Effective December 31, 2020
This policy of Enservio, LLC (referred to as "Enservio”, “we”, “us” or “our”) explains our policy concerning the collection and processing of personal data, and tells you about your privacy rights and how the law protects you. Enservio respects your privacy and is committed to protecting your personal data. The information that we receive through our website depends on what you do during your visit.
Our websites and services are not intended for use by minors under the age of 16 and we do not knowingly collect data relating to children.
1. IMPORTANT INFORMATION AND WHO WE ARE
Attn: Data Privacy Champion
117 Kendrick Street, Suite 250
Needham, MA 02494
Our Data Privacy Champion has been appointed to ensure that personal data is processed according to law and this notice. In many jurisdictions, you have the right to make a complaint at any time to a regulatory agency for data protection issues or collection and use of personal data. We would, however, appreciate the chance to deal with your concerns so please contact us first.
Enservio acts as a service provider of personal data to third parties.
Some of our websites and services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they process personal data. We encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed such as de-identified or anonymous data. We follow the law in each applicable jurisdiction in determining what constitutes personal data.
We may collect, use, store, and transfer different kinds of data which we have grouped together as follows:
- Identification Data such as a name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Financial Data such as bank account, credit card and debit card numbers, and other financial information.
- Commercial Transaction Information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Technical Data such as internet protocol address, login data, browser type and version, time zone setting, data on devices used to access a website, service or application, browsing history, search history, and information regarding interaction with an internet website, application, or advertisement.
- Usage Data such as how you use our website or service.
- Geolocation Data such as latitude and longitude for your location.
- Employment Information such as information about employment or a profession.
- Education Data such as information about education.
- Inference Data such as information drawn from other information reflecting preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
- Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly identify you. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect Special Categories of Personal Data about you, such as race or ethnicity, trade union membership, criminal convictions and offences, but only where required to provide services to you or our customers.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes data you provide when you:
- apply for, inquire about, or purchase our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical, and Usage Data among others about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical and Usage Data among others about you if you visit other websites employing our cookies.
- Customers. Customers who use our tools and services may provide us personal data for use in those services.
- Third parties or publicly available sources. We may receive personal data about you from third parties and public sources.
4. HOW WE USE YOUR PERSONAL DATA
All information provided is treated as confidential. Enservio does not, and will not, pass any personal information collected through any Site to any other third party, other than in connection with the Services. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We use personal data when necessary to perform contracts, provide you services and to comply with our legal obligations or form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. Enservio does not sell personal or business information for marketing or solicitation purposes.
You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not affect our processing of your personal data for other non-marketing purposes such as providing a product/service to you, warranty registration, product/service experience, or other transactions, etc.
You can make choices about what cookies collect information on our websites. You may be able to set your browser to refuse all or some browser cookies. If you disable or refuse certain cookies, some parts of the website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with:
- Other companies in the Solera group of companies who are involved in providing the service or product or provide IT and system administration services and undertake information reporting.
- Our customers who are providing services to you.
- Our service providers who provide IT and system administration services.
- Our professional advisers such as our lawyers, bankers, auditors, and insurers.
- Government agencies that require reporting of processing, financial, or transaction activities, but only as required by law.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. OUR ACTIONS OVER THE PAST TWELVE MONTHS
The following table provides additional information on the personal information collected in the last twelve months:
Categories of Personal Information collected
Categories of Sources of such Personal Information
Purpose for which the Personal Information was collected
Categories of third parties with whom the Personal Information is shared
Commercial Transaction Data
Marketing and Communications Data
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. YOUR LEGAL RIGHTS
Residents of California
Under certain circumstances, you have the right to:
- Request disclosure of what personal information the business collects, uses, discloses, or sells by submitting a request through the webform located at the “Exercise your Rights” link on the Enservio.com website or https://privacyportal-cdn.onetrust.com/dsarwebform/20bbc57b-6134-4535-8062-a1745b771851/379a18ad-03dc-47bc-937a-3c70ce793101.html.
- Request deletion of personal information collected or maintained by us. You must make this type of request through the webform located at the “Exercise your Rights” link on the Enservio.com website or https://privacyportal-cdn.onetrust.com/dsarwebform/20bbc57b-6134-4535-8062-a1745b771851/379a18ad-03dc-47bc-937a-3c70ce793101.html. We will ask you to verify that you have requested deletion of all or certain personal information.
- Non-discrimination. Your exercise of privacy rights conferred under the California Consumer Privacy Act (“CCPA”) will not result in discriminatory treatment.
- Use an authorized agent. California law allows you to use an authorized agent to make a request under CCPA on your behalf. You must provide us with written documentation that the agent is authorized to act on your behalf or a power of attorney. We may also contact you directly to verify your identity.
NOTICE TO CA RESIDENTS: Where we receive valuable consideration for the provision of personal data to third parties, we do so as a service provider for a third party. We do not sell information that identifies a person to other businesses. We have not sold personal information, as those terms are defined in the CCPA, within the last twelve months.
You may have rights under data protection laws in relation to your personal data. Contact us for more information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If your request provides an email address, or our records contain your email address, we may ask you to verify your identity through such address. Where additional information is required, we try to ask only information that can be corroborated through our records. We may also ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within forty-five days (or thirty days for residents in the EU). Occasionally it may take us longer. If so, we will notify you and keep you updated. If we deny your request, we will explain the basis for such denial. We will keep a record of rights requests and responses for at least twenty-four months in a log that will not be used for any purpose other than for record-keeping and analytics.
DOCUMENT CHANGE HISTORY
Changes made from Previous Version
December 31, 2019
December 31, 2020
Reviewed policy; updated date; changed “Enservio, Inc.” to “Enservio LLC” throughout.