to control cookie preferences through built-in settings. Declining certain cookies may impair website functionality.
We do not sell your personal data, including for CCPA purposes. If you are a California resident and wish to exercise your “Do Not Sell My Info” right or request disclosure of information, please contact us directly at [email protected].
11. Children’s Privacy
Our services are not directed to individuals under the age of 13. We do not knowingly process personal data from children under 13 without verifiable parental consent. If you believe we have collected personal data from a child in error, please notify us at [email protected] and we will take immediate steps to delete such information.
12. Policy Amendments & Notifications
We may update this Privacy Policy from time to time to remain compliant with legal, operational, or technological changes. Substantive amendments will be communicated through notification on our homepage or by contacting you via preferred communication channels where appropriate.
13. Contact Us
Should you have any questions, complaints, concerns, or requests regarding this Privacy Policy or the way your information is processed, please contact:
Email: [email protected]
Website: https://enorivercapital.com
We take privacy seriously and are dedicated to ensuring your rights are respected and upheld in accordance with applicable data protection laws.