In this enyi privacy notice, “enyi”, “our” “we” or “us” means enyi bold & free trading as enyi (Molokwu F.) Robertstr. 27, 30161, Hannover, Germany. We are the owner and operator of marketplace services offered through the enyi website at www.enyi.app and mobile application platform (collectively, “Site”) (the “Services”) and the data controller in respect of your personal information. This means that we are the primary entity who decides the purposes and means for dealing with your personal data.
We may modify this Policy at any time, and by continuing to use our Site, you accept the Policy as it applies and as amended from time to time with notice. Your continued use of our Site after any modification to this Policy will constitute your acceptance of such modifications.
This policy was last updated on 15th May 2021.
This Policy will give you an understanding of:
the types of personal information we collect;
why we collect, use and disclose personal information;
how we collect, use, store, disclose and otherwise handle personal information;
how you can manage your personal information;
when we disclose your personal information;
how we deal with data security and third-party links;
how we administer changes to this Policy; and
how you can contact us to give feedback or submit complaints, and how we deal with any such complaint.
2. Types of information we collect;
a) Registration Data
By creating an account with us, you may enter your details on the input form. We may collect the data that you input for your account creation (“Registration Data”).
We may collect the following Registration Data from Site visitors and members:
business name and details of contact person;
mailing or street address;
affiliated company name;
telephone number and other contact details; or
any other information relating to you that you provide to us directly or indirectly through our Site/app, including information you provide through emails, social media and seller registration forms surveys and competition entry forms.
b) User Data
If you are a user of enyi, we may collect the following data for the purpose of providing you with our Services personalised to you as a user:
your profile information, picture/s and contact details;
your customers (if you are a seller) and suppliers’ details; and
payment details and supply or order history
c) Public Data
On the Site you may have the ability to comment or participate on blogs, discussion forums or other parts of the Site that allow you to post your comments or engage with enyi or other users (“Public Data”). We may collect this data on enyi when you choose to comment or participate.
You should be aware that any information you provide in this manner may be made broadly available for others. Public Data may also cover certain User Data that you choose to make public, however you will have the ability to edit the visibility of the User Data you make public through your account settings.
This Public Data includes information such as your profile information, your time zone, and any information you input or upload to your profile (such as profile picture). You are responsible for what you make public.
d) Log Data
We may receive information when you view content on or otherwise interact with our Site (“Log Data”). We may receive this Log Data automatically.
This Log Data includes information such as personal information from your interaction with us and its content, our Services and our advertising, including without limitation device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the Site, mobile network information, time, date, referring URL, the type of operating system and browser, ad data, IP address, server address, date and time of your visit to our Site, information of documents you download, pages visited, search terms, cookie information, and standard web log data.
e) Cookies and other similar technologies
Cookies are files that store information on the device on which you are using or accessing our Site. Cookies also retain your details and preferences, so you can easily continue your browsing session upon return to our Site. If you do not want to activate cookies, you can opt-out of receiving them by amending the settings of your internet browser, although you may find that some parts of our Site will consequently have limited functionality and personalisation if you do so.
We may share non-personal and personal information with our affiliated organisations, such as advertisers and/or advertising networks to deliver advertising, and to help measure the effectiveness of an advertising campaign from time to time.
f) Third party analytics tools
We may use third-party analytics tools to analyse usage trends on our Site, including the tracking and reporting of Site traffic, ad conversion tracking, traffic analysis and marketing optimisation; and collect this data in aggregate form so that it cannot identify any individual.
Third-party analytics tools collect information such as how often you visit our Site, the web pages you visit, add-ons, and other analytics data that assists us in improving our Services. These tools might include, but are not limited to, Google Analytics, Google AdWords conversion tracking, Google Tag Manager, or Facebook Ads conversion tracking.
We reserve our rights to modify, add or remove any third-party analytics tools. By using our Site, you acknowledge the processing of any non-personal data these tools will collect in the way and for the purposes described above.
3. Why we collect and use your personal information
Our principal purpose in collecting, using and storing your personal information is to provide the Services in a personalised, safe and efficient manner. We collect, use, store, share and disclose your personal information for the following legal bases in order to:
Performance of a contract with you;
provide and maintain the enyi Services;
register your account and provide you with access to protected areas of the Site;
notify you about changes to the service;
provide customer support services;
respond to any enquiries and communications from you; and
process your payments
Provide you with news updates on the app and its functionality, company updates and share eco lifestyle tips.
Necessary for our legitimate interests
ensure the operation and security of our Site (including to authenticate your account and maintain back-ups of our databases);
create a better experience for you on the Site and personalizing our Services to you;
carry out our business in favour of the well-being of our employees and shareholders;
send you important service notifications regarding the Site and our Services (in respect of Account and User Data);
conduct market research and analysis;
protect enyi and its customers by enabling us to take appropriate legal enforcement action and prevent fraud;
verify information for accuracy or completeness (including by way of verification with third parties); and
aggregate and/or make anonymous your personal information, so that it cannot be used, whether in combination with other information or otherwise, to identify you.
Compliance with our legal obligations
comply with our legal obligations, a request by a governmental agency or regulatory authority or legally binding court order.
With your consent send you special offers and general information about other goods and services similar to those you have already purchased or enquired about, via email and push notifications through the Site.
Share personalised consolidated newsfeeds through our lifestyle functionality.
Where we rely on consent as the legal basis for processing your data, you will have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your data) that we will cease to process the affected data after consent is withdrawn. However, please note this may result in us being unable to provide you with certain features of the Services. To withdraw your consent to email marketing communications, please click the “Unsubscribe” link at the bottom of any relevant emails, update your communication preferences in your user account or update your push notification preferences on your device.
4. How we collect and use your personal information
We generally collect personal information directly from you when you:
share your information with us on our Site;
communicate with us over email, online chat systems, the phone or in person;
participate in one of our surveys or competitions;
interact with our Site;
purchase products through our Site or use our Services; and
We may also collect your personal information from third parties including:
service providers of our IT, analytics (e.g. Google), social media plugin (E.g. Facebook), chat platform (e.g. XMPPFramework/Swift), mailing list and payment processing services (e.g. Paypal); and
referrals who may have referred you to us.
Aside from Log Data, which may be collected automatically when you access or use the Site, all personal information we collect is voluntary and you can choose not to provide this information to us. However, this may mean that we will not be able to provide you with certain Services or be limited in how we can do so, or properly investigate or resolve any complaint you submit.
5. Your rights over your personal information
Please note that the below rights apply only if you are based in the EU.
You may, in circumstances, have the following rights in relation to the personal information we hold about you. All rights applicable to you can be exercised by contacting us emailing us at [email protected] or contacting us through our website at www.enyi.app
You can request to:
access a copy of the information held about you;
rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected. You can also update any incorrect contact information yourself by updating your profile information in your account portal;
delete, restrict or remove the data we hold about you;
transfer the data we hold about you to another party;
object to any further processing of your data, if we are processing your personal information on the basis of our legitimate interests (see “How do we use your personal data and for what grounds” above), or for direct marketing;
We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
refuse your request based on the exemptions set out in the applicable data protection laws;
request for proof of your ID to process the request or request further information:
charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests;
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly;
If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with the data protection regulator for your country of residence;
6. Disclosure and destruction of personal information
We may disclose your personal information to the following third-party entities for the purposes described in this Policy, such as:
our employees, related entities and employees of those entities;
our business partners;
our professional advisers, dealers and agents;
third parties and contractors who provide services to us, including customer enquiries and support services, manufacturing services, information technology service providers, marketing, analytics (e.g. Google) and advertising services, social media plugin providers (e.g. Facebook and Instagram);
payment systems operators (e.g. Paypal);
Any potential or actual third party buyer of our business and/or assets in the event that we sell, trade or licence ownership of any part of the enyi business or assets (including management of the Site);
any third parties authorised by you to receive information held by us; and
government, regulatory and law enforcement agencies as required, authorised or permitted by law.
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
If you deactivate and delete your account your data will no longer be visible on your account. Please keep in mind that third parties may still retain copies of information you have made public through our Site.
7. International transfer of personal data
We may on occasion need to transfer your personal data outside your country of residence. This means that your personal data may be transferred abroad to a country with different data protection laws.
If you are based in Germany, where we need to make such international transfers, we will ensure that such transfers are made subject to appropriate safeguards to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data have been self-certified under the Privacy Shield framework, through the use of IPO approved standard contractual clauses or the recipients are based in countries approved by applicable data protection laws to provide an adequate level of data protection.
8. Data security, storage and third-party information
We store your personal information in electronic form in secure databases owned and operated by our third-party service providers. We manage the security of your personal information by using SSL encryption.
While we take reasonable steps to ensure your personal information is protected from loss, misuse, unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed. This means that we cannot guarantee the security of your personal information. In the event of a breach, we will attend to the required reporting arrangements. We cannot accept responsibility for the misuse, loss or unauthorised access to, your personal information where the security of information is not within our control.
Our Site may contain links to websites, other apps and social media platforms operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content, on those linked websites, and have no control over or rights in them. The privacy policies that apply to third-party websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.
9. Changes to Policy
If and when we amend this Policy in any way, we will make all reasonable efforts to bring those changes to the attention of our visitors and members. An updated version of our Policy will be maintained on our Site so that you remain aware of our policies. The updated version will become effective on the date it is posted, which will be listed on the page as the new effective date. We encourage you to check our Site from time to time to view our most current policy.
10. Contact us
If you have any questions about this policy or how we handle your personal information, or wish to exercise your rights under paragraph 5 above, please contact us at [email protected] or write to enyi bold & free (Molokwu F.) at Robertstr. 27, 30161, Hannover, Germany