Last updated on (the "Effective Date"):
IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SITE.
1. THE BASICS
A. About Us. Our services allows our Clients learn how to improve their English language pronunciation skills using our proprietary online learning application.
“Client” means any person or entity that has registered in order to use the Platform Services including any of that person or entity’s Authorized Users (as defined in a Client’s agreement with Enunc8).
“PII” means any information that personally identifies or can be used to identify an individual directly or indirectly including, but not limited to, name, date of birth, email address, gender, occupation, or other demographic information.
“Platform Services” means our applications including any of their updates or documentation that may be made available by us for your use including but not limited to, their derivative works.
“Visitor” means, depending on the context, any person who visits any of our Sites, offices, or otherwise engages with us.
“you” or “your” means, depending on the context, either a Client or a Visitor.
2. ENUNC8 CLIENTS
This section applies to PII we collect and process through the when you engage with us as a Client. If you are not yet a Client, Section 3 (applicable to Visitors to our Site) may be more applicable to you and your data. In this Section 2, "you" or "your" refers to Clients.
A. Information We Collect. The PII that we collect depends on the context of your interactions with Enunc8, your Enunc8 account settings, the products and features you use, your location, and applicable law. However, the PII we collect broadly falls into the following categories:
(i) Information you provide to us. You (or your organization) may provide certain PII to us when you sign up for a Enunc8 account and use the Platform Services, consult with our support team, send us an email or communicate with us in any other way. We will usually let you know prior to collection whether the provision of PII we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information. The information you provide to us, may include:
Registration Information. You need a Enunc8 account to use the Platform Services as a Client. When you register for an account, we ask you to provide business and professional contact information which may include your job title, organization, location, phone number, or email address;
Marketing information. Including contact preferences and frequency of emails.
Account and Support Information. Account log-in credentials; troubleshooting and support data (for example, data you provide or that we collect in connection with a support query that we receive from you) including, but not limited to, contact or authentication data, the content or transcript of your communication with us, and information regarding the product or service you are using related to your help inquiry.
Payment/billing Information. This may include credit card numbers, associated identifiers, and your billing address.
Historical Information. We may also maintain a record of your purchases, transactional information, your Platform Services history and usage, your support logs and history, and any communications and responses.
(ii) Information we collect automatically. When you use the Platform Services, we may automatically collect or receive certain information about your device and usage of the Platform Services which may include:
Device information: We may collect information about your device and the applications you use to access the Platform Services, such as your IP address, operating system, browser ID, or other information about your system and connection.
Log data: We keep log files on our web servers that record the nature of each access and the applicable data every time a device accesses an applicable server, which may include your originating IP address and your activity while using the Platform Services (for example, date and time stamps, pages and files viewed, searches and other actions you take such as which features you accessed), device event information (for example, system activity, error reports or crash dumps), hardware settings, and metadata (or other data about data), and other information associated with files that you upload to our Platform Services.
Usage data: We collect usage data about you whenever you interact with our Platform Services, which can include: dates and times you access the Platform Services and browsing activities (for example, the portions of the Platform Services you used) as well as performance data regarding the Platform Services, including metrics related to the deliverability of emails and other communications you send through the Platform Services. This information allows us to improve the content and operation of the Platform Services, and facilitate research and analysis of the Platform Services.
(collectively “PS Usage Data”).
(iii) Information we collect from other sources. Occasionally, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Examples of information we may receive from other sources include general demographic information, IP addresses, location/GPS information, and online behavioral data. We may use this information alone or in combination with other PII we collect in an effort to enhance our ability to provide relevant service and content to you or to develop and provide more relevant products, features, and services.
B. Why We Use PII. We may use the PII we collect or receive through the Platform Services (alone or in combination with other data we source) consistent with our legitimate interests to operate and administer our Platform Services for the purposes of:
sending you messages and providing certain features to you including, but not limited to, informing you about temporary or permanent changes to our Platform Services; planned maintenance outages; account, security or compliance notifications; new feature alerts; version updates and releases; abuse warnings; or changes to this or other policies.
communicating with you about your account and providing customer support to either perform our contract with you or in reliance on our legitimate interests in administering and supporting our Platform Services.
meeting our legal requirements, including performing our obligations under contract; complying with court orders, discovery requests, subpoenas, and other appropriate legal mechanisms; providing information to representatives and advisors, including attorneys and accountants; prosecuting and defending a court, arbitration, or similar legal proceeding; and responding to lawful requests by public authorities, including to meet national security or law enforcement requirements.
providing support and improving the Platform Services to perform our contract with you for the use of the Platform Services or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Platform Services and providing certain features. In the event that we share your PII with a third party, we take steps to protect your information in a manner consistent with our obligations under applicable privacy laws.
providing suggestions and tailored features to you within our Platform Services to optimize and personalize your experience.
performing data analytics projects to improve and enhance our Platform Services for our Clients and Visitors. These data analytics projects use data from Enunc8 accounts to provide and improve the Platform Services. We use information such as spending habits and purchase history, in order to improve our predictions, decisions, and products for our Clients. If you prefer not to have their data used for this purpose, you can alter the settings on your account to opt out of data analytics projects or at any time by emailing us at email@example.com.
Enunc8 takes the privacy of PII seriously, and we will continue to implement appropriate safeguards to protect this PII from misuse or unauthorized disclosure.
D. Cookies and Tracking Technologies. We (including our partners and vendors) use various technologies to collect and store PS Usage Data when you use our Platform Services (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels and web beacons. Such technologies allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our application and to provide analytics information and enhance the effectiveness of our Platform Services. We may use page tags (also known as web beacons) in the emails we send to you. When you receive and engage with marketing messages we send to you, web beacons track certain behavior such as whether the email sent through the Platform Services was delivered and opened. Links within these emails are tracked to show each individual recipient’s clicks. Please see Section 6 (Cookie Notice) for more information.
E. Analytics Technologies. We may use Google Analytics or other similar technologies (the “Analytics Technologies”) to collect and process certain information about you and your use of the Site. The information collected by the Analytics Technologies is statistical data and does not include PII, and we do not maintain it or associate it with PII we collect in other ways or receive from third parties.
Our web server and/or the Analytics Technologies may collect and store the following general information about you:
the originating name of the domain from which you access the Internet;
the date and time you access the Site;
the pages of the Site you visit;
the Internet address of the website from which you linked directly to us; and
the type of device, device ID and web browser you use to access the Site.
This information is collected automatically. It is used to help us improve the Site by tabulating the number of visitors to the Site in terms of new users, origin of referrers, popularity of pages, amount of use, types of errors, and to make the Site more useful to you.
Our web server and/or the Analytics Technologies may also collect Internet protocol addresses (the Internet address of a device) to track a user’s session while the user remains anonymous. We analyze this data for certain trends in statistics, such as which parts of the Site users are visiting and how long they spend there.
F. Additional Data Protection Rights. Depending on the jurisdiction in which you reside, you may have the rights to access, correct, update, port, delete, restrict, or object to our processing of your PII; the right to complain to a data protection authority about the collection and use of PII; and the right to withdraw your consent to our use of PII.
You may be able to manage your individual account and profile settings within the dashboard provided through the Enunc8 platform or you may contact us directly at any time to update your own marketing preferences by emailing us at firstname.lastname@example.org.
If your PII is collected or processed on the basis of your consent, you, as a data subject, can withdraw your consent at any time. Withdrawing your consent, however, will not affect the lawfulness of any processing we conducted prior to your withdrawal nor will it affect the processing of your PII conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
Enunc8 takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.
3. ENUNC8 VISITORS
This section applies to PII that we collect and process when you visit the Sites, and in the usual course of our business, such as in connection with applying for a job or signing up for marketing or sales information. In this Section 3, “you” and “your” refers to Visitors.
A. Information We Collect.
(i) Information you provide to us on the Sites or otherwise: Our Sites offer various ways to contact us to inquire about our company and our Platform Services. We may also collect PII from you in person when you attend trade shows or other events in which we participate and you attend or via a phone call with one of our sales representatives. If you choose to provide additional information when you communicate with us, or otherwise interact with us, we may keep copies of any such communications for our records.
The PII we collect may include:
Business and professional contact information which may include your job title, organization, location, phone number, or email address;
Nature of your communication;
Marketing information or contact preferences; and
Other information you choose to provide to us when entering text while filling in our forms.
Device information: We collect information about the device and applications you use to access our Platform Services, such as your IP address, operating system, unique device identifiers, mobile network information, request information including speed, frequency, the referring page (the site which you visited immediately before ours or that contained a link to our page that you clicked), your exit page (the site you choose to visit immediately after ours), other websites you have recently visited, information on the specific web browser you used (including its type and language), and other information about your system and connection.
Usage data: It is important for us to ensure the security and reliability of the Platform Services we provide. Therefore, we also collect usage data about your interactions with the Site, other websites (including pages and files viewed, searches, operating systems, system configuration information, and date and time stamps), emails sent through the Platform Services, which may include dates and times you access emails and your browsing activities (such as what pages are viewed and which emails are opened).
B. Why We Use PII. We may use the information we collect through our Sites and in connection with our events and marketing activities, and whether alone or in combination with other data we collect, for a range of reasons in reliance on (and to the extent necessary for) our legitimate interests, including, but not limited to:
providing, operating, optimizing, and maintaining the Site.
sending you marketing information, product recommendations, and non-transactional communications (for example, newsletters, or sales calls) in accordance with your marketing preferences, including information about our products, services, promotions, or events as necessary to conduct direct marketing or to the extent you have provided your prior consent.
recruiting, if you have applied for a position with Enunc8.
responding to your online inquiries and requests and providing you with information and access to resources or services in those inquiries or requests.
managing the Sites and system administration and security and facilitating the security and continued proper functioning of the Sites.
improving the navigation and content of the Sites.
identifying any server problems or other IT or network issues.
processing transactions and setting up online accounts.
compiling aggregated statistics about Site usage and to better understand the preferences of our Visitors.
improving and personalizing our marketing activities.
conducting research and development to improve our Sites and our Platform Services.
conducting marketing research, advertising to you, providing personalized information about Enunc8 (on and off our Sites) and/or based on your activities and interests in supporting our marketing activities, advertising our Platform Services, or other instances where we seek and you have provided your consent.
carrying out other legitimate business or other lawful purposes, including, for example, data analysis, fraud monitoring and prevention, identifying usage trends, and expanding our business activities or product offerings.
cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent such cooperation requires the processing or disclosure of PII as necessary to (1) protect our rights, (2) protect against misuse or abuse of our Sites and Platform Services, (3) protect the safety of personal property or others, (4) pursue remedies available to us and limit our damages, (5) comply with judicial proceedings, court orders, or other legal processes, or (6) respond to lawful requests.
C. Public Information and Third-Party Websites
(i) Blog. We have public blogs on the Sites, but currently do not support comments to our blog posts. Should we offer the ability to comment, however, any information you include in a comment on our blog may be read, collected, and used by anyone. If your PII appears on our blogs and you want it removed, contact us at email@example.com. If we are unable to remove your information, we will tell you why.
(ii) Social media platforms and widgets. The Sites include social media features, such as the Facebook, Twitter, and LinkedIn buttons. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site.
We maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
D. Cookies and Tracking Technologies. We (including our partners and vendors) use various technologies to collect and store information when you use the Platform Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. Such technologies allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our application and to provide analytics information and enhance the effectiveness of our Platform Services. We may use page tags (also known as web beacons) in the emails we send to you. When you receive and engage with marketing messages we send to you, web beacons track certain behavior such as whether the email sent through the Platform Services was delivered and opened. Links within these emails are tracked to show each individual recipient’s clicks. Please see Section 6 (Cookie Notice) for more information.
E. Additional Data Protection Rights. Depending on the jurisdiction in which you reside, you may have data protection rights including the right to:
complain to a data protection authority about our collection and use of your PII. For more information, please contact your local data protection authority.
withdraw your consent, if we have collected and processed your PII with your consent. You may withdraw your consent at any time, however, such withdrawal will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your PII conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences.
While we will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws, we may ask you to verify your identity in order to help us respond efficiently to your request.
4. GENERAL INFORMATION FOR CLIENTS AND VISITORS
(iii) Law Enforcement: Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation; to exercise, establish, or defend our legal rights; or to protect the vital interests of you or any other person.
(v) Other: Any other person with your consent.
B. Your Choices and Opt-Outs. Clients and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the “Contact Us” section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Clients cannot opt out of these messages unless you cancel your Enunc8 account.
C. Our Security. We take appropriate and reasonable technical and organizational measures designed to protect PII from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the PII. We generally do not disclose our security practices in an effort to retain the utmost protection of our Sites and the Platform Services. If you have any questions about the security of your PII, you may contact us at firstname.lastname@example.org.
Enunc8 accounts require a username and password to log in. Clients must keep their username and password secure, and must never disclose them to any third party. Because the information in a Client’s Enunc8 account is private, account passwords are hashed, which means we cannot see a Client’s password. We cannot resend forgotten passwords either. We will only provide Clients with instructions on how to reset them.
D. Data Retention
We retain PII we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). Though the specific retention period varies depending on the type of data, in generally we determine retention periods based on whether:
we have a legal or contractual need to retain the data;
the data is necessary to provide our Platform Services;
our Clients have the ability to access and delete the data within their accounts; and
our Clients would reasonably expect that we would retain the data until they remove it or until their Enunc8 accounts are closed or terminated.
When we no longer have any legitimate, ongoing business need to process your PII, we will either delete or anonymize your PII. If this is not possible (for example, because your PII has been stored in backup archives), then we will securely store your PII and isolate it from any further processing until deletion is possible.
We will retain information we process on behalf of our Clients for as long as needed to provide services to our Clients (unless deletion is requested at an earlier time by the Client) and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We reserve the right to delete an applicable Client’s (and its Authorized Users’) information at the termination of a Client’s contract with us (unless such deletion is prohibited by applicable laws).
E. Protecting Children
THIS SITE IS NOT INTENDED FOR CHILDREN UNDER 16 YEARS OF AGE.
Enunc8 does not knowingly collect PII from children under 16. If you are under 16, do not use or provide any information on this Site or provide any information about yourself to us, including your name, postal address, telephone number, email address or any screen name or user name you may use.
If we learn we have collected or received PII from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email in “Contact Us” section below.
5. INFORMATION FOR CALIFORNIA CONSUMERS AND THE CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act (“CCPA”) organizations that process PII for their own purposes ("businesses") are differentiated from organizations that process PII on behalf of other organizations ("service providers"). Enunc8 acts as a business. With respect to PII that we have obtained through your use of our Platform Services, we use this information to conduct research and analysis to help better understand and serve our Platform Services clients as well as to improve our Platform Services.
A. Your Rights. If you are a California resident, you may have certain rights. For example, California law may permit you to request that we:
provide you with (1) the categories of PII we have collected or disclosed about you in the last twelve months; (2) the categories of sources of such information; (3) the business or commercial purpose for collecting or selling your PII; and (4) the categories of third parties with whom we shared PII;
provide access to and/or a copy of certain information we hold about you; and
delete certain information we have about you.
You also have the right to receive information about the financial incentives that we offer (if any) and the right to not be discriminated against for exercising your rights.
Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Platform Services to you. If you ask us to delete it, you may no longer be able to access or use the Platform Services.
B. Summary of Information We Collect. If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the CCPA). We and our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):
Our or our service provider’s operational purposes;
Auditing your interactions on our Site (for example, measuring analytics such as frequency of use of ad links);
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection and error reporting;
Short-term (or transient) use, such as customizing content that we or our service providers display on the Site (such as contextual ads);
Providing the Site and the Platform Services (for example, account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communication about the Platform Services);
Improving our existing Site and Platform Services and developing new Platform Services (for example, by conducting internal research to develop new products or features);
Verifying or maintaining the quality or safety of, or upgrading or enhancing our Site or the Platform Services;
Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners; and
Other uses about which we notify you.
C. Categories of PII Sold or Disclosed. The CCPA sets forth certain obligations for businesses that “sell” PII. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity.
D. Exercising Your Rights. If would like to exercise any of your California rights, please submit a request to email@example.com. You will be required to verify your identify before we fulfill your request. To do so, you will need to provide us with certain account information, such as the full name and email address you used to create your account and your most recent activity with us. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf, however, you will still need to verify your identity directly with us.
E. California Shine the Light.
We do not sell or disclose personal information with third parties for their direct marketing purposes.
6. COOKIE NOTICE
A. What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
We refer to cookies created by us as "Enunc8 Cookies" and those created by parties other than us as "third-party cookies". Third-party cookies enable third-party features or functionality to be provided on or through the Site (for example, advertising, interactive content, and analytics). The parties that provide these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
In addition to the party which sets the cookie, the duration of the cookie’s retention in your browser can help define its purpose. Session cookies are cookies which are stored on your device for the duration of the browser session. When you close your browser, the session cookies are cleared. Persistent cookies are stored either until you manually delete them or until your browser deletes them based on the duration set within the persistent cookie file.
Essential: Those cookies that are strictly necessary to provide you with services available through our Site and to use its features, such as access to secure areas. Refusal of these cookies may impact website functionality.
Performance/Functionality:Those cookies that are used to enhance performance or functionality of the Site but are non-essential to their use. Without these cookies, however, certain functionality may become unavailable.
Analytics/Customization:Those cookies that collect information in aggregate form either (1) to help us understand (A) how the Sites are being used or (B) how effective are marketing campaigns are or (2) to help us customize our Sites for you.
Advertising: Those cookies that are used to ensure advertising messages are relevant to you, for instance, by preventing the same ad from reappearing continuously, ensuring that ads are properly displayed, or, in some cases, selecting advertisements based on your interests.
Social Networking: Those cookies that are used to enable you to share pages and content you find interesting on the Sites through third-party social networking or other websites (including, potentially for advertising purposes related to social networking).
C. Enunc8 Cookies
[Final list being compiled.]
D. Third-Party Cookies
(Subject) Enunc8 Visitors
(Purpose) Google Analytics cookies help us measure and evaluate Site performance by providing insights into Site Visitor behavior and actions
(Retention) 26 months
(Type) Advertising/Social Networking
(Subject) Enunc8 Visitors
(Purpose) Display targeted, more personal ads/sharing pages and content through social networking
(Retention) 180 days
(Type) Advertising/Social Networking
(Subject) Enunc8 Visitors
(Purpose) Display targeted, more personal ads/sharing pages and content through social networking
(Retention) 90 days
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
F. Other Tracking Technologies
Other than the cookies listed above, we have also implemented the following tracking technologies within certain parts of the Sites and Platform Services.
(ii) Local and session storage. Our Site uses local and session storage to temporarily store information to improve user experience while interacting with the website.
7. CONTACT US
information collected by Enunc8 offline or through any other means, including any other website operated by Enunc8 or any third party (including our affiliates and subsidiaries); or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.
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