Last Updated: August 31, 2018
Description of Users and Acceptance of Terms
What Information We Collect/Receive; the Purpose of Collection and Use
We collect and/or receive the following categories of information.
Contact Information: When you contact us through the “Contact Us” page, request a demo of our services, sign up to receive our newsletter, or sign up to become a Registered User, you will be asked to provide certain information which may include first name, last name, e-mail address, job title, and name of your organization (“Contact Information”). The Contact Information is used to provide the requested Services, or information, and to contact Customers, Registered Users and Visitors for purposes of direct marketing of our current and future products and services.
Billing Information: In order to purchase our Services, Customers will be required to provide certain additional information which may include a credit card number, expiration date, billing zip code, activation code, and similar information (“Billing Information”). Billing Information is collected and processed by our third-party payment processor operating as our agent (See, Onward Transfers to Third Parties). Enigma does not directly obtain or process any Billing Information.
Other Information: In addition to the Contact Information, we may collect or receive the following information (“Other Information”):
From Your Activity.
In an ongoing effort to improve the Sites, and the Services we automatically collect certain information when visitors visit the Sites and when Registered Users and Customers access the Services. This information consists of IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Sites Visitors visit, and similar information concerning your use of the Sites and the Services.
We also collect information by using “cookie” technology. Cookies are small packets of data that a website stores on the hard drive of your computer or mobile device to “remember” information about your visit. We may use session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer/device until you delete them). If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Sites, and/or the Services may not function properly.
Third-Party Analytics and Remarketing.
For Google Analytics, please visit: https://www.google.com/analytics
For Mixpanel, please visit: https://mixpanel.com
For Google Adwords, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
Information Accessible Through Third-Party Providers
In an ongoing effort to better understand our Visitors, Registered Users, Customers, and our products and services, we may analyze your information in aggregate form in order to operate, maintain, manage, and improve the Sites, and the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes. In addition, we may provide aggregated statistical collective user information, to our partners so that they understand how often people use specific components of our Services.
How We Share Your Information
Onward Transfer to Third Parties
With regard to the principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Opt-In to Certain Onward Transfers
We will not transfer your personal information to a third party acting as a controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.
We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. You may grant such consent by contacting us at email@example.com.
In each instance, please allow us a reasonable time to process your response.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by e-mailing the instructions to this email address: firstname.lastname@example.org. Please allow us a reasonable time to process your request
Accessing and Modifying Personal Information and Communication Preferences
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Enigma marketing email or contacting us at email@example.com. Registered Users cannot opt out of receiving transactional e-mails related to their account. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
Disclosures to Public Authorities
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Your Enigma account information is protected by a password for your privacy and security. You are responsible for creating this password and for protecting it and not sharing it with any third party. Enigma takes reasonable and appropriate security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and compliance with applicable laws and regulations. You should keep in mind, however, that no internet transmission is 100% secure or error-free. In particular, e-mail sent to or from the Sites, may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other electronic means.
Retention of Personal Information
Important Notice to Non-U.S. Residents
It is important to note that the Sites, the Services, and their servers are operated in the United States. If you are located outside of the U.S., please be aware that any information provided to or collected by us, including personal information, will be transferred from your country of origin to the U.S. Except in the case of data transfers under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Sites, and Services, constitutes your consent to this data transfer.
Important Notice for Residents of the European Economic Area and Switzerland
Enigma is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Enigma has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to BBB PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Enigma, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the U.S. Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Enigma at firstname.lastname@example.org.
Publicly Available Information
Links to External Websites
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Enigma via email at email@example.com.
In addition, Enigma does not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.
Questions or Concerns
If you have any questions or concerns regarding privacy at Enigma, please send us a detailed message to firstname.lastname@example.org or to Enigma Technologies, Inc. at 245 Fifth Avenue, 17th Floor, New York, NY 10016. Your privacy is important to us and we will make every effort to resolve your concerns.