Last Updated: 16 April 2019
1.1 This Policy
Your privacy is important to Enigma Digital Limited (“Enigma Digital”, “we”, “our”); therefore, we’ve created a
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
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
- Account Information. When you create an account with us, you provide us with your login credentials, including
your email address and password.
- 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) and/or
PayPal. Enigma Digital Limited does not receive or store full credit card information. PayPal, 2 Checkout 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) or
- 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.
- 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.
- 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.
- Website interactions. When you send us comments or blogs on our website, you provide us with your name, email
address and user-generated content.
- 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
- 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.
- 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.
- 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.
- 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.
- 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
- 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
3.3 Information we receive from other sources
- We may receive information about you from third parties, including advertising networks, analytics providers
and search information providers.
- 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.
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
and current data protection law. We will process your personal data in the following ways:
4.1 Performance of a contract
- We require certain personal information from you in order to provide our services, including processing a
- 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.
- To communicate with you about completed transactions.
- To provide you with support for our offerings, as requested by you.
- 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
- To provide you with information, new features or products, advertising or other content.
- You may withdraw consent at any time by emailing [email protected].
4.3 Legitimate interest
- Where you have requested specific information or access to your data, we will process your data on the basis
of legitimate interest.
- 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.
- 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
- To comply with any legal obligation and/or any lawful request from government or law enforcement
- To process your payment and detect or prevent fraud, including fraudulent payments.
- 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
- Personally identifiable information is processed by 3rd party suppliers who help us to provide our services
to you, including payment processing and email providers.
- Anonymised information is shared with analytics tools; this data cannot be used to identify a specific
5.2 Legal Obligation
We may disclose your information if reasonably necessary,
- In order to comply with a legal process, to assist in the prevention of a crime, or to protect the safety of
- 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
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
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:
- We are required to retain it in order to comply with applicable laws, for example, Data Retention guidelines
or local business law
- 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.
9.1 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
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.
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
- 106/7B The Big Peg
- 120 Vyse Street
- B18 6NB