Effective: February 13, 2020
Enableocity takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.
We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Members (Section 2), Contacts (Section 3), and Visitors (Section 4). Sections 1 and 5 are applicable to everyone.
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.
Enableocity is a Sales Enablement-as-a-Service Company (the "Services") operated by Enableocity, Inc. d/b/a/ Enableocity, an Arizona C Corporation headquartered in the State of Arizona in the United States ("we," "us," "our," “Platform”, and "Enableocity").
The Services enable our Members to, among other things, store, share send and manage content and email campaigns. We also provide other related services, such as sales enablement consulting, training and gamification.
In this privacy policy, these terms have the following meanings:
“Content” is the information store of your files, documents, photos, comments, messages, emails, campaigns and so on (“Your CONTENT”), collaborate with others, and work across multiple devices. To make that possible, we store, process, and transmit Your Content as well as information related to it. This related information includes your profile information that makes it easier to collaborate and share Your Content with others, as well as things like the size of the file, the time it was uploaded, collaborators, usage activity and other metadata of the Content.
"Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's List or about whom a Member has given us information. You may choose to give us access to your contacts to make it easy for you to do things like share and collaborate on Your Content, send emails and messages, and invite others to use the Services. If you do, we’ll store those contacts on our servers for you to use
"Distribution List" is a list of Contacts a Member may create, upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).
"Member" means any person or entity that is registered with us to use the Services.
"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Website(s)" means any website(s) we own & operate (such as www.Enableocity.com) or any web pages, interactive features, applications, add-ons, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.
This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitor or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.
The Personal Information that we may collect broadly falls into the following categories:
(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with Enableocity), or communicate with us in any other way.
We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Service and in this privacy policy.
This information may include:
(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device, location and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement.
This information may include:
(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
(iv) Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement.
If you are a user of Enableocity and have Enableocity subscription account, your administrator may have the ability to access and control your Enableocity account. Please refer to your organization’s internal policies if you have questions about this. If you are not an Enableocity user but interact with an Enableocity user (by, for example, joining a shared folder or accessing Content shared by that user), members of that organization may be able to view the name, email address, profile picture, and IP address that was associated with your account at the time of that interaction.
A Distribution List can be created in a number of ways, including by importing Contacts, such as through a CSV or directly from your email client. Your Distribution Lists are stored on a secure Enableocity server. We do not, under any circumstances, sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person. You may export (download) your Distribution Lists from Enableocity at any time.
If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.
If a Contact chooses to use the Forward to a Friend (FTF) link in an email campaign a Member sends, it will allow the Contact to share the Member’s email content with individuals, not on the Member’s Distribution List. When a Contact forwards an email to a friend, we do not store the Contact’s email address or their friend’s email address, and no one is added to any Distribution List as a result of the FTF link. The Member who created the email campaign only sees an aggregate number of times their email campaign was forwarded by a Contact and does not have access to the email addresses used to share or receive that forwarded content.
You and your Contacts may have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.
This section applies to the information we process about our Members’ Contacts as a data controller pursuant to our legitimate business interests, as explained in the "Legal Basis for Processing" section below. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. Enableocity is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts.
The Personal Information that we may collect or receive about you broadly falls into the following categories:
(i) Information we receive about Contacts from our Members: A Member may provide Personal Information about you to us through the Services. For example, when a Member uploads their Distribution List or integrates the Services with another website or service (for example, when a Member chooses to connect their e-commerce account with Enableocity), or when you sign up for a Member’s Distribution List on a Enableocity signup form, they may provide us with certain contact information or other Personal Information about you such as your name, email address, address or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Member.
(ii) Information we collect automatically: When you interact with an email campaign that you receive from a Member or browse or purchase from a Member’s connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement.
(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as social media platforms and third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us, and we use this information to provide publicly available social media information about you to Members who have enabled the "Social Profiles" feature in their Enableocity accounts.
We may use the Personal Information we collect or receive about you for our legitimate business interests, including:
We and our partners may use various technologies to collect and store information when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the Enableocity platform was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Members’ email campaigns, and to provide analytics information and enhance the effectiveness of our Services.
Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement.
We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services and our Website.
You may have the following data protection rights:
As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Enableocity as a processor on behalf of our individual Members, you should contact the relevant Member that is using the Enableocity Services, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.
(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to sign up for a free or paid Enableocity account, apply for a role with Enableocity, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.
(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement.
We may use the information we collect through our Websites for a range of reasons, including:
In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.
We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our Cookie Statement.
You have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
For example, if it is necessary to provide Members something they have requested (like enable a feature such as Social Profiles), then we may share Members’ or Contacts’ Personal Information with a service provider for that purpose. Other examples include analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content.
These third-party service providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this privacy policy.
In connection with our Services, we use a third-party service provider, SendGrid & Twilio, Inc. We use SendGrid and Twilio’s API, which allows us to build features into our Enableocity application to enable us to communicate with our Members through emailing, texting and calling. If you are a Member, SendGrid and Twilio may need to collect and process certain Personal Information about you as a controller to provide such services.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Members and Visitors with them for this purpose. We do not sell or market to any of our Members’ Contacts. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our Cookie Statement.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
(v) Any other person with your consent.
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your Enableocity account.
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page. If you have any questions about the security of your Personal Information, you may contact us at legal@Enableocity.com.
Enableocity accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s Enableocity account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.
We operate in the United States. Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through email at legal@Enableocity.com.
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send us an email to legal@Enableocity.com.
Updated February 13, 2020