Enigma Privacy Notice
Effective Date: January 1, 2021
We at Enigma (“Enigma”, “We”, or “Us”) know you care about how your Personal Information (PI) is used and shared, and we take your privacy seriously. We take it so seriously, it is actually our business to make sure you are in charge of your own personal information, so you benefit when you share it, and you’re in charge when you want it deleted. The purpose of this Privacy Notice is to inform you about how our services collects and uses your personal information and the choices and features you have to share it with others for your benefit. By using our Services, you agree to our terms of service and this privacy notice.
What Information We Collect
Information you voluntarily provide us such as your name, email, address, phone and other information that you add to your profile such as demographic information or other information you choose to share about yourself and household.
Information we automatically collect such as browser type, usage time on our services, cookie information to secure your session and identity, interaction with the companies you choose to receive offers from and share personal information.
How We Use Information
We use the PI to provide our Services. Our perspective is that you should own your PI and our Services enable you to benefit from it. We use PI to set up your account, authenticate your identity and enable your use of our Services. We use PI to provide customer support, respond to inquiries, communicate to you, troubleshoot problems, investigate fraud and enforce our terms of service. As our Services grow, we will communicate with you and subsequently use PI to provide you those additional Services. We use PI in this context based on the contract that we have in place with you or our legitimate interest for security purposes (e.g. the prevention and investigation of fraudulent activities). We’re happy to terminate our Services and delete your PI based our terms of service. You can exercise your rights regarding your PI by contacting us through the app or the website.
Third Party Sharing of PI
The purpose of our Service is to enable you to share PI with third parties for your own benefit. We fuel first-party permissioned connections – working for you as your agent, to get you the most benefit from brands you love. The Services also enable you to turn off sharing, send deletion requests to those third parties, opt-in and opt-out of marketing communications, customize advertising and other cool features.
We also share PI with companies that help us provide the services on our behalf. Those companies are prohibited by contract from using PI for purposes other than our Services but we remain responsible for ensuring they process your PI to the standard required by the applicable privacy law.
We may choose to buy or sell assets, and may share and/or transfer PI in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, PI could be one of the assets transferred to or acquired by a third party.
Under certain circumstances, we may be required to disclose PI in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We also follow national, state, and local security breach laws and will notify you accordingly should something not go according to plan.
We use first party (comes from us) and third party (comes from a partner) tracking tools to help provide our Services. We use them for security and service authentication, internal service analytics and performance evaluation, and marketing. We enable you to disable tracking tools except for ones that are essential to provide our Services.
Your Privacy Rights
You do not have to provide any PI to us and once you have, you can request to have us delete it. You can turn off tracking tools, and tell us what communications you want to receive as well as what you don’t want to receive.
Data Subject Rights
If you would like to access, review, update, rectify, and delete any PI we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR) or similar privacy law, you can let us know through the app or on the website.
International Data Transfer
PI you submit through the Services may be sent to the United States and processed by us there or in other countries, on our service providers’ cloud servers. We will always protect PI in accordance with this Privacy Notice wherever it is processed.
We rely on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission.
California Consumer Privacy Act
We collect identifiers, commercial information, and internet or other electronic network activity information as defined under the CCPA. The purpose of our Services is to put you in control of your PI and therefore you can request that we share or stop sharing PI with third parties at any time, in accordance with our terms of service. We don’t purposefully “sell” your information but under certain legal definitions related to how advertising works, it’s possible that our advertising activities could qualify as a “sale” and therefore you have the ability to exercise an opt-out. You can also request that we disclose the PI we have about you as well as certain categories of information we associate with your PI. These will be based on the PI you’ve shared with us and how you used our Services to benefit from sharing your PI with third parties. You can also ask us to delete your PI, in accordance with our terms of service.
Do Not Track
California and Delaware law require an indication as to whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.
We do not knowingly collect or solicit PI from children (persons under the age of 13). If you have provided or know of PI of someone under the age of 13 that has been provided to us, please contact us so we can delete it.
As we add to our Services and as privacy law continues to change we will update this Privacy Notice and alert you if there are material changes.
You can contact our DPO at firstname.lastname@example.org.
Business customers should contact their business contact set out in our commercial agreement.