Privacy Notice

Effective Date: Sept 10, 2024

Data Controller Contact Information

Enpass Technologies Inc.
1201 North Market Street,
Suite 111, Wilmington
Delaware 19801

Email: support@enpass.io
Phone: +1 302 208-2510

Enpass Technologies Inc and its business partners believe in high standards when protecting information provided by our users and customers. This privacy notice applies to the information that we collect from you when you use our Platform, https://www.enpass.io, https://discussion.enpass.io, https://support.enpass.io, Enpass Admin Console and our software for mobiles and desktops applications, collectively and herein after 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 disclose them, how you can access and change them, and how you can limit our disclosing of them. Our privacy notice also explains certain legal rights that you have with respect to your personal data.

Definitions

‘NONPERSONAL DATA’ (NPD) means any 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 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.
Even though the definition of personal data is broad, we only collect your first name, last name and email address. For Enpass Business users, using Enpass-hosted Hub, we store additional data on our servers. 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.

YOUR RIGHTS

Contact us using the information at the top of this privacy notice to exercise any of your legal rights contained within this privacy notice. We will respond to your request within 30 days after receiving it. Occasionally it may take longer for multiple requests or complex circumstances.

With the exception defined in our Disclosures to Successors provision, we never sell your PD.

When using our Platform and submitting PD to us, you have certain rights under privacy laws in the United States including the California Consumer Privacy Act (CaCPA), the California Privacy Rights Act (CPRA), and privacy laws of other countries including the European Union General Data Protection Regulation (the EU GDPR), the UK General Data Protection Regulation (the UK GDPR), the UK Data Protection Act of 2018, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other global privacy laws. Even if not listed here, we will make reasonable efforts to honor data subject access requests even though we may be under no legal obligation to do so. However, we reserve the right to decline any data subject access request that we are not legally obligated to comply with. Your rights include but are not limited to the following:

1. The right to equal service, price, and not be discriminated against even if you exercise your privacy rights.
2. The right to one or more means where you can submit requests under this privacy notice including (at minimum) a toll-free telephone number and an email address if the business operates a storefront and a website. If the business operates only an Internet website, then it must have a dedicated email address where you can submit requests for information required to be disclosed by law.
3. The right to know whether your PD is sold or disclosed and to whom.
4. The right to request that we do not sell any of your PD.
5. The right to be informed about the PD that we collect from you and how we process them.
6. The right to get confirmation that your PD are being processed and you can access your PD.
7. The right to have your PD corrected if they are inaccurate or incomplete.
8. The right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing them. However, the right to deletion is not absolute and can be overridden to continue data processing in some cases where we still have a legal ground or overriding legitimate interest to process your data.
9. The right to ‘block’ or restrict the processing of your PD. When your PD are restricted, we are permitted to store your PD, but not to process them further.
10. The right to request the PD that you provided to us and use them for your own purposes. Upon express request, we will provide your data to you or another service or product provider within 30 days of your request subject to commercial and industrial secrets.
11. 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 and targeted advertising (including profiling);
    • processing for purposes of scientific/historical research and statistics.
12. 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.
13. The right that we limit the collection of your PD to that which is adequate, relevant and reasonably necessary with the purposes for which the data is processed.
14. The right that we do not process your PD for purposes that are neither reasonably necessary nor compatible with the disclosed purposes for which such personal data is processed, as disclosed to you unless the controller obtains your consent.
15. The right to designate an authorized agent to make a request on your behalf. When designating an authorized agent, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.
16. The right to file a complaint with supervisory authorities if your information has not been processed in compliance with your rights under privacy laws.

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 us form, opt-in form, or signup for our newsletter is based on and the necessity for the performance of a contract or to take steps to enter into a contract.

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.

Our Use of Cookies

Our Platform 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.

When Providing Support

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

Partners and Affiliates

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

Device Data from app usage

To enhance and improve our product, we gather certain device data to analyze apps usage. This information includes:

• Device name
• Install ID (UDID)
• Device type
• Installed operating system and version
• Device language
• Device country
• IP address
• Apple Identifier (if you choose to sign-in with Apple)
• Google Identifier (if you choose to sign-in with Apple)
• Browser user-agent

Enpass-hosted Hub for Enpass Business

This is applicable only for our Enpass Business users using our Enpass-hosted Hub where you send some additional PD to us. For more information about the data we collect when you use Enpass-hosted Hub, please visit: https://www.enpass.io/data-on-enpass-hub

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 ” https://discussion.enpass.io ” where you provide us with your PD to create an account.

Analytics

We do not use analytics in our apps.
Some parts of our Platform use Google Analytics and Clearbit to collect information about the use of our Platform.

Google Analytics may collect information from users such as age, gender, interests, demographics, how often they visit our Platform, what pages they visit, and what other websites they have used before coming to our Platform. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and Platform. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our Platform, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our Platform.

• For more information on how Google collects and processes your data visit: https://www.google.com/policies/privacy/partners/

Clearbit use pixel tags to collect IP addresses, which may then be used to analyze web traffic and derive insights.

• For more information on how Clearbit collects and processes your data visit: https://clearbit.com/privacy-policy

At User Registration

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

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 with all our products and services. However, you can access and use some parts of our Platform without giving us your PD.

HOW YOUR PD IS USED AND DISCLOSED

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.

Disclosing Your Information When You Log-in 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.

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.

Disclosing PD With Our Subprocessors

We may share your PD with our subprocessors. 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 subprocessors.

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 process; (b) necessary to assist law enforcement officials or governmental 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 company.

Community Discussion Boards, Blogs, or Other Mechanisms

Our Platform may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our Platform for publication may be available worldwide on the Internet. We cannot prevent the use or misuse of such information by others.

HOLDING AND DESTROYING YOUR PD

We only retain your PD for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for PD, we consider the amount, nature, and sensitivity of the PD. When your information is no longer needed, we will destroy, delete, or erase it.

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 our Platform 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.

LINKS TO OTHER WEBSITES

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

Our Platform is not designed for use by anyone under the age of 16. 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 and they are under the age of 16, 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 under the age of 16 is accessing our Platform, we will delete their 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 can always opt-out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third-party without your permission except in the sale or transfer of our company, or if our company files for bankruptcy as described in the section Disclosures to Successors.

OUR SECURITY POLICY

We have built our Platform using industry-standard security measures and authentication tools and user 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.

USE OF YOUR CREDIT CARD

You may have to provide a credit or debit card to buy products and services from our Platform. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.

TRANSFERRING PD FROM OTHER COUNTRIES

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 acceptable 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 user, or a user from another country, with your consent your PD may be transferred to the United States or other countries when you request information from us. When you buy goods or services, we will use your PD to perform a contract with you. Wherever we transfer, process, or store your PD, we will try to apply reasonable safeguards to protect it. We will use the information we collect from you by following the practices described in our privacy notice. Also, we enter into data processing agreements and standard contractual clauses when appropriate. By using our Platform, services, or products, you agree to the transfers of your PD described within this section.

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 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 this privacy notice in effect when the information was collected. 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.

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