Privacy Policy
Last Updated: August 4, 2025
This is the Privacy Policy of Entabeni Systems Inc. ("Entabeni", "Company", "we", "our", or "us"), which provides point-of-sale and e-commerce solutions and access control services (collectively, the "Services") to ski resorts. Entabeni is an "Affiliate" (as defined in N.H. Rev. Stat. Ann. § 507-H:1) of Indy Ski Pass LLC, which has its own Privacy Policy available at https://www.indyskipass.com/privacy-policy.
Entabeni respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes how we collect, process, retain, and disclose personal information about you, our:
- Our ski resort customers who use the Services to power their business (each, a "Ski Resort");
- Individuals who make purchases from Entabeni-powered businesses (each, an "End User"); and
- Visitors to our website located at https://www.entabenisystems.com/ (the "Website") and individuals who provide information to us via email or other electronic message ("Visitors").
This Privacy Policy does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Company or any third party (including our Affiliates and subsidiaries) that does not link to this Privacy Policy;
- us in an employment capacity; or
- any third party (including our Affiliates and subsidiaries).
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Website and Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website and Services after we make changes as described here is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
Children's and Minors' Data
Our Website and Services are not intended for, and we do not knowingly collect any personal information from, children under the age of 18. If we learn we have collected or received personal information from a child under 18 years old without verification of parental consent, we will delete that information.
Please note that the Ski Resorts who utilize our Services may collect information from children under the age of 18 and such Ski Resorts are the controller of such information.
How We Collect Information
We may collect information in the following ways:
- when you access our Website;
- when you communicate with us, including via email and other electronic messages, between you and the Company; and
- when you interact with our advertising on third-party websites and services, if that advertising includes links to this Privacy Policy.
Categories and Sources of Personal Information
The following table contains the categories and sources of information that we may collect from you and that we have collected over the last 12 months. Please note that this table only discloses personal information that we collect from Ski Resorts and Visitors and not personal information that Ski Resorts collect from End Users, which Entabeni does not collect and for which Entabeni is a processor as described in "Entabeni and End Users" below.
| Category | Examples | Personal Information Collected | Source |
|---|---|---|---|
| A. Identifiers | Real name, postal address, email address, account name | YES | Ski Resorts, Visitors |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, address, telephone number. Some personal information included in this category may overlap with other categories. | YES | Ski Resorts, Visitors |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO | N/A |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | Ski Resorts |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | N/A |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES | Visitors |
| G. Geolocation data | Physical location or movements | NO | N/A |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | N/A |
| I. Professional or employment-related information. | Current or past job history or performance evaluations | NO | N/A |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | N/A |
| K. Inferences from personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | N/A |
| L. Age or date of birth | NO | N/A |
M. Sensitive Personal Information
| Category | Examples | Collected | Source |
|---|---|---|---|
| M.1 | Social security, driver's license, state identification card, or passport number | NO | N/A |
| M.2 | Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | NO | N/A |
| M.3 | Personal information that reveals consumer's precise geolocation | NO | N/A |
| M.4 | Personal information that reveals a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership | NO | N/A |
| M.5 | Personal information that reveals the contents of a consumer's mail, email, and text messages unless company is the intended recipient of the communication | NO | N/A |
| M.6 | Personal information that reveals consumer's genetic data | NO | N/A |
| M.7 | Personal information collected and analyzed concerning a consumer's health | NO | N/A |
| M.8 | Personal information collected and analyzed concerning a consumer's sex life or sexual orientation | NO | N/A |
Information Collected Automatically
This section provides more detail about Category F in the above table.
Web Browser Cookies
We collect information about how you use our Website by setting and accessing cookies on your computer. A cookie is a small piece of information sent by our Website that is saved on your storage drive by your computer’s browser. The cookie holds information our Website may need to personalize or enhance your experience and to gather statistical data, such as which pages are visited, the Internet provider’s domain name and the addresses of the sites visited immediately before coming to and immediately after leaving our Website. The information in the cookie lets Entabeni trace “clickstream” activity (i.e., the paths taken by visitors to our Website as they move from page to page) to enable us to better serve our customers by revealing which portions of our Website are the most popular. From time to time, other companies may help us with data research and analysis, but they will be prohibited from using that data for any other purpose. You may disable cookies on your browser. Please review your browser’s instructions for doing so. Note that certain features of the Website may not be available if you delete or reject cookies.
Information from Ski Resorts
Through the use of our Services, Ski Resorts gather information about End Users. Entabeni receives information from Ski Resorts utilizing our Services. For more information, see "Entabeni and End Users".
Purpose for Collecting Personal Information
Your personal information is collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes. Collected information data is relevant to and not excessive for the purposes for which they are collected and used. We may use your personal information for the following purposes:
- Provide you with our Services as you request
- Answer your questions
- Manage and optimize the customer relationship by improving our Website and Services
- To better understand your preferences by analyzing your behavior on our Website
- Send you information as requested by you
- To communicate with you about the Services
- To personalize Website content
- To process orders or other transactions
- To comply with our legal or contractual obligations and to resolve disputes
- To respond to law enforcement, court orders or other government requests under applicable law
Personal Information Sold or Shared
Entabeni does not "sell" or "share" your personal information as such terms are defined in the California Consumer Privacy Act.
Personal Information Disclosed to Third Parties for Business Purposes
We may disclose personal information we collect to third parties for business purposes including the following:
- to prevent or investigate suspected fraud, threats to physical safety, illegal activity, or violations of a contract or our policies;
- to help us conduct marketing and advertising;
- to comply with legal requirements, or to respond to court orders, or other similar government demands; and/or
- in connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or reorganization, we will share your personal information with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
Data Subject Rights
a. Right to Know What Personal Information is Being Collected
You have the right to request the following information:
- Categories of personal information collected about you
- Categories of sources from which personal information is collected
- The business or commercial purpose for collecting, selling, or sharing your personal information
- Categories of third parties to whom we disclose your personal information
- The specific pieces of personal information we have collected about you
b. Right to Delete Personal Information
You have the right to request that we delete any personal information about you that we have collected from you.
c. Right to Correct Inaccurate Personal Information
You have the right to request that we correct your inaccurate personal information if we maintain inaccurate personal information about you.
d. Right to Know What Personal Information is Sold or Shared and to Whom
You have the right, if Entabeni sells or shares your information, to request that we disclose specific categories of personal information collected and shared.
- Categories of personal information that we collected from you.
- Categories of personal information that we sold or shared about you and the categories of personal information for each category of third parties to whom personal information was sold or shared.
- Categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
e. Right to Opt Out of Sale or Sharing of Personal Information
You have the right to direct Entabeni, if we sell or share your personal information to third parties, not to sell or share your personal information. We currently do not sell or share your personal information to third parties.
f. Right to Limit Use and Disclosure of Sensitive Personal Information
If Entabeni uses your sensitive personal information, you have the right to direct Entabeni to limit the use of your sensitive personal information to the use which is necessary to perform the Services.
g. Right of No Retaliation Following Opt Out or Exercise of Other Rights
We may not discriminate against you if you exercise any of your rights as described in this Section.
h. Right to Data Portability
You have a right to obtain personal information in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the information to another entity without hindrance. You may exercise this right no more than two times per calendar year.
Methods for Exercising Data Subject Rights
You can submit a request to exercise one or more of your data subject rights by emailing us at [email protected].
After we receive your request, we will determine if the request is a verifiable customer request before acting on the request. You must provide enough information for us to be able to verify that it is the proper person making the request. We have 45 days in which to take action on your request. If we run into issues in honoring your request, we will notify you within those 45 days. The original 45-day period may be extended by 45 days if reasonably necessary. We will inform you, without delay, of the reasons, if we decide not to take action on your request. We will also inform you if you have rights to appeal our decision.
If you use an authorized agent to submit a request and the authorized agent does not provide a proper power of attorney, we may require you to either (1) verify your identity directly with us, or (2) directly confirm with us that you provided the authorized agent permission to submit the request.
California Shine the Light Law and Do Not Track
If you are a California resident and have an established business relationship with us, you may request that we not disclose your personal information to third parties for the third parties’ own direct marketing purpose (as defined in California Civil Code section 1798.83). Please note that we do not currently disclose your personal information to third parties for the third parties’ own direct marketing purpose.
Note that we do not currently respond to web browser "Do Not Track" signals.
Entabeni and End Users
Entabeni provides Services to Ski Resorts. If you are an End User who provides your personal information through our Services to a Ski Resort, Entabeni acts as processor or service provider of your personal information on behalf of such Ski Resort. To exercise your data subject rights with regard to such Ski Resort, you need to directly contact the Ski Resort you interacted with. For more information about how Ski Resorts utilizing our Services collect and use your information when you visit and make purchases, review the specific Ski Resort’s terms and privacy policy.
Data Security
We apply commercially reasonable and appropriate administrative, technical, and physical safeguards to protect the confidentiality, integrity, and availability of your personal information. Such safeguards protect against unauthorized access, alteration, disclosure, unlawful processing and accidental loss, destruction, or damage of your personal information. Although these safeguards reduce the risk of adverse effects to the confidentiality, integrity, and availability of your personal information, they cannot ensure or guarantee against the possibility of a security incident.
Data Retention
Your personal information is retained for as long as reasonably necessary and proportionate to achieve:
- The purpose(s) for which your personal information was collected and processed
- Another disclosed purpose that is compatible with the context in which your personal information was collected
International Transfer of Your Personal Information
We are a global business and some of our Ski Resorts and Visitors are located outside of the United States. As a result, it may be necessary for the personal information that we collect from you to be transferred to or accessed from outside your local jurisdiction in order for us to provide our services. If we do this, we have procedures in place to ensure your data receives the necessary protections. Any transfer of your personal information will follow applicable laws and we will treat the information according to the principles set out in this Privacy Policy.
Links to Third Party Websites and Services
Our Website and Services may contain links to third-party websites, services, or resources that are not covered under this Privacy Policy. Upon visiting or using those third-party websites, services, or resources, we recommend that you review their privacy policy, terms and conditions, and terms of use before providing your personal information.
For example, almost every Ski Resort using the Services also uses non-Entabeni services to support their business (for example, sales channels, payment gateways, or shipping providers). Entabeni doesn't control how these services use your personal information, and you should review any other service you use to make sure it meets your privacy expectations.
Transfer of Corporate Assets
If Entabeni is acquired by or merged with a third-party entity, Entabeni reserves the right to transfer or assign the personal information you provided to us as part of such merger, acquisition, sale, or other change of control to the new entity. In the event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditor’s rights generally, we may not be able to control how your personal information is processed. If such a situation arises, Entabeni would request that all applicable privacy laws and protection standards at least as stringent as Entabeni’s be applied to your personal information originally in our possession. In the event of a transfer of corporate assets, the information regarding the transfer will be posted on our Website.
Changes to Our Privacy Policy
We reserve the right to update this Privacy Policy to accurately disclose changes as necessitated by applicable laws and other events. If those changes are material in nature, we will notify you by a notice placed on our Website, a notification within our Services, and/or by electronic mail.
Contact Us
If you have any questions about your privacy or security on our Website or through the use of our Services, please email us at [email protected] or write to us at: Entabeni Systems Inc., 21 Ten Mile Drive, Granby, Colorado 80446 USA.