Privacy Policy

This Privacy Policy explains what personal data Entelera collects, why we collect it, how we use and protect it, and the choices and rights you have. It applies to our website at entelera.com, the installable Entelera web app, the Energy Updates Today email newsletter, and our consulting and AI-automation enquiry form (together, the "Services").

We have tried to write this in plain English. If anything is unclear, contact us at privacy@entelera.com.

1. Who we are

The Services are run by Entelera, operated by Aashish Arya (founder), based in India.

• Registered legal entity: [Registered legal entity name, to be added after registration]
• Registered address: [Registered address, to be added after registration]
• General contact: hello@entelera.com
• Privacy contact: privacy@entelera.com

In this policy, "Entelera", "we", "us" and "our" mean the operator named above. For the purposes of India's Digital Personal Data Protection Act, 2023 (DPDP Act), we are the Data Fiduciary for the personal data described here. For the purposes of the EU General Data Protection Regulation (GDPR) and UK GDPR, we are the controller.

2. Summary

• We collect only what we need: mainly your email address (for the newsletter) and the details you choose to send us through the enquiry form.
• We send the newsletter only if you sign up, and every email has a one-click unsubscribe link.
• Saved stories in our web app are stored on your own device, not on our servers.
• Our company and executive profiles use publicly available professional information. If you are named in a profile, you can ask us to correct or remove information (see Section 10).
• We do not sell your personal data, and we do not use it for third-party advertising.
• We use trusted service providers (for example, hosting, email and analytics) who process data on our behalf under contract.
• You can access, correct or delete your data, withdraw consent and raise a complaint. Contact privacy@entelera.com.

3. The personal data we collect

3.1 Data you give us

Please do not send us sensitive personal data (for example, health information, financial account details, government ID numbers, or information about religion, political views or sexual orientation) through the enquiry form or by email. We do not need it.

3.2 Data collected automatically

When you visit the website or use the web app, we and our service providers may automatically collect:

• Technical data: IP address, browser type and version, device type, operating system, language settings and approximate location (country or city level, derived from IP address).
• Usage data: pages viewed, referring page, time and date of visits, time spent, links clicked, and similar information.
• Newsletter engagement data: whether an email was delivered, opened, and which links were clicked. This is typically collected by our newsletter platform using small tracking pixels and tracked links (see Section 6).
• Server and security logs: recorded by our hosting provider to keep the Services running securely.

3.3 Data stored only on your device

Our installable web app (PWA) uses your browser's storage features:

• Saved stories: when you save a story, a reference to it is stored in your browser's local storage on your device. This data stays on your device. It is not sent to us, and we cannot see it.
• Offline cache: a service worker stores copies of pages and assets on your device so the app loads quickly and works offline. These copies contain our published content, not personal data about you.

You can clear this data at any time by clearing your browser's site data for entelera.com or uninstalling the app (see Section 6).

3.4 Data we collect from public sources

To publish news, company profiles and executive profiles, we collect information from public sources, such as company websites, annual reports, regulatory and stock-exchange filings, press releases, published interviews, conference materials, reputable news media and public professional profiles. For individuals, this is limited to professional information, for example:

• Name, job title, current and past roles and employers
• Board positions and professional affiliations
• Educational and career history as publicly reported
• Public statements, interviews and quotes
• Professional photographs that have been published for that purpose
• Publicly reported business activities, decisions and news coverage

We do not intentionally publish private contact details, home addresses, family information, or sensitive personal data in profiles. See Section 10 for more detail and how to request a correction or removal.

4. How we use personal data, and our legal bases

We use personal data only for the purposes below. Where GDPR or UK GDPR applies, we have listed the legal basis we rely on. Under India's DPDP Act, we process personal data on the basis of your consent or for a legitimate use permitted by the Act (for example, where you have voluntarily provided your data for a specified purpose and have not objected).

Where we rely on legitimate interests, we have considered your rights and expectations and believe they are not overridden. You can object (see Section 11).

We do not:

• sell or rent your personal data;
• share your personal data for third-party advertising or cross-context behavioural advertising;
• use your personal data to make decisions about you based solely on automated processing that have legal or similarly significant effects;
• add your enquiry form email to the newsletter unless you separately subscribe.

4.1 AI-assisted tools

Entelera's articles, summaries and profiles are produced with the help of AI-assisted tools working from public sources, and are subject to editorial review. When we use AI tools, we do not feed subscriber lists or enquiry form data into them except where needed to handle your request (for example, to help organise or summarise a project enquiry). Where available, we choose services and settings that do not use our data to train their models. We are responsible for what we publish, and we correct errors (see Section 10).

5. The newsletter: consent and unsubscribing

• Consent: we only send Energy Updates Today to people who have signed up. We may ask you to confirm your subscription by clicking a link in a confirmation email (double opt-in).
• What you will receive: a daily briefing at around 9:00 AM IST, and occasional emails about Entelera's Services related to your subscription. If we want to send you other kinds of marketing, we will ask first where the law requires it.
• One-click unsubscribe: every email includes a clear unsubscribe link. Unsubscribing takes one click and no login, and we process it promptly (and in any case within the period required by law, such as 10 business days under the US CAN-SPAM Act). Where supported by your email provider, we also include a one-click "List-Unsubscribe" header.
• Identification: our emails identify Entelera as the sender, use accurate subject lines, and include our postal address: [Postal address for commercial emails, to be added after registration].
• After you unsubscribe: we keep your email address on a suppression list so we do not email you again by mistake. We will not use it for anything else.

6. Cookies, local storage and similar technologies

We use a small number of technologies that store or read information on your device:

We do not use advertising or cross-site tracking cookies.

Managing these technologies: you can control and delete cookies and site data through your browser settings (usually under Privacy or Site settings). To remove saved stories and the offline cache, clear site data for entelera.com, or uninstall the web app from your device. Where we show a cookie banner, you can change your choices at any time using the [Cookie settings] link in the website footer.

Some browsers send a "Do Not Track" signal. Because there is no common standard for responding to it, we do not currently respond to it, but we do not track you across other websites.

7. Who we share personal data with

We share personal data only as described below.

7.1 Service providers (processors)

We use trusted third-party service providers to run the Services. They process personal data on our behalf and on our instructions, under contracts that require them to keep it confidential and secure and to use it only to provide their services to us. These include:

• Website hosting and content delivery [e.g. Vercel / Netlify / Cloudflare / AWS]
• Website content management (CMS) and newsletter delivery [e.g. Ghost / Beehiiv / Mailchimp]
• Website analytics [e.g. Google Analytics / Plausible / Cloudflare Web Analytics]
• Form handling and email [e.g. Google Workspace / Zoho Mail / Formspree / Tally]
• AI and automation tools used in our editorial and business workflows [e.g. provider names]
• Security, spam-prevention and backup services [e.g. Cloudflare Turnstile / reCAPTCHA]

An up-to-date list of our main service providers is available on request from privacy@entelera.com.

7.2 Other sharing

We may also share personal data:

• With professional advisers such as lawyers, accountants and auditors, under confidentiality obligations;
• If required by law, for example to comply with a court order, a lawful request from a government authority or regulator, or other legal obligations in India or elsewhere;
• To protect rights and safety, for example to prevent fraud, abuse or security threats, or to establish, exercise or defend legal claims;
• In a business change, such as a merger, acquisition, investment, restructuring or sale of assets, including the transfer of the Services to the registered legal entity once Entelera is incorporated. Any successor will be required to handle your personal data in line with this policy, and we will tell you if required by law;
• With your consent or at your direction.

8. International data transfers

Entelera is based in India, and our audience and service providers are global. This means your personal data may be stored or processed in India, the United States, the European Union or other countries where we or our service providers operate. Data protection laws in these countries may differ from those where you live.

• Transfers from India: we transfer personal data outside India only in line with the DPDP Act and any restrictions the Government of India notifies.
• Transfers from the EU/UK: where we transfer personal data of people in the EU, EEA or UK to a country that does not have an "adequacy" decision (India currently does not), we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, or another lawful transfer mechanism. Many of our providers also participate in frameworks such as the EU-U.S. Data Privacy Framework.

You can ask us for more information about the safeguards we use by emailing privacy@entelera.com.

9. How long we keep personal data

We keep personal data only for as long as we need it for the purposes in this policy, or as required by law. When it is no longer needed, we delete or anonymise it.

10. Company and executive profiles

Entelera publishes profiles of energy companies and the executives who lead them, as part of our news and industry-intelligence service.

• What we include: only professional information that is already publicly available, such as name, title, role history, board seats, education and career history as publicly reported, public statements and news coverage (see Section 3.4). We do not intentionally include private contact details, home addresses, family details or sensitive personal data.
• Where it comes from: official company sources, regulatory and stock-exchange filings, press releases, reputable media and other public professional sources. Profiles are compiled with AI-assisted tools and are subject to editorial review.
• Why: to provide accurate, useful information about the energy industry to professionals, investors and the public. In India, the DPDP Act does not apply to personal data that the individual has made publicly available themselves or that is required to be made public by law. Where information comes from other public sources, we limit it to professional facts that are already in the public domain and honour correction and removal requests as described below. Where GDPR or UK GDPR applies, we rely on our legitimate interests and on applicable journalistic and freedom-of-expression protections.
• No unsolicited marketing: we do not use profile information to send marketing to the people we profile.

If you are named in a profile, you can ask us to:

• correct information that is inaccurate, incomplete or out of date;
• update information, for example after a change of role;
• remove specific information or, where appropriate, the whole profile; or
• object to the processing of your personal data in the profile.

How to request this: email privacy@entelera.com with the subject line "Profile request", including the link to the profile, what you would like changed and why, and enough information for us to confirm you are the person named (or are authorised to act for them). We will acknowledge your request promptly, review it fairly, and respond within the timeframes in Section 11. We balance each request against the public interest in accurate reporting about the energy industry. Where we decline a request, we will explain why and tell you how to escalate it.

11. Your rights and how to exercise them

Depending on where you live, you have some or all of the following rights.

11.1 Everyone

We aim to give all users, wherever they are, the ability to:

• access a summary of the personal data we hold about you;
• correct inaccurate or incomplete data;
• delete your data (for example, by unsubscribing and asking us to erase your record);
• withdraw consent at any time (for example, by unsubscribing). This does not affect processing carried out before you withdrew it.

11.2 India (DPDP Act, 2023 and IT Act, 2000)

As a Data Principal, you have the right to:

• obtain a summary of the personal data we process about you and the processing activities, and the identities of other Data Fiduciaries and Data Processors we have shared it with;
• request correction, completion, updating and erasure of your personal data;
• withdraw consent as easily as you gave it;
• have your grievances addressed by our Grievance Officer (Section 12);
• nominate another person to exercise your rights in the event of your death or incapacity; and
• if you are not satisfied with our response, complain to the Data Protection Board of India.

We also take reasonable security practices to protect personal data as required by the Information Technology Act, 2000 and the rules made under it.

11.3 EU, EEA and UK (GDPR / UK GDPR)

You also have the right to:

• access your personal data and receive a copy;
• rectification of inaccurate data;
• erasure ("right to be forgotten") in certain circumstances;
• restriction of processing in certain circumstances;
• data portability, i.e. to receive data you provided to us in a structured, commonly used format;
• object to processing based on legitimate interests, and to object at any time to direct marketing;
• withdraw consent at any time; and
• lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office, ico.org.uk; in the EU, the supervisory authority in your country). We would appreciate the chance to resolve your concern first.

[EU representative (GDPR Art. 27), if required: name and contact details] [UK representative (UK GDPR Art. 27), if required: name and contact details]

11.4 United States

We do not sell personal information or share it for cross-context behavioural advertising. If you live in a US state with a consumer privacy law that applies to us, you may have rights to know, access, correct and delete your personal information, and to opt out of certain processing. You can exercise them using the contact details below, and we will not discriminate against you for doing so.

11.5 How to make a request

• Email: privacy@entelera.com (subject line: "Privacy request")
• Newsletter: use the unsubscribe link in any email to stop receiving it at any time.
• Saved stories / offline data: clear your browser site data or uninstall the web app.

We may need to confirm your identity before acting on a request, usually by asking you to reply from the email address we hold. You can use an authorised representative, who will need to show they are authorised. We will respond within one month (or any shorter period required by the law that applies to you). If a request is complex, we may extend this where the law allows and will tell you why. Requests are free of charge unless they are clearly unfounded or excessive.

12. Grievance Officer

In accordance with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and the rules made under them, our Grievance Officer is:

• Name: [Grievance Officer name, e.g. Aashish Arya]
• Designation: [Designation, e.g. Founder]
• Organisation: [Registered legal entity name]
• Address: [Registered address]
• Email: [grievance@entelera.com or privacy@entelera.com]
• Phone (optional): [Phone number]
• Hours: [e.g. Monday to Friday, 10:00 AM to 6:00 PM IST]

We will acknowledge your grievance promptly (where required, within 24 hours) and aim to resolve it within [15] days, and in any case within the period required by applicable law. If you are not satisfied with the outcome, you can escalate to the Data Protection Board of India or another competent authority.

13. How we protect personal data

We use reasonable technical and organisational security measures appropriate to the nature of the data, including:

• encryption in transit (HTTPS/TLS) across the website and web app;
• reputable service providers with strong security practices;
• access to personal data limited to people who need it, protected by strong passwords and multi-factor authentication;
• keeping the data we collect to a minimum; and
• regular review of our tools, access and settings.

No online service is completely secure. If a personal data breach occurs that is likely to affect you, we will notify you and the relevant authorities where required by law (including the Data Protection Board of India and, where applicable, CERT-In and EU/UK regulators).

14. Children

The Services are designed for energy-industry professionals and are not directed at anyone under 18. We do not knowingly collect personal data from children under 18. If you are under 18, please do not subscribe to the newsletter or submit the enquiry form. If you believe a child has given us personal data, contact privacy@entelera.com and we will delete it.

15. Third-party links and content

Our articles and pages link to third-party websites, such as news sources, company websites, regulators and data providers. We are not responsible for the privacy practices or content of those websites. Please read their privacy policies before giving them your personal data.

16. Changes to this policy

We may update this policy from time to time, for example when we register Entelera as a legal entity, add new features, or change service providers. We will update the "Last updated" date at the top. If we make significant changes, we will tell you clearly, for example by a notice on the website or in the newsletter, and ask for your consent again where required by law.

17. Contact us

If you have any questions about this policy or how we handle your personal data:

• Privacy enquiries: privacy@entelera.com
• General enquiries: hello@entelera.com
• Post: [Registered legal entity name], [Registered address]

Entelera, operated by Aashish Arya (founder), India.