ENHANCE, INC.

PRIVACY POLICY

  

Enhance, Inc., (“ENHANCE”, “we” or “us”) is the owner of the site www.enhance.co, and its related sub-domains and affiliated sites (collectively, the “Site”). ENHANCE recognizes that your privacy is important to you, and the security of your personal data is important to us, as well. We want you to be as comfortable as possible using the Site and the Services (as defined in the Terms of Use, located at https://www.enhance.co/about/terms-of-service) provided by ENHANCE. Therefore, we have developed this Privacy Policy which details important information regarding the use and disclosure of user information we may collect from individuals who access and/or use our Site and/or Service. Users of the Site that register for the Services shall be “Clients.

This Privacy Policy is incorporated into and subject to the Terms of Use. Each time that you access or use our Service and/or Site you signify that you agree to be bound by the Terms of Use and this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must discontinue use of the Site and the Service.  Any terms not defined in this Privacy Policy shall have the respective meanings given to them in the Terms of Use.

 

I. INFORMATION WE MAY COLLECT

 

Information Provided by You.

 

Registration. We will collect and store personal data you enter when registering for the Service or logging into the Site. In order to register for the Service, you must complete the sign-up form by providing the requested contact and registration information (“Client Information”). The types of personal data collected may include, but not be limited to, your name, email address, date of birth, gender, company information, company title, password, payment information, and phone number. The information you provide is used for such purposes as allowing you to set up a user account, to add and edit apps, improve the content of the Service, customize the advertising and content you see, and communicate with you about specials and new features.

 

Web Logs. Like most standard website servers, we log IP addresses (a unique number that identifies each computer on the Internet) to improve security, analyze trends and administer the Site and Services. We may collect information about you and your interactions within the Site and via the Services, which may include the browser you are using, the IP address and operating system of the computer you used to access our Site or Service, your usage of our Site and Services, and your response to our marketing materials. We use this information in the aggregate to gauge the effectiveness of our Site, Service and marketing efforts, improve security, personalize your experience and improve our interactions with you.

 

Cookies. To help make sure you receive information that is relevant to you, our Site and Services use “cookies.” We use session cookies to make it easier for you to navigate our Site and use our Services. A session cookie expires when you close your browser. In addition, we use persistent cookies to identify Clients, customize the content of certain sections of the Site and/or Services, and to enable us to personalize and improve your experience on the Site and/or Services. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Cookies help us learn which areas of our Site and Services are useful and which areas need improvement. In addition, we may use remarketing technology to advertise on other websites you may visit. In doing so, a third party may place or read a unique ad-serving cookie on your device and use technical information about your browser and your activity on our Site and/or Services to serve advertisements to you on websites which we do not own and/or operate.  You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Site and Services, but your ability to use some areas of the Site and Services may be limited, and you may not be able to use certain features of the Site and Services.

This Privacy Policy covers the use of cookies by ENHANCE and its service providers and does not cover the use of cookies by any advertisers and/or Clients.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s ("NAI") educational page by clicking here.

You can opt out of targeted advertising by following the instructions set forth on the pages below:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

App Info. In order to provide the best user experience, along with giving you valuable insight into your App and its performance, ENHANCE collects info about your App. Some of this information you provide directly via the Services, and other information we collect based on your activity on the Site, Services and your Apps.

 

II. HOW WE MAY USE YOUR INFORMATION

 

Service Providers. We may use third party service providers (i) to help us operate our business and the Site or administer activities or services on our behalf; and/or (ii) to provide Clients with products and services via the Services jointly or as a third party service provider. We may share your information with these third parties for those limited purposes, including information about your App(s) as related to any transactions you partake in with these third parties.

Internal Marketing. We may use your information for internal marketing purposes, including, but not limited to, promoting the Site and the Service to visitors and Clients.

 

Aggregate Data. We may develop, use and share with third parties information about how Clients use the Services and the Site, in non-personal aggregate form. This information will not identify any specific individual, but rather, reflect the collective behaviors and demography of users on the Site and Service.

 

Other Uses. We may use your information to contact you about the Services on our Site for which you have expressed an interest, for example, if you have contacted customer service or made an inquiry.

 

Announcements. If you are a Client, we may send you service-related announcements and emails from time to time relating to your account. We may also send you service-related announcements when it is necessary to do so. For instance, if any service is temporarily suspended for maintenance, or the delivery of a service is delayed we might send you a notice, or if there is some service issue with something you might have requested. You may not opt-out of these communications, which are not promotional in nature.

 

Legal Matters; Safety. We may, without prior notice, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Use, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat.

 

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, any and all personal data, including personal data, of our visitors and Clients may be one of the assets sold or merged in connection with that transaction. Information about visitors and Clients may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding. In such transactions, personal data will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.

 

III. ACCESS TO YOUR INFORMATION

 

Clients may deactivate their account at any time by contacting info@enhance.co. If for any reason you are concerned that the personal data you provided to us is not correct and you cannot change it by accessing your account, or should you wish to have your email address removed from our mailing list or contact information changed, please contact us or send an e-mail to info@enhance.co. We will be happy to review, update or remove information as appropriate. Notwithstanding the foregoing, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity to improve our Services, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements and constraints related to the security, integrity and operation of our Site. Further, we may maintain certain information about your and others use of the Service in aggregate, non-personal form. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

 

IV. CHOICE AND OPT OUT

 

You may remove your information from our database so as not to receive future communications or to close your account by emailing us at legal@enhance.co

 

If you are in the EEA, you have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise them, please contact us using the contact details above at any time. For your reference, you have the right to request that we: (i) provide access to any personal data we hold about you; (ii) correct any incorrect or outdated personal data which we hold about you; (iii) erase any personal data which we hold about you with certain exceptions as described below; (iv) consider valid objections or limit the way we use of your personal data, including for direct-marketing purposes, as applicable; (v) your personal data to a third-party provider of service to the extent applicable and commercially reasonably possible; (vi) withdraw your consent in cases where we rely on your consent in order to use your personal data for any reason at any time.

If you have any other questions or would like to make a request about your data, you can also contact our Data Protection Officer at legal@enhance.co.

If you prefer not to receive electronic promotional communications from us, you can also opt-out by following the unsubscribe instructions included in each communication.

 

Please note, requested changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal data removed from our database. You may also be required to provide us with information necessary to confirm your identity before responding to any requests you make.  We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personal data, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. In addition, certain personal data information may be exempt from requested changes in certain circumstances.  Finally, we are not responsible for informing third parties (including without limitation our third party service providers or affiliated companies) with whom we have already shared your personal data of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

 

V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

 

Links to other sites. When visiting our Site and using the Services, you may have access to various third party sites. To the extent hyperlinks may be utilized to access external or third party sites or if you come to our Site through a link from any such third party sites, you should be aware that these external or third party sites are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you check the privacy policies of these sites to determine how your information will be utilized by the proprietors of those third party sites and to establish whether and for what purpose they collect it.

 

Client use of personal data.  We also process personal data on behalf of our Clients who use our Services.  In those situations, there is a written contract in place between us and our Clients which sets out our data protection obligations.  It is the Client who determines the purposes and means of processing such personal data under such contracts.  For clarity, we neither control what personal data our Clients collect nor how they use it, and we are not responsible for our Client’s privacy policies.  This Privacy Policy neither applies to such Clients’ use of personal data, nor to our processing of such personal data for such Clients.  You should consult the terms and conditions and privacy policy of the relevant Client to determine they use your information and to establish whether and for what purpose they collect it.

Security. Your account information is protected by a password for your privacy and security. ENHANCE endeavors to safeguard user information to ensure that user account information is kept private. However, despite these efforts, no system can completely guaranty that there will never be unauthorized access to your personal data, and your use of the Site indicates that you are willing to assume this risk. You need to prevent unauthorized access to your account and your information by selecting and protecting your password appropriately, and limiting access to your computer and browser by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Data Retention.  We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law.  In addition, we will retain your personal data for as long as your account is active (as applicable for Clients) or as needed to provide you with our Services.  

 

International Users. The Site and Service is hosted in the United States. If you are accessing the Site from outside the United States, by providing your information to the Site and using the Service, you hereby consent to the transfer of your information to the United States for processing and maintenance in accordance with this Privacy Policy and our Terms of Use. You are also consenting to the application of United States law in all matters concerning the Site and the Services.

 

Children’s Privacy. The Site is not directed or intended for children under 16 years of age. We do not knowingly collect personal data from individuals under 16 years of age. If you are under 16 years of age, you should not register or provide personal data on the Site. Should we become aware of a child under the age of 16 registering with our Site, we will promptly remove all such information associated with that account.

 

Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the “Effective Date” posted at the top of the Privacy Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal data, you will know because the Effective Date of the Privacy Policy will change. If we are going to use any personal data in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change to the extent applicable. If you do not consent, your personal data will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By accessing our Site or Service after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the privacy policy in effect when the information was obtained from you.

 

Applicable Law. If you choose to visit the Site or access our Services, your visit and/or use and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, and governing law. By visiting the Site, you agree that the laws of the State of California, without regard to its conflict of laws principles, govern this privacy policy and any dispute of any sort that might arise between us or our affiliates.

 

Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we may share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the address referenced below, addressed to: 

Enhance, Inc.

Attn: California Privacy Rights.

 

Contacting Us. If you have any questions about this Privacy Policy, or the practices of the Site, please contact us at legal@enhance.co. 

 

Copyright © 2019 Enhance, Inc. All rights reserved.

Effective Date: [March 14, 2019].