Enable3 Privacy and Cookies Policy
Lastly updated: October 30, 2024
Enable3 is a B2B product offering the integration of loyalty solutions into mobile applications and web resources. We understand that you care about your privacy interests and treat your rights responsibly.
This Privacy and Cookies Policy applies to your use of our website https://enabl3.io (hereinafter - the “Website”) and explains how information is collected, used, and disclosed by NABL APPS LIMITED (hereinafter - “Enable3”, “we”, “us”, “our”), a company duly incorporated and existing under the laws of the Republic of Сyprus, when you access or use our Website, Enable3 Widget or other products or services, which are included in our services on Loyalty Programs' services provision (collectively, the “Services”), or when you otherwise interact with us.
By visiting our Website, you may access our Services provided that you accept our Terms of Use and our respective Policies and successfully pass the onboarding procedure. Please read further for details on the information we may collect about you or your device.
By using our Website, Enable3 Widget, submitting the registration form on the Website or booking a Demo meeting, and reading this Policy, you (i) accept our use of your personal data and cookies; (ii) are notified by Enable3 about the processing of your personal data by means and for purposes underlined here; (iii) consent to the processing of your personal data for contacting, marketing and administrative purposes. You may unsubscribe from these communications or withdraw your consent at any time by contacting us via support@enabl3.io.
1. Information We Collect
We may collect the following types of personal data from you when you use our Website and interact with our Services:
Name: We may collect your full name when you provide it to us during registration, account setup, or other interactions.
Email address: We may collect your email address when you provide it to us for communication, account setup and account verification, use of our Services, and updates.
IP address: We may collect your IP address automatically when you visit our Website, which helps us understand how it is used and improve its functionality.
Other Log Information: We may collect other log information when you access our Website such as including access times, pages views and the website navigation paths.
Survey responses: If you choose to participate in surveys or provide feedback, we may collect your responses to those surveys.
Device Information: We may collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, your web browser, and device identifiers (including a network ID used to communicate with other nodes on the platform).
Usage Information: If you use our Website, we will collect information contained in or relating to any communication that you send to us or send through our Website (including shard size, number of shards and frequency of access), and metadata associated with the communication.
Information Collected by Cookies and Other Tracking Technologies via Our Services: We use cookies on the Website to collect information about your visit and to allow you to navigate from page to page without having to re-login each time, count visits, and see which areas and features of our Website are popular. Cookies are small text files that are usually stored on a computer's hard drive by websites that you visit. With this knowledge, we can improve the quality of your experience with our services by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. Web beacons (or pixel tags) are electronic images that may be used in our web Services or emails to help deliver cookies, count Website visits, understand usage, and determine the effectiveness of email marketing campaigns. Our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites after you use our Services.
Other information: We may collect any other information you provide to us during personal communication, such as through email or other means of communication.
2. Information You Provide to Us
We may collect information you provide directly to us. For example, we collect the information you provide when you subscribe to our updates, respond to a survey, fill out a form, request customer support, or communicate with us. The types of information we may collect include your name and surname, email address, IP address, survey responses, and any other information you choose to provide during personal communication with the Enable3 manager.
If you use our Website, our third-party service provider may collect information on your payment method in connection with your payments (if any).
3. Information We Obtain from Third Parties
Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
Companies who support our Website and Services.
Our payment processors collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment to fulfill your orders and provide you with products or services you have requested to perform our contract with you.
When you visit our Website, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
Any information we obtain from third parties will be treated in accordance with this Privacy and Cookies Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices.
4. How We Use Your Personal Data
We use your personal data for the following purposes:
Providing Services: We use your personal data to provide and deliver our digital Services, including tokenizing reward systems and loyalty programs, communicate with you about your account, respond to your inquiries, monitor and analyze trends, usage, and activities related to our Services, and provide customer support.
Developing new products and services: We may use your personal data to develop new products and services.
Improving our Services: We may use your personal data to analyze how our Services are used, improve their functionality, and enhance user experience.
Communicating with you: We may use your personal data to communicate with you about our Services, updates, promotions, technical notices, events, and other relevant information.
Security and Fraud Prevention: We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
Legal compliance: We may use your personal data to comply with applicable laws, regulations, and legal obligations, including General Data Protection Regulation (GDPR) requirements (if they apply in your case), detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect the rights and property of Enable3 and others.
Terms of Use Compliance: We may use your personal data to verify your compliance with the Terms of Use governing the use of our Website and Services.
Marketing and Advertising: We use your personal information for marketing and promotional purposes, such as sending marketing, advertising, and promotional communications by email or text message and showing you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Website and other resources.
We may also use Google Analytics to help us understand how our clients use the Website - you can read more about how Google uses your personal Information here: https://www.google.com/intl/en/policies/privacy/ You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
In addition, we may use your personal Information to provide you with targeted advertisements or marketing communications we believe may interest you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work You can opt out of targeted advertising by using the links below:
5. Legal Basis for Processing Your Personal Data
We process your personal data based on the following legal bases:
Contractual necessity: We process your personal data to fulfill our contractual obligations to provide our Services to you, including registering your account and delivering the requested Services.
Legitimate interests: We may process your personal data based on our legitimate interests, such as improving our Services, communicating with you about our Services, and ensuring the security and integrity of our Website and Service.
Consent: In some cases, we may rely on your consent to process your personal data, such as when you provide us with your email address for communication or participate in surveys.
6. Data Sharing Disclosure
We do not sell or rent your Personal Data to third parties. However, we may share your personal data with the following types of recipients:
Service providers: We may share your personal data with third-party service providers who may be engaged by us to help provide our Services, such as hosting, data storage, customer support, and others. Among other things, service providers help us host our Website, send out email updates (if any), identify and serve targeted advertisements or measure site traffic, provide optimization, content customization, and communication with clients, services etc.
Our service providers are contractually obligated to use your personal data only at our direction, to handle your personal data in confidence, and not to disclose your personal data to unauthorized third parties. Service providers who violate these obligations are subject to appropriate discipline, including, but not limited to, termination as a service provider. Such providers include but are not limited to Amazon, MailChimp, Hotjar, Google Analytics, Google AdSense, Google Advertisement, Google Tag Manager, Facebook Business, Twitter, Leadfeader, LinkedIn, Bing Advertisement, Taboola Advertisement, Microsoft Office add-in, Stripe, etc. For information on how third parties collect and process personal data and how you can control information sent to those third-party providers, please review privacy policies on their websites.
Legal requirements: We may disclose your personal data as required by applicable laws, regulations, legal processes, or governmental requests. We may also disclose your personal data in response to a request for information if we believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
Business transfers: In the event of a merger, acquisition, or other business transfer, we may transfer your personal data to the relevant third party.
Enable3’s rights protection: We may disclose your personal data to the public authorities concerned if we believe your actions are inconsistent with our user Terms of Use or policies or to protect Enable3's rights, property, and safety.
Internal sharing: We may disclose your personal data between and among Enable3 and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
7. International Data Transfers
As part of providing our Services, your personal data may be transferred to, stored, and processed in countries outside of your own country of residence, including countries that may have different data protection laws than those in your jurisdiction. We will take appropriate safeguards to protect your personal data when it is transferred internationally, including ensuring that the recipients of your personal data provide an adequate level of data protection or obtaining your explicit consent, where required by applicable laws.
7.1. Transfer of Information to the Republic of Cyprus and Other Countries
Enable3 is based in the Republic of Cyprus, and the information we collect is governed by the law of the Republic of Cyprus. By accessing our Website or using our Services, or otherwise providing information to us, you consent to the processing and transfer of information in and to the Republic of Cyprus and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy and Cookies Policy.
8. Correct / Update / Delete Information
You have the right to access your personal information and to require the correction, updating, or deletion of incorrect or/ inaccurate data by contacting us; please email us at support@enabl3.io. Nevertheless, this request must comply with legal obligations. Upon the accepted request, we will provide you with the personal information that we collect and store about you and general disclosure of your personal information.
9. Data Retention
We may hold your personal information in accordance with applicable laws and regulations and as needed to provide you with Services. This requirement is conditioned by the need to comply with legal obligations and resolve possible disputes. We may retain your personal information so long as your account is active. Moreover, your information may be held beyond the abovementioned period until it is indispensable for us to have relevant information to respond to any issues that may arise later.
In case you have a lawful demand for the deletion of your personal information from our Services, please contact us at support@enabl3.io.
10. Your Rights
As a personal data subject, you have certain rights regarding your personal data. These rights may include:
Right to access: You have the right to request access to the personal data we hold about you and receive information about its processing.
Right to rectification: You have the right to request the correction of inaccurate or incomplete personal data we hold about you.
Right to erasure: You have the right to request the deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
Right to restrict processing: You have the right to request the restriction of processing of your personal data under certain circumstances, such as when you contest its accuracy or object to its processing.
Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible.
Right to object: You have the right to object to the processing of your personal data under certain circumstances, such as when it is processed for direct marketing purposes or based on legitimate interests.
Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data infringes applicable data protection laws.
You may exercise any of these rights where indicated on our Website or by contacting us using the contact details provided below.
10.1. Rights of EU residents
If you are a resident in the European Economic Area, you have the following rights with respect to your personal data under the General Data Protection Regulation (GDPR) that we hold:
Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds related to your particular situation. You can object to marketing activities for any reason whatsoever.
Right of access. You have the right to obtain access to your personal data.
Right to be informed. You have the right to get information from us on how we use your personal data.
Right to rectification. You have the right to change or amend any of your personal data if it is inaccurate or incomplete.
Right to delete. You have the right to delete your personal data.
Right to restriction. You have the right to obtain restrictions on the processing we undertake on your personal data.
Right to data portability. You have the right to portability, which allows you to move, copy, or transfer personal information easily from one organization to another.
We process your personal data on the basis of your freely given consent and legitimate interests. You should be aware that you are entitled under EU GDPR to withdraw your consent where it has been given at any time. In case you do this, we will have no alternative lawful reason to process your personal data. However, if you ask us to remove your personal data processed on the basis of legitimate interests, we may not be able to provide you with our Services anymore.
10.2. Rights of California residents
If you are a California resident, you have the following rights under the California Consumer Rights Act (CCPA): the right to know the categories of personal data that we collect about you, the right to ask us to delete your personal data from our Services, and the right to opt-out of selling your personal data (if any).
You can exercise all of the aforementioned rights by contacting us using the contact details provided below, particularly:
To request information on the personal data that we have about you and how we use it:
The categories of personal data we have collected about you;
The categories of sources from which we collect your personal data;
The purpose for collecting, processing, (or selling) your personal data;
The categories of third parties with whom we share your personal data;
The specific pieces of personal data we have collected about you;
If we share your personal data, you can request a list of categories of personal data that we have disclosed for business or commercial purposes, along with a category of any other company. In clauses 1-3 of this Policy, we have already indicated what Information (personal data) we may collect.
Please note that you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. You can request it via Contact Us on our Website or send us an email to support@enabl3.io.
We may require you to confirm your identity and your residency to obtain the information you email us with your request at the contact information below. Please include “California Privacy Rights” as the subject line. You must include your full name and email address and attest to the fact that you are a California resident by including a California postal address in your request. We will respond to your request within 45 days or let you know if we need additional time.
When you make this request, the information provided may be limited to the personal data we collected about you in the previous 12 months.
Right to opt out of selling your personal data:
You have certain rights regarding the sale of personal data, such as to opt out of the sale of your personal data. We do not sell the personal data we collect (as defined in the CCPA) and will not sell it without providing you with the right to opt out.
Right to non-discrimination:
California consumers have the right to non-discrimination in relation to the exercise of their rights under the CCPA. In particular, we cannot deny you the Services, charge you different prices for the Services, either by denying benefits or imposing penalties, provide you with a different level or quality of the Services in comparison to how we proceed with other California users, or threaten you with any of the above.
Right to Delete any of your personal data:
You have the right to request that we delete any of the personal data we collected about you and retain it, subject to certain exceptions.
If you would like to remove your personal data collected by us on the basis of legitimate interests, you can request the deletion of your account (“Delete my account”). Please note that you may no longer be able to use our Services. If you decide to terminate your use of our Services, we will remove all your personal data from our database within 30 business days after receiving your request.
You can change any of your personal data in your account.
If you would like to request access to your personal data or ask any other questions related to your personal data, you may always send your request by emailing to support@enabl3.io. We will respond to your request within three business days.
10.3. Rights of Canadian residents
If You are a Canadian resident, you have the following rights under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA):
Know why we collect, use or disclose your personal data;
Expect us to collect, use or disclose your personal data reasonably and appropriately and not use the information for any purpose other than that to which we have consented;
Know who in Enable3 is responsible for protecting your personal data;
Expect Enable3 to protect your personal data by taking appropriate security measures;
Expect the personal data Enable3 holds about you to be accurate, complete and up-to-date;
Obtain access to your personal data and ask for corrections if necessary;
Request the removal of your personal data;
Complain about how Enable3 handles your personal data if you feel your privacy rights have not been respected.
“Personal Data”, as specified in PIPEDA, is as follows: information about an identifiable individual but does not include the name, title, business address, or telephone number of an employee of an organization.
Right to Delete any of your personal data:
You have the right to request that we delete any of your personal data we collected about you. You have the right to request that we delete any of your personal data we collected about you and retained, subject to certain exceptions.
If you would like to remove your personal data collected by us on the basis of legitimate interests, you can request the deletion of your account (“Delete my account”). Please note that you may not be able to access our Services any more. If you decide to terminate your use of our Services and delete your account, we will remove all your personal data from our database within 30 business days after receiving your request.
You can change any of your personal data in your account.
If you would like to request access to your personal data or ask any other questions related to your personal data, you may always send your request by emailing to support@enabl3.io.
11. Security Measures
We take appropriate technical and organizational measures to protect the privacy of the information you provide to Enable3 from loss, misuse, disclosure, alteration, and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you transmit over the Internet or third-party content.
12. Links to Third-Party Websites
Our Website may contain links to third-party websites or services that we do not operate or control. This Privacy and Cookies Policy does not apply to such third-party websites or services, and we are not responsible for their privacy practices. We recommend reviewing the privacy policies of third-party websites or services before providing any personal data.
13. Minor's Privacy
Our Services are not intended for minors under the age of 18, and we do not knowingly collect or process personal data from minors without appropriate parental consent. If you believe that we have inadvertently collected personal data from a minor, please contact us immediately, and we will take steps to delete the information as required by applicable laws.
14. Cookie Policy
Cookies, pixels, and other technologies (collectively, “cookies”) are small files that contain information that is transferred to and from your computer's or mobile device’s hard drive.
These technologies help us better understand user behavior, tell us which parts of our Website people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
By continuing to access and use the Website or Enable3 Widget, you accept our use of cookies.
However, you are free to explore the Website without providing any personal data. If you have not disabled cookies, our Website may use cookies to track your use of the Website and collect navigational information.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of the Website.
Analytical/performance cookies. These allow us to recognize and count the number of visitors and see how visitors move around the Website when they are using it. This helps us to improve the way the Website works.
Functionality cookies. These are used to recognize you when you return to the Website. They enable us to personalize content for you, greet you by name, and remember your preferences, such as your choice of language.
Targeting cookies. These cookies record your visit to the Website, the pages you have visited, and the links you have followed. We will use this information to make the Website more relevant to your interests. We may also share this information with third parties for this purpose.
14.1. Why we use cookies
We use cookies to recognize your browser, your computer or your mobile device, learn more about your interests, provide you with essential features and Services, and for other purposes. More specifically, these include:
We recognize you when you sign in to use our Services. This allows us to provide you with product recommendations, display personalized content, and offer other customized features and Services.
Conducting research and diagnostics to improve Services.
Preventing fraudulent activity.
Improving security.
Reporting. This allows us to measure and analyze the performance of our Services.
Cookies allow you to take advantage of some of the Website’s essential features. For instance, if you block or otherwise reject our cookies, you may not be able to use any of our products or services that require you to sign in.
Approved third parties may also set cookies when interacting with the Website and related Services. Third parties include search engines, providers of measurement and analytics services, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads and to help us to perform Services.
14.2. Managing cookies
You can manage browser cookies through your browser settings. The "Help" feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a Website and some features and Services may not work.
For additional, more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.
15. Changes to this Privacy and Cookies Policy
We may update this Privacy and Cookies Policy from time to time to reflect changes in our data practices or legal requirements. We will notify you of any material changes by posting the updated Privacy and Cookies Policy on our Website or through other means of communication. We encourage you to review this Privacy and Cookies Policy periodically for the latest information on our privacy practices.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy and Cookies Policy or our data practices, please contact us using the following contact information:
NABL APPS LIMITED
Antoni Loukaidi 114, Oasis Court, Flat/Office 103, Limassol 3032, Cyprus
+35796875560
support@enabl3.io
Thank you for reading our Privacy and Cookies Policy. By using our Website and Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy and Cookies Policy.