Ensono Privacy Policy

1: Policy Statement

Ensono, Inc. and its affiliates (“Ensono,” “we,” “us,” or “our”) are committed to respecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, and protect “Personal Information” we obtain from individuals, associates, customers, and contractors (“you”) through our website (collectively, our “Site”), products, and services (collectively, the “Services”), and from third party and publicly available sources, as further described below. Please read this Privacy Policy carefully before you start to use our Services, whether online or offline. When referenced in this Privacy Policy, the term “Personal Information” (i.e., Personal Data or other similar terms as defined by applicable law) includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws.

For purposes of this Privacy Policy, Ensono is the controller (i.e., responsible party) of the Personal Information described in this Privacy Policy. However, we also provide and administer the Services on behalf of customers and act as a processor or service provider relative to such customers. This Privacy Policy does not apply in that regard, and we recommend that you review the privacy policy of such third-party customers with whom you are dealing directly as they will be responsible for the handling of your Personal Information.

If you have any questions related to Privacy at Ensono, please contact us at [email protected].

2: Scope

This Privacy Policy applies to all our data users, regardless of location, who process personal data for or on behalf of Ensono, including without limitation for:

Business operations.
The provision or offer of products and services.
Monitoring visitors’ preferences to our websites by using data processing techniques such as web browser cookies to best direct them to relevant content, products, or services.

3: Roles and Responsibilities

All Ensono employees, suppliers, and data users assist in protecting the personal information for which Ensono is responsible (including personal data of Ensono colleagues, clients, business partners, and other data subjects with whom we have business interactions) in compliance with all applicable laws, regulations, and other Ensono policies and procedures.

4: Ownership

Publishing, monitoring and enforcement of this policy shall be with Ensono’s Legal, Compliance & Continuity, Information Security and CPE teams. Any questions about the operation of this policy or any concerns that this policy needs to be followed should be referred to [email protected].

5: Policy

Categories of Personal Information We May Collect

The types of Personal Information we collect about you depends on how you interact with us. Depending on the Services you use, the following are the categories and specific types of Personal Information that we may have collected in the preceding twelve months:

Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information, or other similar identifiers and account information.
Government Identifiers, including driver’s license number (in certain instances may be considered sensitive personal information).
Information Specific to the Services, in certain instances, such as invoices, business and commercial communications, order status and history.
Demographic Information, including age and gender, some of which may include characteristics of protected classifications under state or federal law.
Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.
Internet or Other Network Activity, including browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.
Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
Payment Information, including credit or debit card number, or other financial information.
Inferences, inferences drawn from or created based on any of the information identified in this section.
Sensitive Personal Information (where permitted and in accordance with applicable law, including for employment purposes), of the information listed above, social security number, racial or ethnic origin, username and password and/or health information are also sensitive personal information.

The provision of the Sensitive Personal Information listed above is voluntary. In certain instances, we will not be able to process your request for our Services without the requested Personal Information.

If you do not provide us with certain Personal Information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or request for customer service or to provide the full functionality of our Site or Services to you. However, unless otherwise specified, not providing your Personal Information will not result in legal or other consequences to you.

Sources of Personal Information

We collect your Personal Information in the following ways, pursuant to applicable law:

Directly From You, such as when you use our Services, create an account and profile with us; sign up with us to receive marketing communications; or otherwise reach out to us.

Other Sources, including vendors, affiliates, and through tracking technologies. To learn more about our use of cookies and similar tracking technologies, please review the “Cookies and Other Tracking Technologies” section below.

Use and Processing of Your Personal Information

We may use your Personal Information, and in limited circumstances your Sensitive Personal Information for the following business purposes (“Processing Purposes”) associated with our general business operations. We may collect your Personal Information for the following Processing Purposes:

To provide you the Services and propose service improvements.

If you attend an event, we may collect your information to contact you.
To enable you to access and use our Site.
To communicate with you and to respond to your requests, questions, comments, and other inquiries.
To understand what partner resources you use, if any, and to connect you to additional resources at your request.
To send marketing and promotional materials, including information relating to our products, Services, sales, or promotions or those of a third party.
To administer, maintain, evaluate, and improve our websites and Services, and to develop new products and services.
To conduct research and analytics related to our Site and Services.
For marketing and promotional purposes to show you advertisements for products and/or services tailored to your interests on social media and other websites, which you may be able to opt out of as explained in the “Your Rights” section.
To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
For other purposes with your consent, or as otherwise permitted or required by applicable law.
To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
We use Personal Information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Ensono and our users, customers, employees, or others.

Use of Your Sensitive Personal Information

With regard to Sensitive Personal Information you provide, if any, we only use your Sensitive Personal Information to provide you with the requested products or services, to administer your account or application, or with your consent.

Legal Basis of Processing

Where a legal basis for processing is required (e.g., in the European Union and the United Kingdom), we process your information for the Processing Purposes described in this Privacy Policy based on the following legal grounds:

With Your Consent: In certain instances, we ask for your consent to process your Personal Information for specific purposes. Provision of your consent is voluntary, and you have the right to withdraw your consent at any time.
When Pursuing Legitimate Interests: We process your Personal Information for our legitimate interests and those of third parties, while applying appropriate safeguards that protect your privacy, and as further described in this Privacy Policy.
To Perform a Contract With You: We will process your Personal Information when processing of your Personal Information is necessary for the evaluation, execution or performance of a contract with you.
When We Have Legal Obligations: We will process your Personal Information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request, including law enforcement.

In some cases, your provision of Personal Information may be required by a statutory or contractual obligation.

Disclosure of Your Personal Information

To the extent that we have collected or processed your Personal Information in the prior twelve (12) months, we may have disclosed the above-listed Personal Information as described below.

Service Providers. We may disclose Personal Information to authorized third parties who perform services for us (including cloud services, data storage, sales, human resources, and marketing). Our contracts with our service providers include commitments that they agree to limit their use of Personal Information and to comply with privacy and security standards.
Affiliated Companies. We may disclose such Personal Information with subsidiaries, or affiliates as needed to provide our products and services and generally as necessary in the administration of a global organization.
Subsequent Owner or Operator. We may disclose your Personal Information in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, insolvency or other corporate change.
Social Media Platforms. Some of our websites may have features such as, plugins, widgets, or and other tools made available by social media platforms and networks that may result in information being collected or shared between us and these platforms. This Privacy Policy does not govern their subsequent use of your information.
Authorities and Regulators. We may disclose your Personal Information to legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or in relation to a legal activity, such as in response to a subpoena or an investigation of suspected illicit activity. We may also disclose such Personal Information if we believe disclosure is necessary to prevent physical, financial, or other harm, injury, or loss.
Deidentified Personal Information. We may disclose or use aggregated or de-identified data for any lawful purpose. Deidentified information is generally not considered to be Personal Information under applicable laws.
Additional Disclosures: From time to time, we disclose your information to our attorneys, banks, auditors, securities brokers, and other professional service providers and advisors in connection with the purposes described above.
Partners. We may disclose your Personal Information to our partners with your consent, where required.
Other Disclosures With Your Consent. We may disclose your Personal Information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.

Security Measures

We use various reasonable safeguards (administrative, organizational, technical, and physical) to protect the Personal Information we collect and process. Our security controls are designed to maintain an appropriate level of confidentiality, integrity, and availability of your Personal Information. Nonetheless, no such measure is 100% effective; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information. In the event of an incident that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone, if permitted to do so by law. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as specified in the “Contact Us” section below.

Data Retention

The time periods for which we retain your Personal Information depend on the purposes for which we use it and applicable law for the type of data and use. Ensono will keep your Personal Information for as long as you are a registered subscriber or user of our Services or for as long as we have a valid business purpose or legal basis to do so and, thereafter, for no longer than is required or permitted by law. The Personal Information we collect may be stored and processed in servers in the United States and/or other jurisdictions where Ensono, or our service providers, have facilities.

Children’s Privacy

Our Sites and Services are not intended for use by children under the age of 16.

International Data Transfers

Ensono is headquartered in the United States and we have operations, entities, and service providers both in the United States and throughout the world. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area or the UK, we provide adequate protection for the transfer of Personal Information to countries outside of these areas, such as through the use of authorized EU Standard Contractual Clauses, the UK Standard Contractual Clauses, or the UK Addendum to the EU Standard Contractual Clauses. Depending on your location, you may have the right to request a copy of such appropriate safeguards by contacting us as set out at the end of this Privacy Policy.

Cookies and Other Tracking Technologies

A cookie is a string of information that a website saves on a visitor’s computer and then the visitor’s browser provides to the website operator each time the visitor returns to the information collecting website. When Ensono collects cookies or makes use of a browser’s local storage capabilities, they help Ensono identify visitors, their usage of the site, and their website access preferences. Ensono may also use information derived from cookies or local storage to direct the visitor to information similar to what they visited and thereby market Ensono products and services by personalizing the experience on the visitor’s web page on Ensono’s Site. More information about cookies and how they work is available at www.allaboutcookies.org. If you would like to change what cookies Ensono places on your computer when you visit our Site, please click on the cookie settings button. If you use a different device to access the same Services or Site, you may need to manage your settings for each separate device you use.

Our websites use cookies to tailor web content to match your browser capability. You can set your Internet browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. If you reject the cookie, you may still use this site, but you may be limited in the functionality of some areas.

Cookies on our website are generally divided into the following categories:

Cookie Type	Description
Strictly Necessary Cookies	These are cookies that our website needs in order to function and that enable you to move around and use the website and features. Without these essential cookies, the website will not perform as smoothly for you as we would like it to, and we may not be able to provide the website or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Functional and Performance Cookies	Analytics cookies provide us with information regarding how visitors navigate and interact with our website. Such cookies allow us to understand, for example, more about how many visitors we have to our website, how many times they visit us and how many times a user viewed specific pages within our Site. Among other Analytics cookies, we use Google Analytics cookies for these purposes. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.
Targeting and Social Media Cookies	Targeting and Social Media cookies may be placed by us or third parties to enable third party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and shared by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our website and third-party sites based on those interests.

Links to Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Ensono. Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites. This Privacy Policy only applies to Personal Information collected through our Services or on this Site. We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with Ensono.

Your Rights

You may have certain rights regarding your Personal Information. The rights available to you depend on our reason for processing your Personal Information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, the European Union, or United Kingdom). Specifically, you may have the following rights:

Right to access: You may have the right to obtain from us confirmation as to whether Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. This access to information includes the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed, among other categories of information.
Right to rectification (right to correct inaccurate information): You may have the right to request that we correct any Personal Information about you that is inaccurate. Depending on the purpose of the processing, you also have the right to request that we complete the Personal Information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.
Right to erasure (right to be forgotten): You may have the right to request that we erase your Personal Information, under certain conditions.
Right to restrict processing: You may have the right to request that we restrict the processing of your Personal Information, under certain conditions. In such case, the respective data will be marked and may only be processed by us for certain purposes.
Right to object to processing: You may have the right to object to our processing of your Personal Information. Such right to object may especially apply if we collect and process your Personal Information through automated decision making, such as profiling, to better understand your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, your Personal Information will no longer be processed by us for such purposes. Such a right to object may, in particular, not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Right to data portability: You may have the right to request that we transfer the Personal Information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
Right to withdraw consent: Where we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Right to know what Personal Information is sold or shared and to whom, and right to prohibit the sale or sharing of Personal Information: We do not and have not in the preceding 12 months, sold your Personal Information. However, we have shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. You may opt-out of the sharing of your Personal Information by updating your preferences under the “Your Privacy Choices” button.
Right to limit the use and disclosure of sensitive Personal Information: We will only use sensitive or special Personal Information as needed for the purposes for which it was collected. If this changes, we will notify you, and you may have the right to restrict such additional uses.
Right of non-discrimination/retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Policy.

Opt-out Preference Signal (Do Not Track)

Ensono does not currently recognize Do Not Track signals. However, we recognize commercially reasonable universal preference signals (e.g., Global Privacy Control).

Changes to This Privacy Policy

As Ensono grows and our business changes, we may modify, expand, or update this Privacy Policy at any time as we deem appropriate to reflect those changes. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on the Site and update the Privacy Policy’s “last updated” date above. It is important that you check back from time to time and make sure that you have reviewed the most current version of this Privacy Policy. If you do not agree with the changes, then you should stop using our Site and Services and notify us that you do not want your Personal Information used in accordance with the changes.

Contact Us

If you have questions or comments regarding this Privacy Policy or our privacy practices, please contact us at [email protected]. You may also have a right to lodge a complaint with a data protection supervisory authority or an attorney general, if applicable.

Ensono, Inc
3333 Finley Rd, Downers Grove, IL 60515
Attention: Data Privacy Officer

This Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Effective Date: April 22, 2024
Last Updated: April 22, 2024