Privacy Policy

This privacy policy (“Policy”) describes the personal data Enably Inc (‘We”) collects and how this data is used and shared.

This policy describes how we collect and use personal data. This notice applies to all users of our apps (“users”), websites, features, or other services anywhere in the world.

Enably Inc. is the data controller for the personal data collected in connection with use of Enably’s website.

A. The data we collect

We collect personal data such as:

• provided by users to Enably, such as when submitting a contact form
• from other sources, such as other users or account owners, business partners, vendors, financial solution providers, and governmental authorities

Data from other sources. These include:

• publicly available sources
• marketing service providers or data resellers whose data we use for marketing or research

B. How we use personal data

We also use such data:

• for increase of awareness and improvement of services we provide
• for customer support
• to send marketing and non-marketing communications to users
• in connection with legal proceedings

We do not sell or share user personal data with third parties for their marketing purposes without their users’ consent.

C. Cookies and third-party technologies

We and our partners use cookies and other identification technologies on our apps, websites, emails, and online ads.

We use cookies and similar technologies for purposes such as:

• authenticating users
• remembering user preferences and settings
• determining the popularity of content
• delivering and measuring the effectiveness of advertising campaigns
• analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide analytics services for us to serve advertisements on our behalf, and to track and report on the performance of those advertisements. These entities may use cookies, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

We collect and use personal data:

1. Customer support. We use the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
2. Marketing. We may use personal data to market our services to our users. This includes sending users communications about our services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods such as email, SMS, push notifications, and in app communications and ads.
   We may also inform users about products and services offered by our partners. For example, we may provide recommendations, promotions, or ads for our partners based on users’ service request behaviors and order histories. Even though we inform users about products and services offered by our partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.
   We may use the data we collect (including in combination with advertising partners’ data) to personalize and improve the marketing communications (including ads) that we send on and off otegari app and website, including based on use of our services, and user preferences and settings.
3. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of our services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.

D. Data disclosure

We share personal data with other users if requested by users. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

We may share personal data:

1. With our service providers and business partners
   

   We provide personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

   • cloud storage providers
   • social media companies, including Facebook, in connection with otegari’s use of their tools in otegari app and websites (see Facebook’s privacy policies for information on their collection and use of data)
   • Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
   • research partners
   • consultants, lawyers, accountants, and other professional service providers
2. For legal reasons or in the event of a dispute
   We may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
   This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
3. With consent
   We may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.