Effective date: December 04, 2018

Enactia Ltd (“us”, “we”, or “our”) operates the www.enactia.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.enactia.com

At Enactia we are committed to protecting personal data and to fair and transparent processing. Please read our privacy policy, it will help you to understand how we collect and use personal data from individuals, our clients, suppliers or others during the course of our business. We will only use personal data for the purposes described in this privacy policy or as stated at the point of collection.

We regularly review this privacy statement and may make changes at any time without giving prior notice.

Who we are

Enactia Ltd is a limited liability company registered in Cyprus with registration number 385736. Our registered office is 117 Athalassas Avenue, 2nd Floor, Office 201, 2013 Nicosia, Cyprus.

This privacy policy only applies to Enactia Ltd. We are not responsible for the privacy practices of any other organization our website may link to.

Our lawful basis for processing

We rely on several lawful fundamentals of processing when we collect and use personal data to operate our business and provide products and services to our clients. These include:

• Public interests – where the processing of data is necessary for providing certain services to clients (e.g. statutory audit) or for certain requirements we are subject to.
• Legal obligations – in order to comply with the legal and regulatory obligations we are subject to as a provider of regulated services and as a commercial business.
• Contract – in order to perform contractual obligations, we may have with an individual or to take steps to enter into a contract with an individual.
• Consent – where an individual has freely given consent at the time their personal data was provided to us.
• Legitimate interests – The legitimate interests can be ours, our clients or other third parties (e.g. to provide our services, to develop or protect our business, or to keep people informed about relevant products and services) and we always balance the rights of individuals with ours’ and others’ legitimate interests.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal identifiable information may include, but is not limited to:

• Email address
• First name and Last name
• Phone number
• Company Name (in case of a Demo / Trial request)
• Cookies and Usage Data

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

For more details refer to our Cookie Policy.

Use of Data

Enactia.com uses the collected data for various purposes:

• To provide and maintain the Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues

Transfer Of Data

Transfer to third parties

We only share personal data with others when absolutely necessary for the purposes for which we hold it and when necessary for our legitimate professional and business needs, for the purpose of executing your instructions or requests and/or as required or permitted by applicable legislation, professional standards or any applicable agreement between us, and where appropriate contractual arrangements and security mechanisms are in place.

We share personal data only with affiliates for our lawful professional and business necessities which comprise of:

• suppliers that support us and help provide services to our clients, such as providers of cloud-based software, IT systems, security, archiving storage, recruitment, marketing and payment services
• professional advisors, auditors or insurers, where we are required by law or as reasonably required in the management of our business
• law enforcement or other government and regulatory agencies or to other third parties, where we are required by law, the courts or any legal or regulatory authority we are subject to. We will only provide personal data in these circumstances where permitted or there is a legal requirement.

Whilst we store personal data on servers within the European Economic Area (EEA), we may transfer personal data outside the EEA or other third parties that help us run our business. Contractual obligations are imposed on the recipients of any data transferred in order to ensure all personal data is protected to the standard required in the EEA.

Sub-processors

We use a select number of trusted external service providers for certain technical data processing and/or service offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions.

Enactia uses the following sub-processors to process the data collected by our website and Enactia GRC Application:

Simplex (Europe, Cyprus): Secure infrastructure for servers and databases and logs hosted in Larnaca, Cyprus.

Third party services we use

When you visit our websites, or purchase products or services, we use the following third party services which may collect personal data.Please access the desktop version of our website to view our third-party service providers.

How long do we keep personal data?

The personal data you submit to us will only be held for as long as is required for the purposes for which it was collected and as required by applicable law.

We keep personal data only for as long as necessary and this will reflect the requirements of:

• the activity or service for which it is being processed
• any legal, regulatory or contractual requirements
• the time in which any litigation or investigations might arise from providing a service.

Individuals’ rights

Individuals have certain rights over their personal data that we process as data controllers.

If we process your personal data and you exercise any of your rights, we will aim to respond promptly and within any required time limit. However, please note that the length of time it will take us to respond will be dependent on the nature and extent of your request.

You have a right to:

• Access – you can ask us for a copy of the personal data that we hold on you
• Rectification – if you become aware of any errors or inaccuracies concerning your personal data, please let us know either by updating your details on the website or applications you are registered with or contacting us.
• Withdraw consent – where we process personal data based on consent, you have a right to withdraw consent at any time. To stop receiving direct marketing emails from us, please click on the unsubscribe link in the relevant email. For any other withdrawals of consent please contact our DPO office.
• Erasure/deletion- you can ask us to erase or delete your personal data when we no longer need it for the purposes it was obtained.
• Data portability- you can ask for your personal data to be sent to you or to another organization
• Review automated decision making – if we make automated decisions about you, you can ask for those decisions to be reviewed
• Restrict or object to our processing – you can ask to restrict or object to our processing of your personal data (e.g. removal from a marketing subscription list).

If you wish to exercise any of the rights, please send an email to Data Protection Officer (DPO) – see the contact details below.

Disclosure Of Data

Legal Requirements

Enactia.com may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Enactia.com
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Publicity

We may mention, in appropriate circumstances, that you are, or have been, a client of ours and the type of services provided. This will not involve the disclosure of your private or confidential information. You agree that we may consider it appropriate to seek publicity on our involvement with the provision of the Services unless you withhold your consent for such publicity.

Security Of Data

Security is of utmost importance to us. Whilst no data transmission over the internet or any other network can be guaranteed as 100% secure, we take all reasonable steps to safeguard the personal data we hold, and we have in place appropriate technical and organizational security measures in order to protect personally identifiable data and information from loss, misuse, alteration or destruction. These include detailed policies, procedures and training of our people relating to data protection, confidentiality and information security. These are regularly reviewed to ensure they are effective and fit for purpose to prevent any unauthorized or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.

Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered that tracks and reports website traffic. Google Analytics uses the data collected to track and monitor the use of our Service. You can opt-out of having made your activity on the Service available to Google Analytics .

For more information on the privacy practices of Google Analytics , please visit the Google Analytics Privacy & Terms web page: https://policies.google.com/privacy?hl=en 

Visitors and others

Website

Visitors to our website are usually in control of the personal data shared with us.  We may automatically collect a limited amount of personal data about visitors to our website by using cookies (refer to our Cookie Policy). We accept personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example, when an individual fills out our contact form.

When you register with us, use our services, make an enquiry, order products or services from us, you may be asked to provide some personal data such as your name, address, job title, company, phone number and email address. We log your Internet Protocol (IP) address in order to receive and send information from and to you over the internet. We may also log the details of the pages you visit and which browser you are using.

We would not expect to receive any sensitive personal data from any inquiry made using our website, such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sex life or sexual orientation, or criminal records. If you choose to provide such sensitive data, you are giving your explicit consent for us to process it for reasons you are choosing to provide it.

Where you do provide personal data to us, we will only use it for the stated purpose at collection or any purpose obvious in the circumstances of the collection, e.g.: 

• registering to use parts of the website
• subscribing to newsletters, blogs, events invites or other direct marketing
• registering to attend an event
• making an enquiry
• entering a discussion forum
• requesting a document such as reports
• We will indicate where it is necessary for you to provide information or where it is voluntary to enable us to handle your request. We usually only ask for extra information, so we can provide the most suitable response to your request.

Unless asked not to, we may use your contact details to provide information about us, our services and activities, including events that may be of interest.

Personal data collected via our website will be retained by us for as long as necessary.

Recruitment

When applying online for a role with us, applicants will need to supply sufficient information for us to be able to evaluate their application. We will usually require that you provide your name, contact details, details of your qualifications, skills, experience, employment history and information about your expectations. We may ask for other personal data (including special categories of data and criminal records) during your application or after we’ve made an offer, we will explain why and how it will be processed when it is requested. We may also collect personal data about you from third parties, such as references supplied by former employers or conduct background checks.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Inaccuracies and Corrections

We would like to keep your personal data accurate and up to date. If you become aware of any errors or inaccuracies please let us know by contacting us at our registered office or our Data Protection Officer (DPO) – see the contact details below.

Contact Us

If you have any questions about this privacy policy, wish to complain about our use of personal data or exercise one of your rights, please send your correspondence to our Data Protection Officer:

Data Protection Officer (DPO)

E-mail: dpo@enactia.com