At Enreach, we value your privacy and are committed to protecting your personal data (‘Personal Data’). This privacy statement (‘Privacy Statement’) explains how we process your Personal Data in accordance with applicable data protection legislation (‘Data Protection Legislation’), what Personal Data we process, for what purposes we process your Personal Data, how we protect your Personal Data, how long we store your Personal Data, how you can exercise your privacy rights in relation to this Personal Data, and any other information that may be relevant to you as an end user (‘Business End User’) of a Enreach Contact endpoint which can be an Enreach Contact desktop application, mobile application or application for Microsoft Teams (together ‘App’), or Enreach Contact desk phone or mobile phone subscription (together ‘Device’).
In this Privacy Statement, ‘you’, ‘your’, and ‘yours’ refers to all data subjects (‘Data Subject’) interacting with the Enreach Contact App and/or Device as a Business End User, whereas ‘Enreach’, ‘we’, ‘our’, or ‘us’ refers to Enreach Holding LTD., as the provider of the App and Device. Additionally, you will see references to the Enreach Group, which includes all other Enreach entities globally. Further information on the Enreach Group can be obtained by contacting us using the Contact Information provided below.
Enreach is the data processor (‘Data Processor’) for the Personal Data we process within the App or Device, or the backend/cloud connected to the App or Device, on behalf of our business customers (‘Business Customer’), in most cases your employer, who have their own purposes for processing the data. For details on such purposes, you should refer to their privacy statements/notices. To the extent Enreach processes Personal Data within the App or Device or the backend/cloud connected to the App or Device, in connection with its own legitimate business operations, as identified in this Privacy Statement, Enreach will be the (independent) data controller (‘Data Controller).
Without the processing of your Personal Data, you will not be able to access the App or Device. By using the App or Device and submitting any Personal Data, you agree to the use of such data in accordance with this Privacy Statement.
Enreach does not share Personal Data with third parties, unless this is (1) legally required, (2) necessary to supply a service, 3) specifically requested by the business customer that has provided the Personal Data, or (4) otherwise Enreach has a legitimate interest in doing so, assuming that interest outweighs any potential effects that the sharing of Personal Data might have on the rights and freedoms of the affected Data Subject.
We did our best to provide you with all the necessary information in a clear and readable format in this Privacy Statement. However, if you have any questions about our use of your Personal Data after reading this Privacy Statement, you can of course always contact us through the contact details provided below.
The capitalised words in this Privacy Statement have the meanings ascribed to them in this Privacy Statement and in the Definitions provided below.
We are Enreach Latvia
Enreach LTD
Address: Cēsu street 31, K-3, 9, Riga, Latvia, LV-1012
Email: info.lv@enreach.com
Phone: +371 66 100 800
We have a dedicated Data Protection Team and a Data Protection Officer (‘DPO’). If you have any questions relating to the processing of your Personal Data or want to contact our DPO, feel free to do so using the details provided below:
Enreach Data Protection Team
Email: dataprotectionteam@enreach.com; datuspecialists@enreach.com
Phone: +31 088 889 0889; +371 66 100 800
Below are some key terms relevant to this Privacy Statement:
‘Personal Data’: Any information directly or indirectly relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
‘Data Subject’ (you): Natural person(s) whose Personal Data is processed, specifically in this case, the Business End User.
‘Data Controller’: Natural or legal entity that determines the purposes and means for the processing of Personal Data. In the context of this Privacy Statement, this is in most cases your employer, or Enreach as an independent Data Controller when we process your Personal Data for our own legitimate business operations, not related to the processing purposes of your employer.
‘Data Processor’: Natural or legal entity processing data on behalf of the Data Controller. In the context of this Privacy Statement, this is in most cases Enreach as the provider of the App or Device.
‘Business End User’ (you): Data Subject(s) whose Personal Data is processed while using the App or Device, in most cases, the employees of the Business Customer.
‘Business Customer’: The legal entity that has a direct contractual relationship with Enreach, or a contractual relationship with Enreach partners. In the context of this Privacy Statement, this is in most cases, your employer.
‘Sensitive Personal Data’: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a Data Subject’s sex life or sexual orientation.
‘Data Protection Legislation’: Data Protection Legislation refers to the applicable laws that govern the protection of Personal Data and privacy. This includes the legislation applicable to the processing of Personal Data in the EU, such as the General Data Protection Regulation (‘GDPR’) and the ePrivacy Directive, as well any national laws implemented in connection with the aforementioned legislation.
The functions of the App or Device can only be used in conjunction with an Enreach backend/cloud, for which your employer i.e., the Business Customer has purchased a subscription and configured for you. The App or Device functions will only be available after authentication and synchronisation of the data with the corresponding service.
Enreach processes the Personal Data identified in this Privacy Statement to deliver the App and/or Device and ultimately for the purposes determined by the Business Customer. We only collect Personal Data that is necessary for the intended purposes and in accordance with the Data Protection Legislation.
Our intention is not to collect Sensitive Personal Data through the App or Device. We therefore ask that you do not provide any type of Sensitive Personal Data. If you do wish to provide such Personal Data for any reason, Enreach accepts your explicit consent to use that Personal Data in the ways described in this Privacy Statement or as described at the point where you choose to provide us with such data.
Personal Data obtained via the App or Device is used only in the ways described in this Privacy Statement or otherwise for the purpose(s) stated at the time that the data is collected. Enreach makes every effort to avoid any excessive or irrelevant collection of Personal Data.
We may collect Personal Data directly from you or indirectly through the Business Customer. The way we collect your Personal Data differs depending on your relationship with us:
We do not control the purposes and means for the collection of your Personal Data when providing our service on behalf of the Business Customer and are therefore not responsible for it. We only process the data to the extent necessary for downloading the App on your hardware and for other technical purposes related to the availability, development, and usage of the App or Device.
We only process your Personal Data when there is a legal basis for doing so. The Personal Data processed via the App or Device is collected on the basis of:
We may also process your Personal Data for our own business purposes as the provider of the App or Device. Enreach will be an independent Data Controller for such processing, The legal basis for this processing is our legitimate interest, which allows us to use your Personal Data in a manner that is necessary and proportionate to our legitimate business objectives. We ensure that such processing is conducted in compliance with the Data Protection Legislation. Enreach’s legitimate business objectives consist of the following:
The categories of Personal Data described below are the data collected and generated when using the App and/or Device. This data is required for technical purposes to increase ease of use for App or Device functions and ensure stability and security. The Personal Data that we collect through our App and Device will only be used for the specific purposes for which it was provided.
We process the following categories of Personal Data:
We process the following categories of Personal Data:
If you do consent, your data will be accessible from the App, and in some cases used to enrich data, for example your call history. This will only be synchronised and enhanced locally on the device you use. Additionally, when using the desktop version of the App you can add a contact to your personal Enreach Contact phonebook.
If you do consent and make use of the feature, your data will be stored on our servers relating to the corresponding party that has provided you with access to the App. In most cases, this will be your employer i.e., the Business Customer.
We process the following categories of Personal Data:
In our capacity as a Data Processor or independent Data Controller, we do not actively collect Sensitive Personal Data for any of the purposes described in this Privacy Statement.
We may create anonymous, aggregated, or de-identified data from your Personal Data. We do this by excluding information that makes the data personally identifiable to you.
We retain your Personal Data to provide high-quality service compliant with the Data Protection Legislation. Personal Data is stored as long as necessary to fulfil collection purposes, legal obligations, and reporting requirements. All data is stored on servers within the EEA.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve the purposes through other means.
Personal Data may be anonymised in some circumstances rather than deleted. In this event, the anonymised data will no longer be traceable to you and is no longer considered Personal Data.
Uninstalling the App permanently deletes all data in the App; however, it does not delete the data stored in the backend/cloud. The data stored in the backend/cloud will be either deleted or anonymised based on legal requirements, after your employer i.e., the Business Customer has cancelled the subscription. Due to this we have no influence over, and are therefore not responsible for, the duration for which data is stored on the backend/cloud.
If we deem it necessary for the abovementioned processing purposes, your Personal Data may be shared with one or more third parties, regardless of whether the third party is affiliated with the Enreach Group, for the purpose of processing Personal Data in accordance with our instructions.
When third parties are given access to your Personal Data in line with the above, we undertake required contractual and organisational measures to ensure that your Personal Data are processed only to the extent that such processing is legitimate and necessary.
We may share your Personal Data with trusted third parties as follows:
The Enreach Group is composed of a wider group of undertakings with headquarters in the Netherlands, and entities located in the EU, the UK and Serbia. Enreach may transfer your Personal Data to, or otherwise allow access to such data by other entities within the Enreach Group, which may use, transfer, and process your Personal Data for the purposes described within this Privacy Statement. We may also share aggregated data about our customers in the form of business intelligence and statistics with members of the Enreach Group.
In order to communicate via our App or Device, it is necessary for us to transmit traffic data via any Wi-Fi or IP network operators. Enreach uses several European infrastructure providers, and these operators therefore process Personal Data. These operators are independently Data Controllers for the processing of data within their respective networks. For further information on the operators we use, please reach out to us using the Contact Information above.
We may engage certain Data Processors who may process your Personal Data on our instructions. The Data Processors are contractually obliged to implement appropriate technical and organisational measures to ensure that your Personal Data is processed in accordance with our instructions. We may share your Personal Data with such Data Processors in relation to the hosting of your data, the App chat functionality, business intelligence analyses etc.
We only share your data with Data Processors that can provide sufficient guarantees that they will process your data securely and in accordance with the Data Protection Legislation. Our Data Processors cannot do anything with your Personal Data unless we have instructed them to do it. They will not share your Personal Data with any organisation apart from us or further sub-processors which must process your Personal Data on precisely the same terms and to the same high standards.
Where necessary for the processing purposes described above or where required by law, your Personal Data may be transferred to regulators, courts and other authorities, independent external advisors, and compliance and investigation teams.
We attach significant importance to your privacy. We therefore implement appropriate technical and organisational measures to ensure that the processing of your Personal Data is performed in accordance with the Data Protection Legislation, in particular ensuring an appropriate level of security. We implement suitable physical, electronic, and managerial procedures to safeguard and secure your collected Personal Data. The App and Device use TLS encryption for the data and audio connection to the server. The data is therefore not accessible by third parties.
Enreach has implemented generally accepted standards of technology and operational security in order to protect Personal Data from loss, misuse, alteration, or destruction. Only authorised Enreach personnel are provided access to Personal Data and these employees are contractually or statutorily obliged to ensure confidentiality of this data.
Under the Data Protection Legislation, you have a number of rights regarding the processing of your Personal Data within the App, as below:
You have the right to be informed about the collection and use of your Personal Data. We ensure we uphold this right through this Privacy Statement.
You have the right to access the information we process about you relating to our provision of the App or Device. Enreach does not have access to the data contained within the App or Device. Within the App or Device, you can view your Personal Data yourself.
You have the right to have incorrect or outdated information about yourself corrected. Enreach does not have access to the data contained within the App or Device. Within the App or Device, you can correct Personal Data yourself.
In exceptional cases you have the right to have information about you deleted. Enreach does not have access to the data contained within the App or Device. Within the App or Device, you can delete Personal Data yourself.
In some cases, you have the right to have the processing of your Personal Data restricted. If you exercise this right, we may only process your Personal Data with your consent, or for the purpose of establishing, asserting, defending, protecting, a significant public or private interest, except when we process your data for storage.
In certain cases, you have the right to object to our otherwise lawful processing of your Personal Data.
In certain cases, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.
You have the right to withdraw your consent at any time in the circumstances where you have given us consent to process your Personal Data. Within the App or Device or your system settings you can revoke your consent at any time.
An automated decision is one that is made by our systems rather than a person. You have the right to express your concerns and object to a decision taken by purely automated means under some laws such as the GDPR. You also have a right to request that a person review that decision.
This right is unlikely to apply to Enreach’s use of your data, as any automated processing we carry out is unlikely to make decisions and would include human intervention. If you would like to discuss this in further detail, please contact us as set out above.
You have the right to lodge a complaint with a competent supervisory authority.
Enreach processes your Personal Data solely based on the instructions of the Data Controller, your employer. You can therefore invoke any of the above rights by reaching out to your employer.
For the Personal Data we process in our capacity as an independent Data Controller, you can invoke the rights above by reaching out to us on the Contact Information provided above. When you submit a request, we will ask you some additional questions to verify your identity. We will respond to your request as soon as possible, but at the latest within one month.
In case you have any questions with respect to the processing of your Personal Data as described within this Privacy Statement, you can contact the Enreach Data Protection Team and our DPO via the Contact Information above.
Enreach reserves the right to modify or amend this Privacy Statement at any time. The effective date will be displayed below. It is the user's responsibility to check this document regularly for changes.
Thank you for taking the time to read our Privacy Statement.
Version May 2024
English
Latvia