Privacy Notice | Enpass

Privacy Notice

Effective Date: May 28, 2020
Notice Version: 2.0

Data Controller Contact Information:

Enpass Technologies Inc.
913 N. Market Street,
Wilmington,
DE 19801

Enpass Technologies Inc and its business partners believe in high standards when protecting the information provided by our users and customers. This privacy notice applies to the information that we collect from you when you use our website(s), www.enpass.io, discussion.enpass.io, and our software for mobiles and desktops applications, collectively and hereinafter called “Platform.”

Our privacy notice tells you what personal data and nonpersonal data we may collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our privacy notice also explains certain legal rights that you have with respect to your personal data.

Definitions

‘NONPERSONAL DATA’ (NPD) is information that is in no way personally identifiable.

‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data. (GDPR) means General Data Protection Regulation. Even though the definition of personal data is broad, we only collect your first name, last name and email address to use the product. However, if you buy from our website we may be provided with additional information by the payment processor. All your secured data like logins, credit cards or any kind of data that you store in our platform is stored locally and is never sent to our servers encrypted or unencrypted.

‘MASTER PASSWORD’ is a secret word or phrase in combination with any key that is mandatory to gain access to the Secured Data stored in our Platform.

Note: We never ask for your master password or any other secured data.

Topics Covered in Our Privacy Notice

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Generally, you control the amount and type of information that you provide to us when using our Platform.

Our Legal Basis for Collecting and Processing PD

Our legal basis for collecting and processing your PD when you buy our products, services, or fill out our contact or opt-in form is based on and the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter is based on consent.

Automatic Information

We automatically receive information from your web browser or mobile device. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, country, language, and data about your browsing activity when using our Platform. We use all this information to analyze trends among our users to help improve our Platform.

When Entering and Using Our Platform

When you enter and use our Platform and agree to accept cookies, some of these cookies may contain your PD.

At User Registration

When you register as a user, we collect your first and last name and email address.

When Buying Product

All the purchases from our website are processed by a third-party service provider, FastSpring. We may be able to access the name, address, last four digits of credit card and phone number associated with a payment method on the payment provider service, but complete credit card information is available only to our payment processors. We do not receive or store any billing data if you pay through any app store.

Our Use of Cookies

Our websites use cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well. Please see our Cookie Policy.

When Providing Support

When we provide support for you, we may collect some personal data in order to help you.

Partners

You may have purchased one of our mobile apps through any of our partners. These partners may provide your PD to us so we can activate your license.

Gravatar.com

We use a service from www.en.gravatar.com that allows you to have an image that represents you when you are online. It is a picture that appears next to your name when you interact with different Gravatar-enabled websites and mobile apps. To make this happen a tracking mechanism is used that follows you on the Internet.

Cross-Device Tracking

We may track your behavior from device to device by gathering the following data

  • Device name
  • Install ID (UDID)
  • Device type
  • Installed OS and version
  • Device Language
  • Device Country

We use the information we get from this technology to analyze traffic behavior, improve our marketing and advertising.

Contacting us

Our Platform contains contact forms that enable visitors to communicate with us live online or offline by email. In some cases visitors can communicate with us without buying our products and services. At those times, we may collect some or all the following information: your email address, first name, last name, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.

Our Community Forums and blogs

Our platform contains discussion forums “discussion.enpass.io” where you provide us with your PD to create an account. Our discussion forums use a third-party software “CleanTalk” to reject spam postings, and your PD will be shared with them while creating an account. Read their privacy policy here.

Also, we may provide us with your PD when you comment on our blog posts running on WordPress. There we use a service called “Akismet” for spam-filtration and they may have your PD. See their privacy policy here.

Analytics

Our Platform uses analytics and crash reporting services from several companies to collect information about the use of our Platform. Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our Platform. Analytics collects information such as how often users visit our Platform, what pages they visit, when they do so, and their IP addresses. We use the information we get from analytics to improve our Platform.

Sharing Your Information When You Login Using Social Media Websites

You may share your information with third parties such as Facebook.com, Twitter.com, YouTube.com, Instagram.com, and Google.com. If you decide to login to our Platform using these third parties or other social media websites, you are agreeing to let us use and store your profile information from those websites to make better use of any social media features on our Platform. This sharing of information helps us provide you a better experience when using our Platform and services. It also provides us with useful information such as visitor traffic. If you use any of the social sharing icons on our Platform to share our information, you may also be sharing your personal information through social media websites.

What Happens If You Don’t Give Us Your PD

If you do not provide us with enough PD, we may not be able to provide you all our products and services. However, you can access and use some parts of our Platform without giving us your PD.

HOW YOUR INFORMATION IS USED AND SHARED

We use the information we receive from you to:

  • provide our products and services you have requested or purchased from us
  • resolve problems, disputes, and provide technical support
  • personalize and customize our content
  • make improvements to our Platform
  • contact you with updates to our Platform, products, and services
  • contact you with marketing and advertising that we believe may be of interest to you.

Communications and Emails

When we communicate with you, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our Platform or offers from us or our affiliates unless you have opted out of receiving such information.

Sharing Information with Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. We may give your PD to third-party service providers whom we hire to provide services to us.

Sharing Information With Business Partners

We may share your PD with our business partners. The business partners include general business partners, affiliates, and joint venture partners. We share this information with them so that they can send you information about our products and services as well as their products and services. When you choose to take part in our services and/or offerings, you are authorizing us to provide your email address and other PD to our business partners. Please understand that when we share your PD with our business partners, your PD becomes subject to our business partners’ as well as our privacy notice.

Push Notifications

If you sign up for our services you are giving us your consent and authorize us to send you push notifications. You are not required to give us your consent for these push notifications. However, withholding your consent may interfere or prevent us from providing some or all of our services to you.

Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal processes; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

PLEASE NOTE THAT IN ANY CASE YOUR SECURED DATA LIKE YOUR MASTER PASSWORD AND ANY DATA SAVED IN ENPASS CAN’T BE ACCESSED BY ANYONE.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing our Platform to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

RETAINING AND DESTROYING YOUR PD

We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.

UPDATING YOUR PD

You can update your PD using services found on our Platform. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.

You have the right to revoke your consent for us to use your PD at any time. Such opt-out will not affect disclosures otherwise permitted by law including but not limited to disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law.

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES

If any postings you make on our Platform contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.

DO NOT TRACK SETTINGS

Some web browsers have settings that enable you to request that we do not track your movement within our Platform. Our Platform does not obey such settings when transmitted to and detected by our Platform. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

Our Platform may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.

PROTECTING CHILDREN’S PRIVACY

Even though our Platform is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our Platform. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our Platform, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our Platform, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.

OUR EMAIL POLICY

You may receive email communications from us regarding changes to our services, promotional materials and important security-related events. You can any time opt-out of the receipt of email communications for marketing and promotional material by writing to us at support@enpass.io. In the event you unsubscribe from receiving emails regarding marketing and promotional material, we may still send email to you with a one-time password, any security issue related information, purchase confirmation or customer support matter. We will never sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.

OUR SECURITY POLICY

We have built our Platform using industry-standard security measures and authentication tools and use services like Amazon Web Services (AWS) to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our Platform and not share it with anyone.

TRANSFERRING PD FROM THE EUROPEAN UNION

PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union customer or user, with your consent your PD may be transferred to the United States or other countries outside the European Union when you request information from us. When you buy goods or services from us, we will use your PD for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process, or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our Platform, services, or products you agree to the transfers of your PD described within this section.

YOUR RIGHTS

If you want to exercise any of your rights included in this privacy notice, contact us by using the information at the top of this privacy notice.

You Have the Right Not to Have Your Personal Information Sold

With the exception defined in Disclosures to Successors, we never sell your PD. If you wish to make this request, please email us at support@enpass.io.

Your Rights Under the GDPR

When using our Platform and submitting PD to us, you may have certain rights under the GDPR if you reside or are in any of the countries of the European Union. Depending on the legal basis for processing your PD you may have some or all of the following rights:

  • The Right to Be Informed – You have the right to be informed about the PD that we collect from you and how we process them.
  • The Right of Access – You have the right to get confirmation that your PD are being processed and you have the ability to access your PD.
  • The Right to Rectification – You have the right to have your PD corrected if they are inaccurate or incomplete.
  • The Right to Erasure (Right to Be Forgotten) – You have the right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing them.
  • The Right to Restrict Processing – You have the right to ‘block’ or restrict the processing of your PD. When your PD are restricted, we are permitted to store your data, but not to process them further.
  • The Right to Data Portability – You have the right to request your PD that you provided to us and use them for your own purposes. We will provide your data to you within 30 days of your request. Contact us using the information at the top of this privacy notice to request your PD.
  • The Right to Object – You have the right to object to us processing your PD for the following reasons:
    • Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
    • Direct marketing (including profiling)
    • Processing for purposes of scientific/historical research and statistics
    • Rights in relation to automated decision-making and profiling.
  • Automated Individual Decision-Making and Profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.
  • Filing a Complaint with Authorities – You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our Platform so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases your continued use of our Platform, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.