1. Introduction
Envinary Group Limited ("Envinary Group", "we", "us", or "our") is committed to protecting the privacy and security of the personal information of all individuals who interact with us, including website visitors, founders, investors, portfolio company representatives, and other business contacts.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (www.envinarygroup.com), submit inquiries through our contact forms, or otherwise interact with us in the course of our business activities.
Our registered office is located at Unit 808, 8/F., Star House, 3 Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong Special Administrative Region, People's Republic of China.
2. Information We Collect
2.1 Information You Provide Directly
We may collect the following personal information when you interact with us:
- Contact Information: Name, email address, phone number, company name, job title, and mailing address.
- Business Information: Details about your company, business plan, financial projections, and other information submitted as part of an investment inquiry or pitch.
- Communication Records: The content of emails, contact form submissions, and other communications you send to us.
- Investment Information: If you are a limited partner (LP) or prospective investor, we may collect financial information necessary to verify accreditation status and comply with regulatory requirements.
2.2 Information Collected Automatically
When you visit our website, we may automatically collect certain information about your device and usage:
- Device Information: IP address, browser type and version, operating system, device type, and screen resolution.
- Usage Data: Pages visited, time spent on pages, referral URLs, click patterns, and navigation paths through our website.
- Cookies and Tracking Technologies: We use cookies and similar technologies as described in our Cookie Policy.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Communication: To respond to your inquiries, provide information about our services, and maintain our business relationship.
- Investment Activities: To evaluate potential investments, conduct due diligence, and manage our portfolio of investments.
- Investor Relations: To communicate with our limited partners and provide updates on fund performance and portfolio developments.
- Website Improvement: To analyze usage patterns, improve our website's functionality, and enhance user experience.
- Legal Compliance: To comply with applicable laws, regulations, and legal processes, and to protect our legal rights and interests.
- Marketing: With your consent, to send you newsletters, market insights, and information about our activities and events.
4. Legal Basis for Processing
We process your personal information based on one or more of the following legal grounds:
- Consent: Where you have given explicit consent for us to process your data for specific purposes.
- Legitimate Interests: Where processing is necessary for our legitimate business interests, such as evaluating investment opportunities and maintaining business relationships.
- Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.
- Legal Obligation: Where processing is necessary to comply with legal or regulatory obligations.
5. Data Sharing and Disclosure
We may share your personal information with the following categories of recipients:
- Service Providers: Third-party vendors who provide services on our behalf, such as website hosting, email services, data analytics, and professional advisory services. These providers are contractually obligated to protect your information.
- Portfolio Companies: Where relevant to facilitate introductions or business relationships, with your consent.
- Professional Advisors: Lawyers, accountants, auditors, and other professional advisors engaged in the course of our business operations.
- Regulatory Authorities: Government agencies, regulators, or law enforcement bodies where required by law or regulation.
- Business Transfers: In connection with any merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of such transaction.
We do not sell your personal information to third parties.
6. International Data Transfers
As a global investment firm, your personal information may be transferred to and processed in countries other than your country of residence, including Hong Kong SAR, the People's Republic of China, and other jurisdictions where our operations, service providers, or portfolio companies are located.
Where we transfer personal data internationally, we implement appropriate safeguards to ensure that your information receives an adequate level of protection in accordance with applicable data protection laws.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit and at rest
- Access controls and authentication mechanisms
- Regular security assessments and vulnerability testing
- Staff training on data protection and information security
- Incident response procedures for potential data breaches
While we take reasonable precautions, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.
8. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The retention period may vary depending on the context and our legal obligations.
For general business contacts, we typically retain information for up to 7 years after our last interaction. For investment-related information, retention periods may be longer as required by applicable securities and financial regulations.
9. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: The right to request a copy of the personal information we hold about you.
- Rectification: The right to request correction of inaccurate or incomplete information.
- Erasure: The right to request deletion of your personal information in certain circumstances.
- Restriction: The right to request restriction of processing of your personal information.
- Data Portability: The right to receive your personal information in a structured, machine-readable format.
- Objection: The right to object to processing of your personal information based on legitimate interests or for direct marketing purposes.
- Withdraw Consent: Where processing is based on consent, the right to withdraw consent at any time.
To exercise any of these rights, please contact us at privacy@envinarygroup.com.
10. Third-Party Links
Our website may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access through our website.
11. Children's Privacy
Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website and update the "Last Updated" date. We encourage you to review this policy periodically.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Envinary Group Limited
Data Protection Office
Unit 808, 8/F., Star House
3 Salisbury Road, Tsim Sha Tsui
Kowloon, Hong Kong SAR
Email: privacy@envinarygroup.com
Last Updated: December 15, 2024