Enurgen Privacy Policy

Effective, January 14, 2025

This privacy policy addresses Enurgen's use of any Personally Identifiable Information (PII) generated from customers who license and use Enurgen’s services and products. This Policy also applies to those who use web browser connections through Enurgen’s web app and product. PII is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your PII.

Personal information we collect

What personal information do we collect from visitors and customers and how do we collect it?

Information you provide to us: When registering for or using Enurgen services, you provide us with certain pieces of PII. For example, when an Enurgen account is created, you provide us with some or all of your name, position at your company, company name, phone number, company email address, and password. Depending on the purpose for which you are using the Enurgen services, you may also be asked to provide your address for billing and shipping purposes and your phone number for delivery of documents.

Information we collect automatically: user login history, activities surrounding Enurgen services use, including web app usage and API access.

Information that we collect from third parties: We may share and/or collect additional information about you from third parties primarily to assist us in understanding how we can maintain and improve the services we offer to better serve you. We, along with third-party vendors, use first-party cookies (such as the Google Analytics cookies), third-party cookies, and/or other third-party identifiers to compile data regarding user interactions with Enurgen services and products.

Cookies

Cookies are small files that a site or its service provider transfers to your device's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For example, we use cookies for identity authentication. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services and products. We also use cookies to help us compile aggregate data about app traffic and app interaction so that we can offer better app experiences and tools in the future. We use cookies to:

• Understand and save user's preferences for future usage;
• Identify bugs and their root causes to improve future app experiences; and
• We may also use trusted third party services to track this information on our behalf. Through the web browser settings of your device, you can choose to receive warnings each time a cookie is sent, or you can choose to disable all cookies. If you disable cookies, some of our services and products may no longer function properly.

How we use your personal information

We may use the PII we collect in the following ways, to:

• Create user accounts;
• Authenticate user login credentials;
• Provide, operate, optimize and maintain our products and services;
• Understand and personalize user experience with Enurgen services and products;
• Improve our site to better serve users;
• Provide users with customer and technical support;
• Quickly process your transactions; and
• Send periodic emails regarding your services. We may also combine the information we collect (or that is otherwise provided to us) through aggregation or other anonymizing means to limit the identification of any particular individual and help with our business goals (such as research and marketing).

Legal Basis for processing your information: If you are a user or Customer located in the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate business interests. In some cases, we may also have a legal obligation to collect personal information from you. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@enurgen.com.

How we share your personal information

We may use your PII in the ways described here:

• Vendors or third party service providers: We may share your information with third parties that we use to provide and support our services. These parties provide services such as data storage, email delivery, billing and collections, and customer support. We enter into legally binding agreements with these third-party service providers that permit the processing of personal information only to deliver the services that we have retained them to provide and prohibit the use of personal data for any other purpose. We keep an up-to-date list of these service providers here: https://enurgen.com/subprocessors/.
• Compliance with the law, safety, security, business transactions: We may also disclose your information to third parties: a) where required by law or regulatory requirement, court order, or other judicial authorization; b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; c) in connection with the sale, transfer, merger, bankruptcy, restructuring, or other reorganization of our business; d) to protect or defend our rights, interests, or property, or that of third parties; e) to investigate any wrongdoing in connection with our products and services; and f) to protect the vital interests of an individual.
• If you choose to opt-in to Enurgen updates, we will email you technical updates or inform you about other services, products, and features.

How we protect your personal information

Our products and services are scanned on an ongoing basis for known vulnerabilities in order to make your experience with them as safe as possible. PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, data is encrypted in transit via SSL/TLS. Our database service uses the AES-256 encryption algorithm.

You may contact us at privacy@enurgen.com to request a copy of our Data Processing Agreement (DPA) or with any questions.

Your choices about your information

General: Upon written request (email), Enurgen will notify you whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at privacy@enurgen.com. We will respond to your request within a reasonable timeframe.

European Economic Area: If you are based in Europe you have additional rights as outlined below:

• Access: If you wish to access your personal information that Enurgen collects, you can do so at any time by contacting us.
• Correction, update, or deletion: You can correct, update, or request deletion of your personal information by contacting us.
• Object to processing: When we reply on your consent to process your personal information, you may withdraw consent at any time by contacting us. This will not affect the lawfulness of processing prior to the withdrawal of your consent. Withdrawn consent may affect, limit, or prevent Enurgen’s ability to provide our services and products.
• Data Protection Authority: You have a right to raise questions or complaints with your local data protection authority at any time.
• Marketing: You have the right to opt-out of marketing communications we send you at any time. You can do this by clicking the “unsubscribe” link in the marketing emails we sent you or by contacting us. If contacting us, please provide your complete name, email address and any other relevant information that may be required to address your request). Please note that such marketing opt-out does not impact any transaction or operation notices that we may need to send you.

Retention of Information

We retain customer information for 90 days post termination of service, unless a longer retention period is required or permitted by law, for legal, tax, or regulatory reasons, or other lawful purposes.

COPPA (Children Online Privacy Protection Act)

Enurgen's services, products, and websites are not intended or directed to persons under the age of 18. We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our services. We will delete any information we discover is collected from a minor. Please contact us if you believe we might have information about a minor.

When it comes to the collection of PII from children under 13, the United States' Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to licensing.
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at support@enurgen.com and we will promptly remove you from all correspondence.

Users from Outside of the United States

General: By using the Enurgen services you acknowledge and agree that: a) your information will be processed as described in this Privacy Policy; and b) you consent to have your information transferred to us and our facilities in the United States or elsewhere, including those third parties as described in this Privacy Policy.

European Economic Area: If you are based in Europe, you acknowledge and agree that Enurgen may transfer your information (including personal information) to us and our facilities in the United States or elsewhere, including those third parties as described in this Privacy Policy. In order to meet the requirements of the EU General Data Protection Regulation (GDPR) Enurgen's Terms of Use / Terms of Service for Customers include a Data Protection Addendum approved by the European Commission to ensure the adequate protection of Personal Information.

Changes to this Policy

If we change our privacy policies and procedures materially, we will post those changes to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will update the “effective date” listed on this page, and we may also notify you of the change via email or within the Enurgen services or products.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.

7 Bayview Station Road
Ottawa, Ontario
Canada
K1Y 2C5
privacy@enurgen.com