Updated: 14th August 2020

Privacy Policy

 

Thank you for choosing to visit ET2C International Limited (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at contact@et2c.com.

When you visit our website https://www.et2c.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites and our services.

This privacy notice applies to all information collected through our website (such as https://www.et2c.com), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the “Services”).

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

 

TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we use your information?
  3. Will your information be shared with anyone?
  4. Do we use cookies and other tracking technologies?
  5. How long do we keep your information?
  6. How do we keep your information safe?
  7. Do we collect information from minors?
  8. What are your privacy rights?
  9. Controls for do-not-track features
  10. Do we make updates to this policy?
  11. How can you contact us about this policy?
  12. How can you review, update or delete the data we collect from you?

 

1. WHAT INFORMATION DO WE COLLECT?


Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

 

2. HOW DO WE USE YOUR INFORMATION?

 

In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To deliver services to the user. We may use your information to provide you with the requested service.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer your 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.
  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

 

7. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at contact@et2c.com.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

10. DO WE MAKE UPDATES TO THIS POLICY?

 

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) by email at contact@et2c.com

 

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

 

 

Cookie Policy

 

This Cookie Policy explains how ET2C International Limited (HK) (“Company”, “we”, “us”, and “our”) uses cookies and similar technologies to recognise you when you visit our websites at https://www.et2c.com, (“Websites”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

 

WHAT ARE COOKIES?

 

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, ET2C International Limited) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

 

WHY DO WE USE COOKIES?

 

We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.

The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit).

 

HOW CAN I CONTROL COOKIES?

 

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The specific types of first and third party cookies served through our Websites and the purposes they perform are described in the table below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

 

Analytics and customisation cookies:

 

These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.

 

WHAT ABOUT OTHER TRACKING TECHNOLOGIES, LIKE WEB BEACONS?

 

Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Websites or opened an e-mail including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

 

Do you use Flash cookies or Local Shared Objects?

 

Websites may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs”) to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

 

Do you serve targeted advertising?

 

Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.

 

How often will you update this Cookie Policy?

 

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

 

Where can I get further information?

 

If you have any questions about our use of cookies or other technologies, please email us at contact@et2c.com.

Cookie List

 

NameVISITOR_INFO1_LIVE
DescriptionThis cookie is set by YouTube. Used to track the information of the embedded YouTube videos on a website.
Duration5 months
TypeAdvertisement

 

 NameGPS
DescriptionThis cookie is set by Youtube and registers a unique ID for tracking users based on their geographical location
Duration30 minutes
TypeAnalytics

 

NameYSC
DescriptionThis cookies is set by Youtube and is used to track the views of embedded videos.
Duration
TypePerformance

 

Name_lfa
Description
Duration2 years
TypeOther

 

Name_ga
DescriptionThis cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
Duration2 years
TypeAnalytics

 

Name_gid
DescriptionThis cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the wbsite is doing. The data collected including the number visitors, the source where they have come from, and the pages viisted in an anonymous form.
Duration1 day
TypeAnalytics

 

Name_gat_UA-4011612-8
DescriptionThis is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
Duration1 minute
TypePerformance

 

NameIDE
DescriptionUsed by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.
Duration1 year
TypeAdvertisement

 

Namedrift_campaign_refresh
DescriptionThis cookie is set by YouTube. Used to track the information of the embedded YouTube videos on a website.
Duration30 minutes
TypeOther

 

Namedriftt_aid
DescriptionThis is the anonymous identifier token. It is used to tie the visitor on your website with the profile within the Drift system. This allows Drift to remember the information that this site visitor has provided through the chat on subsequent site visits.
Duration2 years
TypeTracking & Identification

 

Namedriftt_sid
DescriptionThis is the session identifier token. It is used to tie the visitor on your website with a current website session within the Drift system. This is enables session-specific features, such as popping up a messaging only once during a 30 minute session as to prevent a disruptive experience.
Duration30 minutes
TypeTracking & Identification

 

Namedriftt_wmd
DescriptionThis cookie marks when the Drift welcome message has been interacted with. It is used so the welcome message is not displayed subsequently.
Duration2 years
TypeFunctionality

 

NameDFTT_END_USER_PREV_BOOTSTRAPPED
DescriptionThis cookie marks when the Drift site visitor has been created within the Drift system. This allows subsequent page visits to be faster because the site visitor does not have to be registered in our system again.
Duration2 years
TypeFunctionality

 

NameDFTT_LEAD_HAS_PREV_IDENTIFIED
DescriptionThis cookie marks when the Drift site visitor has provided their email address to Drift. This allows the Drift widget to process this site visitor as a known visitor rather than anonymous. Although this is a marker for PII it does not relate directly to the email address that has been captured, that identifier is handled by the driftt_aid cookie.
Duration2 years
TypeFunctionality

 

NameDrift.Targeting.firstVisit
DescriptionThis is the timestamp of the first visit. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.lastVisit
DescriptionThis is the timestamp of the last visit. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.numberOfVisits
DescriptionThis is the number of visitors a visitor has made to a page with Drift. It allows the Drift widget to perform page visit targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.numberOfSessions
DescriptionThis is the number of site sessions a visitor has made to a page with Drift. It allows the Drift widget to perform site session targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.currentPageViewStarted
DescriptionThis is the entry page that the current session started at. It allows the Drift widget to perform site session targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.currentSessionStartedAt
DescriptionThis is the timestamp of the beginning of the current site session. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.previousSessionStartedAt
DescriptionThis is the timestamp of the start of the previous site session. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.previousSessionEndedAt
DescriptionThis is the timestamp of the end of the previous site session. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.activeSessionStartedAt
DescriptionThis is the timestamp of the start of the active site session. It allows the Drift widget to perform time-sensitive targeting conditions.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.originalReferrer
DescriptionThis is the original referring source that drove the site visitor to your website. It allows the Drift widget to perform accurate intent based targeting.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.previousPage
DescriptionThis is the previous page that the site visitor was on. It allow the Drift widget to perform page specific targeting.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.currentReferrer
DescriptionThis is the current referring source that drove the site visitor to your website. It allows the Drift widget to perform accurate intent based targeting.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.searchTerm
DescriptionThis is the search term that drove the site visitor to the website. It allows the Drift widget to perform accurate intent based targeting.
DurationLocalStorage does not expire.
TypeTracking

 

NameDrift.Targeting.referrerDomain
DescriptionThis is the domain of the referrer URL. It allows the Drift widget to perform accurate intent based targeting.
DurationLocalStorage does not expire.
TypeTracking

 

Namedrift_ujwt
DescriptionThis is a signed JWT that is used to securely identify users that are on your website.

This cookie is only used if you utitlize signed identities within Drift, which is a very specific feature that only a few customers use. You will not see this cookie unless you expect to.

Duration2 years
TypeTracking & Identification

 

Name__utma
DescriptionUsed to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.
Duration2 years
TypeAnalytics

 

Name__utmt
DescriptionUsed to throttle request rate.
Duration10 minutes
TypeAnalytics

 

Name__utmb
DescriptionUsed to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.
Duration30 minutes
TypeAnalytics

 

Name__utmc
DescriptionNot used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
DurationExpires at end of browser session
TypeAnalytics

 

Name__utmz
DescriptionStores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
Duration6 months
TypeAnalytics

 

Name__utmv
DescriptionUsed to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.
Duration2 years
TypeAnalytics

 

Nameact
DescriptionFacebook – This cookie is used to distinguish between two sessions for the same user, created at different times.
Duration90 days
TypeAdvertising

 

Namec_user
DescriptionFacebook – The c_user cookie contains the user ID of the currently logged in user.
Duration90 days
TypeAdvertising

 

Namedatr
DescriptionFacebook – The purpose of the datr cookie is to identify the web browser being used to connect to Facebook independent of the logged in user.

 

Duration2 years
TypeAdvertising

 

Namexs
DescriptionFacebook – This cookie contains multiple pieces of information, separated by colon (colon is encoded to the value %3A for transmission).

  • The first value is an up to two-digit number representing the session number.
  • The second portion of the value is a session secret.
  • The third, optional component is a ‘secure’ flag for if the user has enabled the secure browsing feature.
Duration90 days
TypeAdvertising

 

Namelocale
DescriptionFacebook – This cookie contains the display locale of the last logged in user on this browser.

This cookie appears to only be set after the user logs out.

 

Duration7 days
TypeAdvertising

NameUserMatchHistory
DescriptionLinkedIn Ads ID syncing
Duration30 days
TypeAdvertising

 

Nameli_sugr
DescriptionBrowser Identifier
Duration3 months
TypeAdvertising

 

NameBizographicsOptOut
DescriptionDetermine opt-out status for 3rd party tracking
Duration10 years
TypeAdvertising

 

Nameli-oatml
DescriptionMember indirect indentifier for conversion tracking, retargeting, analytics
Duration1 month
TypeAdvertising

 

Nameli_fat_id
DescriptionMember indirect indentifier for conversion tracking, retargeting, analytics
Duration1 month
TypeAdvertising

 

NameU
DescriptionBrowser Identifier
Duration3 months
TypeAdvertising

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