For purposes of this policy, “personal information” refers to information that could be used to identify you, such as your name, phone number, and email address; “services” refers to Enigma’s services accessed via its websites; and “service provider” refers to third parties who provide services to Enigma.
Collecting your personal information
Enigma does not collect personal information unless you provide it. However, you may be required to provide certain personal information to us when you contact us or use our websites, such as by emailing us, accessing or providing information on or to our websites, or accessing information provided to us by third parties. [If you create a personal profile on one or more of Enigma’s websites, Enigma may collect, store, and use the information that you provide.]
In addition, information about your computer hardware and software may be automatically collected by Enigma or its service providers, through the use of tracking technologies such as cookies, web beacons, embedded scripts, locations-identifying technologies, file information, etc. Thus, Enigma or its service providers may automatically collect data such as your IP address, browser types, domain names, etc., in order to maintain the service quality and to improve and monitor the user experience of persons who access Enigma’s websites. For example, Google Analytics, a web analytics service that tracks and reports website traffic, may be used by Google to collect, track, and monitor the use of Enigma’s services. This data is shared with other Google services and may be used to contextualize and personalize the ads of its own advertising network. You can opt-out of having your information available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information, please visit the Google privacy web page: https://policies.google.coom/privacy.
Using your personal information
In general, the personal information that you provide to us is used to help us communicate with you. For example, Enigma uses personal information to contact users in response to questions, solicit feedback, provide technical support and inform users about matters of interest to them. In addition, Enigma may collect and use your personal information to manage and operate its business and/or deliver the services that you have requested; to communicate with you; to fulfill or meet the reason for which the personal information was provided; to improve, analyze, and market its services; to perform statistical analyses; to comply with legal obligations and defend, protect, or enforce its rights; and to assist in managing and performing its contracts or other business dealings.
Enigma may also keep track of the behavior of users of its websites, to maintain the quality of its services and to provide general statistics regarding the use of its websites.
Retaining and securing your information
Enigma will retain your information as long as necessary to carry out its business with you, and to the extent necessary to comply with its legal obligations.
Enigma implements security measures that are designed to protect information from unauthorized access. Enigma recognizes the importance of keeping your information secure, but you acknowledge that no method of electronic transmission or storage is completely secure.
Sharing information with third parties
Enigma may share personal information with third parties such as affiliated companies, business partners, service providers, or your employer. For example, Enigma may contact you or a third party about a particular matter that may be of interest to you or the third party.
Enigma may disclose your personal information, without notice, if required to do so by law or in its good faith belief that such action is legally necessary, to enforce contractual terms, including investigating potential violations, to address fraud, security, or technical concerns, or to protect against harm to the rights, property or safety of Enigma or others.
Exercising your rights
If you wish to understand what personal information Enigma has about you, including the categories and specific pieces of personal information collected, the categories of sources of personal information collected, the purposes of the collection and uses of information, the categories of third parties with whom Enigma may share the information and the categories of information that Enigma may share with third parties, or if you wish to delete personal information from our records, please notify Enigma by providing a request that provides sufficient information for Enigma to verify your identity and authority to make the request, and to confirm that the personal information relates to you. However, please note that Enigma may not be able to comply with your request in certain circumstances, or if deletion of the information would not be permitted by law.
[If you do not wish to be contacted by Enigma for marketing purposes, you may unsubscribe from such communications by following the unsubscribe directions in the marketing email.]
In certain circumstances, you may have the right under certain laws to opt out of sale of your personal information to third parties. If you wish to exercise such a right, please notify Enigma by providing a request that provides sufficient information for Enigma to verify your identity and authority to make the request, and to confirm that the personal information relates to you.
Any requests with regard to personal information must be sent as instructed in the section below entitled “Contacting us.”
Enigma does not discriminate against persons exercising their rights under this policy.
Protecting children’s privacy
Enigma’s websites and services are not directed to persons under the age of 13. Enigma does not knowingly collect or solicit information from anyone under the age of 13. If you believe that Enigma has collected such information, please contact us immediately.
Protecting privacy rights for European Union users
Enigma may process personal information under the following conditions:
• Consent: you have given consent for processing personal information for one or more specific purposes.
• Performance of a contract: Provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing personal information is necessary for compliance with a legal obligation to which Enigma is subject.
• Vital interests: Processing personal information is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in Enigma.
• Legitimate interests: Processing personal information is necessary for the purposes of the legitimate interests pursued by Enigma.
In any case, Enigma will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
• Request access to your personal information. You have the right to access, update or delete the information Enigma has about you. If made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact Enigma to assist you. This also enables you to receive a copy of the personal information we hold about you.
• Request correction of the personal information that Enigma holds about you. You have the right to have any incomplete or inaccurate information that Enigma holds about you corrected.
• Object to processing of your personal information. This right exists where Enigma is relying on a legitimate interest as the legal basis for its processing and there is something about your particular situation, which makes you want to object to the processing of your personal information on this ground. You also have the right to object where Enigma is processing your personal information for direct marketing purposes.
• Request erasure of personal information. You have the right to ask Enigma to delete or remove personal information when there is no good reason for Enigma to continue processing it.
• Request the transfer of your personal information. Enigma will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Enigma to use or where Enigma used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent to use your personal information. If you withdraw your consent, Enigma may not be able to provide you with access to certain specific functionalities of the services.
You may exercise tour rights of access, rectification, cancellation and opposition by contacting Enigma. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, Enigma will try to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about Enigma’s collection and use of your personal information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Changing this policy
Version No. 1
Effective as of 2/10/2021.