Privacy Policy

Introduction

We are committed to protect your privacy and this statement means a-lot to us. We adhere to the guidelines of data protection set forth by the European Union in the General Data Protection Regulation (GDPR)- Regulation (EU) 2016/679 in EU law on data protection and privacy for all individual citizens of the European Union (EU) and the European Economic Area (EEA).

This privacy policy helps you understand

  • what information we collect.
  • purpose of collecting that information.
  • sources of collecting information.
  • choices you have in relation to that information.

Recitals

Throughout the policy some terms are being used repetitively in italics, and are recited below

Terms Inclusions
Websites
App, Apps, Products Enpass password manager or any other product downloaded from any App Store or our Websites.
Services Collectively both Websites and Apps/Products
We, Sinew, us, ur Sinew Software Systems Pvt Limited and all its services
App User, Enpass User User of our Apps
User, You Any person using our Websites or Apps (together Services)
Personal Information, Personal Data First name, last name, e-mail address
Customer Support Data Any kind of personally identifiable information (PII) received by our support staff explicitly through any of support channels.
Registration Information Email address, First and last name
Technical Information
  1. Device details for registered users
    – Device name
    – Device ID (UDID)
    – Device type
    – Installed OS and version
    – Device Language
    – Device Country
  2. Purchase details provided by Apple, Google and Microsoft from App Store
Anonymous Data Any data, used by Services, and is accessible to us but alone or combined with any other information can’t be used to
identify any User.
Server Data Used collectively for Personal Information, Personal Data, Customer Support Data, Registration Information,
Technical Information stored and processed on our servers.
Enpass Data, Your
Data, Secured Data
Any kind of your personal information that you have stored in Enpass, and is protected cryptographically to remain
accessible to the User only. Under any circumstances, we can’t decrypt this data.
Master Password a secret word or phrase in combination with any key that is mandatory to gain access to the Secured Data stored in
Enpass.
App Store/ App Stores Marketplace from where Apps can be downloaded or installed.

1. Information we have about you

We collect very limited information about you as a User. Our vision is to provide you with the Products which are strictly offline in nature (where we do not store any of your Secured Data on our servers).

We get information about you only from our following services:

1.1 Websites

While using some parts of our Websites, i.e Newsletters, Press releases and Beta Program etc, you provide us with your Personal Information. All the information provided on these parts is stored or our servers only.

To use our Forums (discussion.enpass.io), you might need to create account there, using your Personal Information. During the time of account creation on our forums, this data has to pass through Anti-Spam service and is processed by them.

1.1 Google Analytics – Browsing data, session and IP address (only for the websites) (see google Policy)

1.2 Cookies

1.2 Apps

Our Apps do not send any of your information outside them without your consent or until you provide it explicitly.

1.2.1 While doing Registration

While registering with us through Enpass, you provide your Email address to us. When you Sign-in through Apple, Google or any other partner, we do receive and store your first and last name too. Along with the Registration Information, we do collect Technical information (see Recitals above) related to your device and purchase receipts fetched from App stores.

1.2.2 Specific features

To make use of some features, Enpass might need to send related information outside Enpass through secured channels. Whenever this happens, you’re explicitly notified and have full control to quit from using that feature.

  • Website Icons- On enabling Website Icons from Enpass, all the saved URLs are sent to our server as Anonymous Data (see Recitals above) after your allow it to do so.

1.3 Customer Support desk

We offer customer support through emails, website, forums and Social media. All the communication happened through emails, websites and forums is stored on our servers and may remain until explicitly asked for deletion. For support through social channels (not limited to Twitter and Facebook), please refer to their privacy policies.

2. Information that we NEVER collect

Important information about you in which we are not interested in

  • At any point of time, we do not collect/store any of the information that you have saved in the Apps (Enpass). All your Secured Data (Logi ns, credit cards or any kind of data that you stored in Enpass) is stored locally and is never sent to our servers (Encrypted or Unencrypted).
  • We never ask for your Master Password or any other Secured Data.
  • No Analytics or tracking on the Apps.

3. How we use your information

3.1 Use of Personal Information

Sinew uses your Personal Information to

  • Identify you as a User and let you unlock the features of Enpass across devices.
  • To send communications about account related activities (Activation/Deactivation of devices).
  • To communicate about product and related services through emails and newsletters.
  • To provide support for the queries or services you requested.

3.2 Use of Technical Information

  • For safety of your account
    – By monitoring the devices associated with your account.
    – Notifying you via email for any device addition.
  • To make our services better by understanding the spectrum of devices and operating systems being used.
  • Purchase related Technical Information is used to let you unlock the Enpass features across devices.

As long as you are using our services, we retain the right to hold and use Server Data to provide our services, troubleshoot problems, analyze the performance and demands on our services.

4. Your rights regarding data

4.1. Server Data

We fully adhere to GDPR laws and you have the following rights with respect to your Server Data stored with us:

  • The right to request a copy of your personal data which we hold about you.
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date.
  • The right to request to erase your personal data where it is no longer necessary for us to retain such data, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  • The right to withdraw your consent to the processing at any time, where we rely on your consent to process your data. This includes cases where you wish to opt out from marketing communications that you receive from us.
  • The right to request that we provide you with your data and where possible, to transmit that data directly to another data controller, where the processing is based on your consent or is necessary for the performance of a contract with you, and in either case we process the data by automated means.
  • The right to restrict our processing of your personal data where you believe such data to be inaccurate, our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
  • The right to object to us using your personal data, where the legal justification for our processing of your personal data is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of legal claims.
  • The right to lodge a complaint regarding our processing of your data, with the competent authority where you reside or in which your data is processed.

4.2 Enpass Data

The data stored in Enpass is solely yours and is only under your control. We have no access or control over that as it is stored on your device only. You can erase that data from your devices and clouds you have linked to sync data.

To know about your control over the data stored with any associated third-party service like cloud accounts, social media channels and anti-spam service, it’s your responsibility to check their privacy policy.

5. Safety of your data

To help protect the privacy of your Server Data, we maintain physical, organizational, technical and administrative safeguards. However we update and test our security technology on an ongoing basis, we cannot guarantee the security of Server Data. All the Server Data is kept confidential and is only available to authorized personnel. Server data includes only your name, email and Technical Information that is stored on our servers. Your Enpass Data is not a part of it as it is only in your possession.

6. Sharing of your data

We will not sell, rent or lease any your Personal Information or Technical Information to others. Sometimes, and with your consent, we share your Personal Information (Name, Email only) with the third-parties for which you were aware that we have to; like with Apple and Microsoft for the beta version delivery through TestFlight and PackageFlight.

7. Link to other websites

Our Services may/might provide links to third-party web-sites, such as those of our business partners, online advertisers and sellers. We make no representations or warranties about the policies of third party websites that are linked to our Services. You should review their privacy policies to learn more about what, why, and how they collect and use personally identifiable information.

8. Underage Enrolment

Our Services are not directed to children and we do not intentionally collect any personally identifiable information from children under the age of sixteen (16) years of age. As a parent or guardian if you becomes aware that your child has provided us with any personally identifiable information, you can ask us to remove that by writing us at support@enpass.io. We will remove that information from our servers as soon as possible

9. Changes in this Policy

This Privacy Policy may change from time to time. We reserve the right to amend it at any time, for any reason. In some cases, it might not be possible for us to reach you to notify about the changes and they may happen without any notice to you. You should check this page frequently to see any changes that may have been made to it.

10. Contact us

If you have any questions about this Policy, please reach us at support@enpass.io or write to us at

1115, Tower-B4, Spaze i-Tech Park,
Sector 49, Gurugram, Haryana,
India-122018

Last updated on November 5, 2019