Privacy Notice
Last updated: July 1, 2023

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1. Introduction
Thank you for visiting the Ellenven Investments Inc. platform. By visiting, accessing or using this platform, you agree to the terms and practices described in this privacy notice (the “Privacy Notice”), so please read it carefully. If any terms or practices described in this Privacy Notice are unacceptable to you, please do not visit, access or use the Ellenven Investments Inc. platform. The use of the words “we”, “us” or “our” in this Privacy Notice refers to any or all of the Ellenven Investments Inc. entities.

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2. About this Privacy Notice
This Privacy Notice explains what information we collect, why we collect it and how we treat your personal information. For the purposes of this Privacy Notice, references to “personal information” will be synonymous with “personal data”. By visiting, accessing or using the Ellenven Investments Inc. platform, you confirm that you are at least eighteen (18) years of age and agree to abide by the terms and practices described in this Privacy Notice in their entirety. Your privacy is important to us, so whether you are new to Ellenven Investments Inc. or a returning user of our website or services, please take the time to familiarize yourself with our policies and practices. If you do not wish to be bound by this Privacy Notice, you should not visit, access or use our website or services.

As used herein, “Digital Currency” means a digital asset (also referred to as “cryptocurrency”, “virtual currency”), such as, but not limited to, bitcoin, that is based on cryptographic protocol(s) of an electronic system that may be (i) centralized or decentralized, (ii) proprietary or open source, and (iii) used as a medium of exchange and/or store of value.

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3. Information we collect
We will collect and process the following information about you:
Information required by Section 326 of the USA PATRIOT ACT (the “Patriot Act”). The Patriot Act requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This federal requirement applies to all Ellenven Capital Inc. counterparties. This information is used to help the United States government fight the financing of terrorism and money laundering activities. When you complete an application, we ask for:
your name, address, date of birth, and other identifying information. For more details, see below.
Verification information we collect about individual customers. (“Individual Verification Information”) We collect information that you provide during a completed, incomplete, or abandoned application. This may include the following information:
Full legal name;
Social Security Number (“SSN”) or any comparable government-issued identification number;
Date of Birth (“DOB”);
Proof of identity (e.g., driver’s license, passport, or government-issued ID);
Home address (not a mailing address or post office box);
Bank statements, tax documents, or other proof of income or net worth; and
Additional information or documentation, at the discretion of our Compliance Team, as necessary to comply with laws, regulations, or internal policies. This may include information related to health, relationship status, and criminal convictions.

Verification information we collect about institutional clients. (“Institutional Verification Information”) We collect information that representatives of an entity provide during a completed, incomplete, or abandoned application. This may include the following information:

Full legal names;
Government-issued identification numbers;
Addresses;
Contact information and Proof of identity;
Device information.

Information that is automatically collected about your device (including hardware, operating system, browser, device type, IP address, message authentication code (“MAC”), hard drive, and location services).

Location information. Information that is automatically collected by analytics providers to determine your location, including your IP address and/or domain name and any external pages that referred you to us.

Log information. Information generated by your use of Ellenven Investments Inc. that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity, and any internal and external information relating to Ellenven Investments Inc. pages.

Trading information. Information generated by your trading activity, including