Last Revised: January 17,2023

enabley Limited operates various educational platforms and services as well as this website. This statement explains what we do with your personal information when you register to use this website and how to exercise your rights over it.

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

If you have any questions about our use of your personal information, or if you want to exercise your rights, you can contact our team at info@enabley.io

Who is in charge of your information?

It is your exclusive choice to provide us the personal information you may elect to give us when you subscribe to our newsletter and/or register to use our website and/or enroll as a User on an enabley platform.

The information we may collect about you

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our site www.enabley.io or by corresponding with us by phone, e-mail or otherwise.

This includes information you provide when you register to use our site, subscribe to our service, sign up for newsletters, participate in other social media functions on our site and when you report a problem with our site.

The information you give us may include your name, address, e-mail address and phone number, personal description and educational and employment history.

Information we collect about you.

With regard to each of your visits to our site we may automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

information about your visit or visits from your IP address, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits

to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them;

We may receive information about you from your employer where you access services under a corporate subscription.

We may collect your personal details from other sources including where emails are forwarded to you or where we receive your contact details in an automatic out of office response to an email sent by us.

Uses Made of the Information

We use information held about you in the following ways:

to tailor the content that we display to you;

to deliver the service and to correspond with you in relation to the product;

to provide you with information about other goods and services we offer that are similar to those that you have already used;

to notify you about changes to our service;

to ensure that content from our site is presented in the most effective manner for you and for your computer or other device used to access our site.

for system administration and to report aggregated statistical information about browsing patterns and actions which does not identify any individual;

to store usage logs which may be used by us to provide existing and potential authors, contributors, associations we partner with, subscribers and clients with firm-level (ie not individual) information about the user base and usage patterns;

to administer our site and for internal operations, including product development, troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

to allow you to participate in interactive features of our service, when you choose to do so;

as part of our efforts to keep our site safe and secure;

to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

we may combine information received from other sources with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above.

Thus, when you provide your personal details to us we use your information for our legitimate business interests to send you marketing communications or to gather information about how you use our website. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights. Some other typical examples of when we might use the approach are for preventing fraud, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.

When we use your personal information in order to create or maintain your subscription or your access to our website, we do this on the basis that it is necessary for us to do so in order to perform the contract we are entering into with you to provide you with your website access and/or the enabley product.

Disclosure of your information

We will not usually share your personal information with other third parties without your consent except in the following situations for ‘legitimate interests’ as follows:

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of enabley our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;

where we are requested to provide information by authorised third parties or regulatory or governmental agencies investigating illegal activities;

where we believe that an emergency, illegal activity or some other reasonable basis exists for notifying the relevant authority;

where we use sub-contractors to provide the service. Any such sub-contractor will only use your personal information for the purposes of providing services to us and will have no right to use your personal information for its own purposes;

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

If enabley or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

Information security

Enabley uses security features by implementing systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information.

For example, we review our information collection, storage and processing practices, including physical security measures, to prevent unauthorized access to our systems. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

However, these measures are unable to provide absolute assurance and although Enabley takes great efforts to protect your personal information, we cannot guarantee and you cannot reasonably expect that enabley’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Data transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. While Data protection laws may vary among countries, we apply the same protections described in this policy.

European requirements

If European Union (EU) or United Kingdom (UK) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.

You also have the right to object to the processing of your information.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.

When we’re pursuing legitimate purposes

We process your information for our legitimate purposes and those of third parties while applying appropriate safeguards that protect your privacy. Your information is processed for:

Providing, maintaining, and improving our services to meet the needs of our users

Developing new services and features that are useful for our users

Understanding our services are used to ensure and improve the performance of our services

Customizing our services to provide you with a better user experience

Marketing to inform users about our services

Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services

Protecting against harm to the rights, property or safety of enabley, our users as required or permitted by law, including disclosing information to government authorities

Performing research that improves our services for our users Fulfilling obligations to our partners like developers and rights holders

Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re providing a service;

We process your data to provide a service you’ve asked for under a contract (including our terms of use.

When we’re complying with legal obligations;

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

If you have questions, you can contact our data protection office at: info@enabley.io. And you can contact your local data protection authority if you have concerns regarding your rights under local law.

Brazilian requirements

If Brazilian data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to:

Obtain confirmation on whether we process your information

Request access to, update, review, anonymize, and remove your information

Object to or restrict the processing of your information

Export your information to another service

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

Where we ask for your consent to process your information for specific purposes, you do not have to provide your consent but where you choose to do so, you have the right to withdraw your consent at any time. You also have the right to obtain information about the effects of not providing your consent to processing for specific purposes.

When we’re pursuing legitimate purposes;

We process your information for our legitimate purposes and those of third parties while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

Providing, maintaining, and improving our services to meet the needs of our users

Developing new services and features that are useful for our users

Understanding how our services are used to ensure and improve the performance of our services

Customizing our services to provide you with a better user experience

Marketing to inform users about our services

Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services

Protecting against harm to the rights, property or safety of enabley, our users as required or permitted by law, including disclosing information to government authorities

Performing research that improves our services for our users

Fulfilling obligations to our partners like developers and rights holders

Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re providing a service;

We process your data to provide a service you’ve asked for under a contract (including our terms of use.

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

If you have questions, you can contact enabley and our data protection office at: info@enabley.io. And you can contact your local data protection authority if you have concerns regarding your rights under Brazilian law.

U.S. State Law requirements

Some U.S. state privacy laws like the California Consumer Privacy Act (CCPA) and Virginia Consumer Data Protection Act (VCDPA) require specific disclosures for state residents.

State laws like the CCPA and VCDPA provide the right to request information about how enabley collects, uses, and discloses your information. And they give you the right to access and correct your information and request that enabley delete that information. CCPA and VCDPA also provide the right to not be discriminated against for exercising these privacy rights.

Cookies

If our website is to work properly, you will need to ensure that your web browser is set to accept cookies. A cookie is a small file (or record in a file) which the website can send to your browser which may then store it on your computer’s hard drive. Cookies allow enabley to analyze web traffic and to determine more popular areas of its website. Cookies also allow enabley to make its website more user friendly by allowing enabley to save all registration and subscription details or passwords so that you do not have to re-enter every time you visit the enabley website. The cookie will stay on your computer and will only be used should you enter the enabley website. Notwithstanding the above, you do not have to accept cookies and you should read the information that came with your web browser software to see how you can set up your web browser to notify you when you receive a cookie and to give you the opportunity to decide to accept or reject it.

Keeping your information up to date, and how long we will keep your information for

It is your responsibility to ensure that the information you submit to enabley is complete, accurate and up to date and it is your responsibility to notify us if that information changes.

We will keep the information that you provide us when you visit the enabley website for no more than 5 years, to enable us to provide you the services we offer, after which it will be deleted.

We will keep the information that you provide us when you access our platform as a User for as long as you continue to use the platform and for a six month period thereafter, after which it will be deleted.

Your right to unsubscribe

When you receive marketing communications from us you have the right to unsubscribe at any time. You can do that by following the unsubscribe link in the email, or by contacting us at info@enabley.io If you unsubscribe, we will stop sending you marketing communications.

Your right to a copy of the information we hold about you

With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you, as well as information about what we do with it, who we share it with and how long we will hold it for.

Your right to have inaccurate information about you corrected

You have the right to have the information we hold about you corrected if it is factually inaccurate. In most cases the easiest way to do that is to contact us and let us know what information needs to be changed.

Your right to have your information deleted in some circumstances

In some circumstances, you have the right to require us to delete the information that we hold about you. In particular, if you cease being an enabley User and we no longer need to process your personal data, then we will delete the relevant data from our systems.

Complaints

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Data Processing Policy

In addition to the terms herein, the processing of your information by enabley shall be subject to the terms of enabley’s Data Processing Policy, available at: www.enabley.io/data-processing-policy/, which shall form an integral part hereof.

Please feel free to contact enabley at any time at info@enabley.io

Last Update: January 17, 2023