Privacy Policy
PRIVACY NOTICE
Last updated August 26, 2021
Thank you for choosing to be part of our community at Ensabill Limited ("Company,"
"we," "us," or "our"). We are committed to protecting your personal information and
your right to privacy. If you have any questions or concerns about this privacy notice or
our practices with regard to your personal information, please contact us at
legal@ensabill.com.
This privacy notice describes how we might use your information if you:
Visit our website at https://ensabill.com
Download and use our mobile application — Ensabill - Financial Assistant
Engage with us in other related ways ― including any sales, marketing, or events
In this privacy notice, if we refer to:
"Website," we are referring to any website of ours that references or links to this
policy
"App," we are referring to any application of ours that references or links to this
policy, including any listed above
"Services," we are referring to our Website, App, and other related services,
including any sales, marketing, or events
The purpose of this privacy notice is to explain to you in the clearest way possible what
information we collect, how we use it, and what rights you have in relation to it. If there
are any terms in this privacy notice that you do not agree with, please discontinue use of
our Services immediately.
Please read this privacy notice carefully, as it will help you understand what
we do with the information that we collect.
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TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM
YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on
the Services, express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services or otherwise when you contact
us.
The personal information that we collect depends on the context of your interactions with
us and the Services, the choices you make and the products and features you use. The
personal information we collect may include the following:
Personal Information Provided by You. We collect names; phone numbers; email
addresses; usernames; billing addresses; debit/credit card numbers; mailing
addresses; job titles; contact or authentication data; passwords; contact
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preferences; details about services from us and our partners that you express interest
in; details about how you use our site; other registration information including but not
limited to your bank account information including the name of the financial institution,
account name, account type, account ownership, iban number, your swift code and
financial transactions; and other similar information.
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number (such as a credit card number), and
the security code associated with your payment instrument. All payment data is stored by
Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy .
Social Media Login Data. We may provide you with the option to register with us
using your existing social media account details, like your Facebook, Twitter or other
social media account. If you choose to register in this way, we will collect the information
described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true, complete and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when you visit, use or navigate the Services.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our
Services and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information through cookies and similar
technologies. You can find out more about this in our Cookie Notice:
https://ensabill.com/cookiesPolicy.html .
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The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and
performance information our servers automatically collect when you access or use
our Services and which we record in log files. Depending on how you interact with
us, this log data may include your IP address, device information, browser type and
settings and information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches and other
actions you take such as which features you use), device event information (such as
system activity, error reports (sometimes called 'crash dumps') and hardware
settings).
Device Data. We collect device data such as information about your computer,
phone, tablet or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address (or
proxy server), device and application identification numbers, location, browser type,
hardware model Internet service provider and/or mobile carrier, operating system
and system configuration information.
Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or by
disabling your Location setting on your device. Note however, if you choose to opt
out, you may not be able to use certain aspects of the Services.
Information collected through our App
In Short: We collect information regarding your geolocation, mobile device, push
notifications, when you use our App.
If you use our App, we also collect the following information:
Geolocation Information. We may request access or permission to and track
location-based information from your mobile device, either continuously or while
you are using our App, to provide certain location-based services. If you wish to
change our access or permissions, you may do so in your device's settings.
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Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model and manufacturer), operating system, version information
and system configuration information, device and application identification
numbers, browser type and version, hardware model Internet service provider
and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you
are using our App, we may also collect information about the phone network
associated with your mobile device, your mobile device’s operating system or
platform, the type of mobile device you use, your mobile device’s unique device ID
and information about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your
account or certain features of the App. If you wish to opt-out from receiving these
types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our App,
for troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our legal obligations,
and/or your consent.
We use personal information collected via our Services for a variety of business purposes
described below. We process your personal information for these purposes in reliance on
our legitimate business interests, in order to enter into or perform a contract with you,
with your consent, and/or for compliance with our legal obligations. We indicate the
specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook account),
we use the information you allowed us to collect from those third parties to facilitate
account creation and logon process for the performance of the contract. See the
section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" for
further information.
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To post testimonials. We post testimonials on our Services that may contain
personal information. Prior to posting a testimonial, we will obtain your consent to
use your name and the content of the testimonial. If you wish to update, or delete
your testimonial, please contact us at privacy@ensabill.com and be sure to include
your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to
contact you about your use of our Services.
To enable user-to-user communications. We may use your information in
order to enable user-to-user communications with each user's consent.
To manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.
To send administrative information to you. We may use your personal
information to send you product, service and new feature information and/or
information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to
keep our Services safe and secure (for example, for fraud monitoring and
prevention).
To enforce our terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in connection with
our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or
other legal request, we may need to inspect the data we hold to determine how to
respond.
Fulfill and manage your orders. We may use your information to fulfill and
manage your orders, payments, returns, and exchanges made through the Services.
Administer prize draws and competitions. We may use your information to
administer prize draws and competitions when you elect to participate in our
competitions.
To deliver and facilitate delivery of services to the user. We may use your
information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential issues you might
have with the use of our Services.
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To send you marketing and promotional communications. We and/or our
third-party marketing partners may use the personal information you send to us for
our marketing purposes, if this is in accordance with your marketing preferences.
For example, when expressing an interest in obtaining information about us or our
Services, subscribing to marketing or otherwise contacting us, we will collect
personal information from you. You can opt-out of our marketing emails at any time
(see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
Deliver targeted advertising to you. We may use your information to develop
and display personalized content and advertising (and work with third parties who
do so) tailored to your interests and/or location and to measure its effectiveness. For
more information see our Cookie Notice: https://ensabill.com/cookiesPolicy.html .
For other business purposes. We may use your information for other business
purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our
Services, products, marketing and your experience. We may use and store this
information in aggregated and anonymized form so that it is not associated with
individual end users and does not include personal information. We will not use
identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to
provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use
your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary
to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we
may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental requests, a
judicial proceeding, court order, or legal process, such as in response to a court
order or a subpoena (including in response to public authorities to meet national
security or law enforcement requirements).
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Vital Interests: We may disclose your information where we believe it is necessary
to investigate, prevent, or take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to the safety of any person
and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in
the following situations:
Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
Vendors, Consultants and Other Third-Party Service Providers. We may
share your data with third-party vendors, service providers, contractors or agents
who perform services for us or on our behalf and require access to such information
to do that work. Examples include: payment processing, data analysis, email
delivery, hosting services, customer service and marketing efforts. We may allow
selected third parties to use tracking technology on the Services, which will enable
them to collect data on our behalf about how you interact with our Services over
time. This information may be used to, among other things, analyze and track data,
determine the popularity of certain content, pages or features, and better
understand online activity. Unless described in this notice, we do not share, sell,
rent or trade any of your information with third parties for their promotional
purposes. We have contracts in place with our data processors, which are designed
to help safeguard your personal information. This means that they cannot do
anything with your personal information unless we have instructed them to do it.
They will also not share your personal information with any organization apart from
us. They also commit to protect the data they hold on our behalf and to retain it for
the period we instruct.
Third-Party Advertisers. We may use third-party advertising companies to serve
ads when you visit or use the Services. These companies may use information about
your visits to our Website(s) and other websites that are contained in web cookies
and other tracking technologies in order to provide advertisements about goods and
services of interest to you. See our Cookie Notice:
https://ensabill.com/cookiesPolicy.html for further information.
Affiliates. We may share your information with our affiliates, in which case we will
require those affiliates to honor this privacy notice. Affiliates include our parent
company and any subsidiaries, joint venture partners or other companies that we
control or that are under common control with us.
Business Partners. We may share your information with our business partners to
offer you certain products, services or promotions.
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Offer Wall. Our App may display a third-party hosted "offer wall." Such an offer
wall allows third-party advertisers to offer virtual currency, gifts, or other items to
users in return for the acceptance and completion of an advertisement offer. Such
an offer wall may appear in our App and be displayed to you based on certain data,
such as your geographic area or demographic information. When you click on an
offer wall, you will be brought to an external website belonging to other persons and
will leave our App. A unique identifier, such as your user ID, will be shared with the
offer wall provider in order to prevent fraud and properly credit your account with
the relevant reward. Please note that we do not control third-party websites and
have no responsibility in relation to the content of such websites. The inclusion of a
link towards a third-party website does not imply an endorsement by us of such
website. Accordingly, we do not make any warranty regarding such third-party
websites and we will not be liable for any loss or damage caused by the use of such
websites. In addition, when you access any third-party website, please understand
that your rights while accessing and using those websites will be governed by the
privacy notice and terms of service relating to the use of those websites.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following categories of third parties.
We only share and disclose your information with the following categories of third parties.
If we have processed your data based on your consent and you wish to revoke your
consent, please contact us using the contact details provided in the section below titled
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
Ad Networks
Cloud Computing Services
Communication & Collaboration Tools
Data Analytics Services
Data Storage Service Providers
Finance & Accounting Tools
Payment Processors
Performance Monitoring Tools
Product Engineering & Design Tools
Affiliate Marketing Programs
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Website Hosting Service Providers
User Account Registration & Authentication Services
Testing Tools
Social Networks
Sales & Marketing Tools
Government Entities
Order Fulfillment Service Provider
Retargeting Platforms
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice:
https://ensabill.com/cookiesPolicy.html .
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our Services offers you the ability to register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do this, we
will receive certain profile information about you from your social media provider. The
profile information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends list, profile picture as
well as other information you choose to make public on such social media platform.
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We will use the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant Services. Please
note that we do not control, and are not responsible for, other uses of your personal
information by your third-party social media provider. We recommend that you review
their privacy notice to understand how they collect, use and share your personal
information, and how you can set your privacy preferences on their sites and apps.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by
law (such as tax, accounting or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than the period of time in which
users have an account with us.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any further processing
until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However, despite
our safeguards and efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security, and improperly collect, access, steal, or
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modify your information. Although we will do our best to protect your personal
information, transmission of personal information to and from our Services is at your
own risk. You should only access the Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years
of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Services. If we
learn that personal information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly delete such data
from our records. If you become aware of any data we may have collected from children
under age 18, please contact us at privacy@ensabill.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United
Kingdom (UK), you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy of
your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing of your
personal information. To make such a request, please use the contact details provided
below. We will consider and act upon any request in accordance with applicable data
protection laws.
If we are relying on your consent to process your personal information, you have the right
to withdraw your consent at any time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal, nor will it affect the processing of your
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personal information conducted in reliance on lawful processing grounds other than
consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data protection
supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
If you are a resident in Switzerland, the contact details for the data protection authorities
are available here: https://www.edoeb.admin.ch/edoeb/en/home.html .
If you have questions or comments about your privacy rights, you may email us at
privacy@ensabill.com.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
Contact us using the contact information provided.
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, we may retain some information in
our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce
our Terms of Use and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies or reject cookies, this could affect certain
features or services of our Services. To opt-out of interest-based advertising by advertisers
on our Services visit http://www.aboutads.info/choices/ . For further information, please
see our Cookie Notice: https://ensabill.com/cookiesPolicy.html .
Opting out of email marketing: You can unsubscribe from our marketing email list at
any time by clicking on the unsubscribe link in the emails that we send or by contacting us
using the details provided below. You will then be removed from the marketing email list
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— however, we may still communicate with you, for example to send you service-related
emails that are necessary for the administration and use of your account, to respond to
service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
Access your account settings and update your preferences.
Contact us using the contact information provided.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and
collected. At this stage no uniform technology standard for recognizing and implementing
DNT signals has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits
our users who are California residents to request and obtain from us, once a year and free
of charge, information about categories of personal information (if any) we disclosed to
third parties for direct marketing purposes and the names and addresses of all third
parties with which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with a
Service, you have the right to request removal of unwanted data that you publicly post on
the Services. To request removal of such data, please contact us using the contact
information provided below, and include the email address associated with your account
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and a statement that you reside in California. We will make sure the data is not publicly
displayed on the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups, etc.).
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will be effective as soon
as it is accessible. If we make material changes to this privacy notice, we may notify you
either by prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be informed of
how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
privacy@ensabill.com or by post to:
Ensabill Limited
Kemp House
160 City Road
London EC1V 2NX
United Kingdom
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
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Based on the applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or delete it in
some circumstances. To request to review, update, or delete your personal information,
click here: Request data .
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