Privacy and Security Policy

ENME SIA (“ENME” / “we” / “our” / “us”) offers tools and platform which provide the means to measure and increase employee commitment by giving them a voice within their organization. ENME understands the importance of protecting personal information. For this reason, ENME strives to have business procedures and security safeguards in place to protect personal information under its control.

This policy sets out the basis on which we will process any personal data we collect from you or that you or your employer provides to us through your use of the ENME online software platform (the “Platform”).

This Policy also governs personal information collected about ENME website users and explains how ENME uses and discloses personal information collected from people who visit its website and otherwise interact with ENME through https://www.enmehr.com (the “Website”). It also explains how ENME uses cookies and similar technologies.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting https://enmehr.com/ or using the Platform you are accepting and consenting to the practices described in this policy.

GENERAL TERMS AND EMPLOYER ACCEPTENCE

Your employer has accepted the “General Terms” (General Terms) set by ENME, that are accessible for further reading on our website.  In accordance to General Terms you have been granted access to the. For the purpose of the Data Protection Act 1998 (the Act), your employer is the data controller. ENME will process your personal information on behalf of your employer and in accordance with its lawful instructions. The information you provide to us and/or upload to the Platform (whether or not it constitutes personal data) will also be governed by the General Terms.

References in this policy to “your employer” shall refer to the entity who has entered into the General Terms with us, whether or not as a matter of law you are an employee, consultant or contractor of that entity, and such references are not intended to characterize or prejudice your status vis-à-vis that entity.

INFORMATION ENME COLLECTS ABOUT YOU 

We will collect and process the following data about you

Information you provide us

You may give us information about you:

•         when using the Platform’s functions, including by filling in forms or completing surveys on or via the Platform. The extent of the information collected in engagement surveys is set by your employer. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location, as well as any views you provide to us about your performance in your role, or information regarding your employer, your colleagues or other third parties during the course of completing engagement surveys or otherwise using the Platform;

·         if you contact or correspond with us (for example, using any support function made available by us), we may keep a record of that correspondence (either directly or through our service providers).

Information your employer provides to ENME

Your employer may give us information about you:

•         when creating a user profile for you in order to enable you to access the Platform under the General Terms (whether on a trial or full basis) or to enable us to send engagement surveys and similar communications to you. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location;

•         otherwise in the course of your employer’s use of the Platform.

Information ENME collects from you

Each time you complete an engagement survey or otherwise use the Platform we may automatically collect the following information:

•         when you use the Platform, we will keep a record of the details of that usage, including the date, time, location, frequency and duration of the usage;

•         if you are an administrative/HR user using the Platform as a representative of your employer, we may obtain further information about you from your employer, for example to verify your eligibility to access and use the Platform;

•         any comments, opinions and/or feedback you provide to us regarding the Platform, for example during any trial period that you may participate in or thereafter;

•         technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type;

•         other information about your use of the Platform, including the pages you have viewed, the duration spent on the Platform and data files you have uploaded to the Platform. This information may be linked to your user profile (where relevant).

Information we receive from other sources

We work closely with third parties (including for example, business partners, other companies within our group, subcontractors and analytics providers) and may receive information about you from them.

 THE USE OF YOUR INFORMATION 

Please note, we are permitted to collect, use, disclose and/or otherwise process any data or information other than personal data, including any data you upload to the Platform or otherwise provide to us, to the fullest extent permitted by the General Terms.

We may use the personal information we hold about you in the following ways:

Information you provide us

We will use this information to:

•         if you are an administrative/HR user, process your application to become a registered user of the Platform and verify your eligibility to use the Platform;

•         carry out our obligations arising from the General Terms. This includes providing your employer with reports and analysis summarizing information provided during your use of the Platform, including in any engagement surveys, aggregated with information from other employees and personnel, and (where relevant) comparing this data with past or future employee responses and/or industry benchmarks. Data you provide to us will never be used to personally identify you, unless you explicitly choose otherwise. All survey responses are entirely optional: individual questions (or the entire survey) may be skipped and there is no requirement for any surveys to be completed;

•         provide you with information, products and services you request from us. We will not contact you for promotional or marketing purposes, such as to inform you of new products or services that we offer, unless you specifically consent to this at the time you provide your details to us or you expressly request (or provide explicit consent for) us to do so at a later date;

•         contact you for your feedback on our services and to help us evaluate and improve our services, for example by acting on any information you have provided to us;

•         notify you about changes to the Platform and any other services of ours that you use, including informing you about new versions of the Platform and about new features, functionality and service offerings; or

•         deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your employer) involving you and any issues caused by your use of the Platform.

Information ENME collects from you

We will use this information:

•         to administer and improve the Platform and other services, including ensuring that content is presented in the most effective manner for you and for your computer;

•         to report to your employer relating to the use of the Platform, as may be required under the General Terms, provided that we will never provide an employer with information about the responses of a particular individual to a survey via the Platform;

•         for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

•         to allow you to participate in interactive features of the Platform, when you choose to do so;

•         as part of our efforts to keep the Platform safe and secure; or

•         to compile reports (which do not personally identify you) of usage of the Platform.

Information we receive from other sources

We may combine information from other sources with the information you give to us or we collect about you and use this information as specified above.

We will not undertake any surveys or analysis via the Platform by reference to any of the following special categories of personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation.

Data collected from you and other employees or personnel may be used by us in an aggregated and anonymized form for statistical and benchmarking purposes including enabling comparisons to other organizations within the same industry.

COLLECTION AND USE OF PERSONAL INFORMATION THROUGH WEBSITE

ENME generally collects and uses personal information from or about its website users as follows:

Information provided by users.

In many cases, ENME collects personal information directly from users when they visit or use the website. For instance, ENME may collect the following types of information:

•         Inquiries and Requests for a Trial or service. ENME may collect users’ name, contact information, e-mail address and any other information provided when users make an inquiry or contact ENME through the website, when users sign up to receive ENME’s newsletter or when users submit a request or an order for an ENME trial or service. ENME will only use this information to process and answer users’ request or to manage ENME everyday business needs in connection with such request.

•         Personalization of Website. When users visit the website, they may, from time to time, be invited to provide information such as user’s title to help ENME personalize or customize the users experience when using the website.

•         Technical information. When users visit the website, ENME may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the users’ computer and which browser was used to view the website, the users’ operating system, resolution of screen, location, language settings in browsers, the site the user came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, ENME will treat this information as personal information. ENME may also, without limitations, collect and use the following type of information when users visit and/or interact with ENME on the website:

o   Google Analytics: ENME uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of ENME’s use of Google Analytics by visiting the Google Analytics opt-out page.

o   HubSpot: ENME uses HubSpot which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and users may not opt-out of ENME’s use of HubSpot.

o   Google AdWords: ENME uses Google AdWords Remarketing to advertise ENME across the Internet and to advertise on third party websites (including Google) to previous visitors to the website. AdWords remarketing will display ads to users based on what parts of the ENME website they have viewed by placing a cookie on the users’ web browser. It could mean that ENME advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the user or give access to the users’ computer or mobile device. The cookie is only used to indicate to other websites that the user has visited a particular page on the website, so that they may show the user ads relating to that page. If users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.

o   The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.

o    Interest-based Advertising. ENME may also allow a limited number of trusted third parties to install cookies on users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about users, such as page views on the website, information requests or purchases on the website. ENME does not provide any personal information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. ENME does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices.

o   Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell users how to prevent their browser from accepting new cookies, how to have the browser notify the users when they receive a new cookie, or how to disable cookies altogether. If users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.

o   Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by ENME. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.

o   Personal Information from other Sources. ENME may obtain from third parties additional personal information about a website user if such user gave permission to those third parties to share its information.

DISCLOSURE OF YOUR INFORMATION

We may share your personal data with other companies in our group. We may also share your personal information with selected third parties in accordance with this policy, including:

•         service providers, for example of IT services, business partners, suppliers and/or sub-contractors, for the performance of any contract that we enter into with your employer (such as the General Terms), including:

o   Amazon Web Services, Inc

o   MAK IT Sia;

o   Open Feedback Sia;

o   Google, Inc;

•         analytics and search engine providers that assist us in the improvement and optimization of our site and the analysis of data supplied via the Platform, including Google Analytics and Hotjar Ltd.; and

•         government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).

SECURITY OF INFORMATION

You will not ordinarily require a username or password to gain access to or complete a survey or otherwise provide us with information via the Platform. Where we have given you a username, password and/or security information which enables you to access particular features of the Platform (for example, as an administrator or senior manager of your employer), you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them.

We maintain appropriate technical and organizational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features which are appropriate to the type of personal data you have provided to try to prevent unauthorized access or inadvertent disclosure, which may include two factor authentication and end-to-end encryption.

STATUS OF THIS POLICY AND YOUR CONSENT

For some of the uses of your information described above there is a legal basis under applicable data protection laws for us to use the information without your consent.  This includes, for example, where it is necessary for us to use the information in order to provide the Platform to you or where we have a legitimate interest to use it by virtue of the relationship between you and us when providing the Platform to you (for instance, for troubleshooting, data analysis, testing or research purposes). Where this is the case, this privacy policy fulfils our duty to process information fairly and lawfully and in a maner that you would expect given the nature of our relationship with you. This includes giving you appropriate notice and explanation of the way in which your information will be used. 

Where consent is required for our use of your information, by ticking the appropriate consent box or otherwise communicating your consent to us (whether by phone, email or other means), you consent to our use of that information as set out in this policy. If you disclose someone else's information to us, you confirm that you have their consent to disclose this information to us and for us to use and disclose it in accordance with this policy.

RETAINING YOUR INFORMATION

We will retain the personal information we receive and collect about you for a period of 5 years or until six months after our relationship with your employer has ended (whichever is sooner). After this period, your personal data will be anonymized. We will not store your personal data for longer than is reasonably necessary to use it in accordance with this policy or with our legal rights and obligations. For the avoidance of doubt, aggregated and anonymized data and any information other than personal data can be stored indefinitely.

YOUR RIGHTS  

You have the following rights in regards to your personal information:

•         You have the right to access information about the personal data we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable or repetitive requests, or requests for further copies of the same information

•         You have the right to request that we rectify or delete any personal information that we hold about you. Please note, if you request that we erase any personal information that we require in order to provide the Platform to you, you may no longer be able to use the Platform. This right does not extend to non-personal information. Please also note that it is likely to be necessary for us to retain your personal information for the purposes of assessing and verifying data that is submitted and/or held on the Platform, and your rights under applicable law to request erasure may be limited accordingly. We also reserve the right to retain your personal data in an anonymized form for statistical and benchmarking purposes.

•         You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies. You may also request that your personal data is transmitted directly to another organization where this is technically feasible using our data processing systems.

•         You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, but have changed your mind, you have the ability to opt out of receiving marketing communications by emailing us at support@enmehr.com or clicking the relevant link in any communication you receive.

Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to facilitate your use of the Platform, you will no longer be able to use the Platform following your request to stop the relevant processing (this does not include your right to object to direct marketing which can be exercised at any time without restriction).  Please allow at least 5 working days for your request to be actioned. 

•         In certain circumstances you have the right to object to our processing of your personal data. If for any reason you are not happy with the way that we have handled your personal information, you also have the right to make a complaint.

Save as set out above, your rights detailed above can be exercised free of charge in accordance with applicable data protection laws. Please contact your employer directly if you would like to exercise any of these rights (other than a change to your marketing preferences, which should be notified directly to us as described above).

DATA INCIDENTS INVOLVING PERSONAL DATA

ENME shall immediately notify CLIENT of any reasonably suspected or actual loss of data or breach or compromise of its security program which has or may result in the loss or unauthorized access, disclosure, use or acquisition of Client’s personal data or otherwise presents a potential threat to such information (“Data Incident”). While the initial notice may be in summary form, a comprehensive written notice shall be given within 48 hours to Client. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action already taken or to be taken by ENME. ENME shall promptly take all necessary and advisable corrective actions, and shall cooperate fully with Client in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence.

CHANGES TO OUR PRIVACY POLICY 

Any changes we may make to our privacy policy will be posted on this page and where appropriate may be notified to you by e-mail or advised to you on next log in to the Platform. Continued use of the Platform will signify that you agree to any such changes.

 CONTACT 

If you have any questions about this privacy policy, please contact us at support@enmehr.com.


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