Privacy Policy

Last Updated: 16 April 2019

1. Introduction

1.1 This Policy

Your privacy is important to Enigma Digital Limited (“Enigma Digital”, “we”, “our”); therefore, we’ve created a Privacy Policy, which (along with our Terms of Use, EULA and other documents referred to in it) covers how we collect, use, disclose, store and transfer your personal information. This policy applies to your use of our website, mobile applications, software and services. By using our website, software, mobile applications and services, you are accepting and consenting to the practices described.

1.2 Who is the Data Controller?

The UK-based company, Enigma Digital Limited, is the controller of the personal data that you submit to us and is responsible for your personal data under applicable data protection law.

1.3 Our Contact details

If you have any comments or questions about our Privacy Policy or our data processing practices, please contact us by emailing [email protected].

2. Your Rights and preferences

Depending upon your geographical location, you have a number of legal rights with respect to your information. Except as limited under applicable law, your rights enable you to:

• Request that we provide you with a copy of the personal data that we hold about you, with the right to transmit that personal data to a third party
• Request that we update any personal data which is inaccurate or incomplete
• Request that we temporarily or permanently stop processing some or all of your data
• Request that we delete any of your personal data which we are holding
• Object to us processing your data on the basis of legitimate interest
• Object to us processing your personal data for direct marketing purposes, with the right to withdraw consent at any time
• Request that you are not subject to automated decision-making, including profiling

If you have any questions about your rights, your privacy or how to exercise your rights, please email our Data Compliance Officer at [email protected].

3. Information We Collect

When you visit our website, use our software, mobile apps, and services, or contact us, you may be asked to provide personal information. We also collect information generated through your use of our products.

3.1 Information You Give Us

1. Account Information. When you create an account with us, you provide us with your login credentials, including your email address and password.
2. Payment Transaction. When you purchase any of our software products or services you provide us with transaction information including your name, email, physical address, credit/debit card information or other payment & billing information, as well as any discounts or offers used and transaction history relating to our company. When you make a purchase, any credit card or payment information that you provide is collected and processed directly by our payment processors, 2Checkout, Stripe (through their Stripe Checkout Service), Paddle and/or PayPal. Enigma Digital Limited does not receive or store full credit card information. PayPal, 2 Checkout, Paddle and Stripe commit to using industry-standard security. You can view their Policies directly on their websites by visiting Stripe (https://stripe.com/us/privacy), 2Checkout (https://www.2checkout.com/legal/privacy/#id_06), Paddle (https://paddle.com/privacy-buyers/) or PayPal (https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev).
3. Device data. When you use our services and choose to create backups of your data, you may provide us with copies of specific and user-selected content and data on your device.
4. Information from 3rd-party services. If you choose to connect our software or services with 3rd party services, for example, iCloud, you provide us with specific, user-selected content from these services. Any data sent under this clause will be confined to content that you have selected and chosen for us to process. You can end our access at any time to other services by logging out of the service.
5. Product Requests. When you request to receive information about or access to our products or services, you provide your email address with the information about your specific product requirements.
6. Website interactions. When you send us comments or blogs on our website, you provide us with your name, email address and user-generated content.
7. Support Requests. When you interact with our support team, you may provide us with personal information including your name, email address, order ID (where applicable), as well as device and technical information where applicable.
8. Marketing Data. We may use personal data, with your consent, to send you marketing communications. You can opt out of these communications at any time.
9. Surveys. If you participate in surveys, you may provide us with your insights into our products and services, and responses to our questions.

3.2 Information We Collect About You

When you visit our website, or use our software, mobile applications and services, we may automatically collect some information about you.

1. Usage information. If you use our services, we collect information about your activity, including navigation and browsing history on our site and click history, connected to your cookies.
2. Technical information. When you visit or make a purchase on our website, we collect technical information such as the IP address used to connect your computer to the internet. This may be used to provide you with customised user experiences, based on language and browser settings.
3. Device data. When you use our services, and choose to create backups of your data, we may be required to process data such as device backups for specific, user-selected content; such data is only held for as little time as is necessary to provide the service, and we take all reasonable measures to minimise the storage of any such data.
4. We collect anonymised data about website, software and services usage. This data is used to monitor website usage and aggregated user behaviour, and to deliver applicable user experiences, for example, mobile device browsing on our website. All anonymised data is not personally identifiable to a particular end-user and cannot on its own, be used to identify or associate with a specific individual. If we do combine personal and non-personal information, the combined information will be treated as personal information for as long as it remains combined.

3.3 Information we receive from other sources

1. We may receive information about you from third parties, including advertising networks, analytics providers and search information providers.
2. Use of Intercom Services. We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyses your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us, by emailing [email protected].

4. How We Use the Information We Collect

All information identified in Section 2, which we collect from you is used in accordance with this Privacy Policy and current data protection law. We will process your personal data in the following ways:

4.1 Performance of a contract

1. We require certain personal information from you in order to provide our services, including processing a transaction.
2. We also require information to ensure that we are able to provide our website, software, and services for your use, including device data, technical information, and usage tracking.
3. To communicate with you about completed transactions.
4. To provide you with support for our offerings, as requested by you.

4.2 Consent

1. In order for us to communicate with you about marketing activities we only use information that you have consented to provide us, with the purpose of informing you about marketing promotions, updates or surveys
2. To provide you with information, new features or products, advertising or other content.
3. You may withdraw consent at any time by emailing [email protected].

4.3 Legitimate interest

1. Where you have requested specific information or access to your data, we will process your data on the basis of legitimate interest.
2. We will use usage information on the basis of our legitimate interest to ensure usage of our website and offerings complies with our Terms & Conditions.
3. To ensure technical functionality of our offerings, to understand user interaction with our platforms and to develop new products and services.

4.4 Compliance with legal obligations

1. To comply with any legal obligation and/or any lawful request from government or law enforcement
2. To process your payment and detect or prevent fraud, including fraudulent payments.
3. To ensure that our website, software, apps and services are being used in line with our Terms

5. Who Has Access to your Data

We are committed to your privacy, so your data will only be shared in the circumstances below:

5.1 3rd-Party Data Processors

1. Personally identifiable information is processed by 3rd party suppliers who help us to provide our services to you, including payment processing and email providers.
2. Anonymised information is shared with analytics tools; this data cannot be used to identify a specific individual.

5.2 Legal Obligation

We may disclose your information if reasonably necessary,

1. In order to comply with a legal process, to assist in the prevention of a crime, or to protect the safety of any person.
2. To protect our legal rights, to investigate or prevent suspected fraud or other wrongdoing, and to enforce our agreements with you.

5.3 To protect the rights of our customers

Where it is necessary to provide protection for users and work with 3rd party providers, for example, in the case of transaction fraud.

5.4 Purchase of our company

In the event of a reorganisation, merger or sale we may transfer or disclose personal information to the relevant third party.

6. Where We Store Your Data

6.1 All information that you provide to us is stored on our secure servers. Payment transactions are encrypted and transmitted over secure connections. We also regularly monitor our system for possible vulnerability and review our security practices.

6.2 When you create an Enigma Digital account with login credentials including a password, you are responsible for keeping this password confidential.

6.3 The data you provide may be transferred by Enigma Digital to recipients who are located outside of the European Union. In such cases, we will ensure that transfer of your personal data is carried out in accordance with applicable privacy laws. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure your data is processed securely in accordance with this Privacy Policy.

6.4 We cannot guarantee the security of all data submitted to our website, and any transmission of data is at your own risk. Once we have received your personal information, we will take all reasonable steps to ensure its safety and security; this includes but is not limited to removing data that is no longer relevant or necessary, anonymising and encrypting data.

7. Data Retention & Deletion

We retain your personal information only as long as is necessary and as permitted by applicable law to provide you with our offerings and legitimate business purposes.

7.1 When you create an Enigma Digital account, we will store your account information for as long as you have an account with us. You can close your account at any time; at this time, we will remove the data that we have previously stored in connection with your account.

7.2 We will remove user data after a period of three years of continuous inactivity, unless:

1. We are required to retain it in order to comply with applicable laws, for example, Data Retention guidelines or local business law
2. There is an outstanding claim, dispute or issue relating to user data which requires us to retain it until it is resolved

8. Third Party Links and Websites

Our site may contain links to third party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, we advise that you read their privacy policies to find out how they process your personal data.

9. Children

9.1 Enigma Digital’s offerings are not directed to children under the age of 16 years. We do not knowingly collect personal data from children under 16 years; if you are under 16 years old, please do not use Enigma Digital products, and do not provide any personal data to us.

9.2 If you are a parent or guardian who is aware that your child has provided us with personal information, please contact us by emailing [email protected], and request removal of the data, based on the rights detailed in Section 2 of this Privacy Policy.

9.3 If we discover that we have collected the personal information of a child under the age of 16 years, we will take reasonable steps to delete data relating to the user. This may include, but is not limited to, removal of a child’s Enigma Digital account and suspending their licenses for our software.

10. Changes to this Privacy Policy

From time to time, Enigma Digital may change this Privacy Policy. We may notify you in advance. Please check back regularly so that you are aware of any changes to the Privacy Policy.

11. Contact Us

If you have any questions about this Policy, please contact our Data Compliance Officer, by emailing [email protected], or by writing to us at the following address:

• 106/7B The Big Peg
• 120 Vyse Street
• Birmingham
• B18 6NB