Privacy Policy

Enna Privacy Policy

BACKGROUND:

Enna respects your privacy, is fully compliant with the UK General Data Protection Regulations (“GDPR”) and Data Protection Act 2018 (“DPA”) and is committed to protecting your personal Data. This Privacy Policy will tell you how we look after your personal Data when you visit our Web Site and inform you of your privacy rights and how the law protects you.

This Privacy Policy gives you information on how Enna collects and uses your personal Data through your use of this Web Site, including any Data you may provide through the Web Site when you register as a candidate or employer, and/or purchase a product or Service.

This Web Site is not intended for children and we do not knowingly collect Data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice on our Web Site from time to time so that you are fully aware of how and why we are using your Data.

• Controller

1. 1. Enna is the controller and responsible for your personal Data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).
   2. We have appointed a Data Protection Officer (Emily Banks) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via the contact page on this Web Site or contact Emily Banks:

By phone on 03301338690

By email on hello@enna.org

By post to: Enna Global, 36-38 Cornhill, London, UK, EC3V 3NG 

• Definitions and Interpretation

In this Privacy Policy the following terms shall have the following meanings:

• Data Collected

1. 1. 1. We may collect, use, store and transfer any of the following Data:
         1. name;
         2. date of birth;
         3. gender;
         4. job title;
         5. profession;
         6. contact information, including email addresses and telephone numbers;
         7. demographic information, including post code, preferences and interests;
         8. financial information, including credit / debit card numbers;
         9. IP address (automatically collected);
         10. web browser type and version (automatically collected);
         11. operating system (automatically collected);
         12. a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
         13. Cookie information (see clause 11 below).

• Our Use of Data

1. 1. The law requires us to have a legal basis for collecting and using your Data. We rely on one or more of the following legal bases :
      1. performance of a contract with you;
      2. where it is necessary to conduct our business or pursue our legitimate interests. For more details, see Clause 4.5;
      3. where we have obtained your consent to use your Data for a specific purpose.
   2. Any personal Data you submit will be retained by Enna for as long as you use Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to six months.
   3. Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties.  This includes our affiliates and / or other companies within our group.
   4. All Data is stored securely in accordance with the principles of the GDPR. Data is primarily held on secure servers located in the United Kingdom. However, some data may also be stored or processed in Germany, where our trusted hosting providers operate additional secure data centres. These data centres meet the security and compliance requirements of the UK GDPR and EU GDPR. For more details on security, see clause 10 below.
   5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site.  Specifically, Data may be used by us for the following purposes:
      1. internal record keeping;
      2. improvement of our products / services;
      3. transmission by email of promotional materials that may be of interest to you;
      4. contact for market research purposes which may be done using email, telephone, fax or mail.  Such information may be used to customise or update the Web Site.
   6. You have the right to object to the processing of your Data where we are relying on a legitimate interest as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

Disclosures of your Data

• Enna may, from time to time, share your Data where necessary with the parties set out below. 

• Any Data used by such parties is used only to the extent required by them to perform the services that Enna requests.  Any use for other purposes is strictly prohibited.  

• Any Data that is processed by third parties must be processed within the terms of this Privacy Policy and in accordance with the GDPR. 

• Changes of Business Ownership and Control

1. 1. 1. Enna may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties.  Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was supplied by you.
      2. In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes.  When contacted, you have the right to ask that your Data be deleted or withheld from the new owner or controller.

• Controlling Access to your Data

1. 1. 1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data.  This may include the following:
         1. use of Data for direct marketing purposes; and
         2. sharing of Data with third parties.

• Your Right to Withhold Information

1. 1. 1. You may access certain areas of the Web Site without providing any Data at all.  However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
      2. You may restrict your internet browser’s use of Cookies.  For more information see clause 11.4 below.

• Your Right to Access, Correct or Request Erasure of your Data 

1. 1. 1. You may access your Account at any time to view or amend your Data.  You may need to modify or update your Data if your circumstances change.  Additional Data as to your marketing preferences may also be stored and you may change this at any time.
      2. You have the right to ask for a copy of your Data.
      3. You have the right to ask us to delete or remove your Data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your Data where you have successfully exercised your right to object to processing.

• Security

1. 1. 1. Data security is of great importance to Enna and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.

• Cookies

1. 1. 1. Enna may set and access Cookies on your computer. Cookies that may be placed on your computer are detailed in our Cookies Policy.

• Changes to this Privacy Policy

1. 1. 1. Enna reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law.  
      2. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

• Your Right to Lodge a Complaint

1. 1. You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (http://www.ico.org.uk).
   2. Before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. You can contact us via the contact page on this Web Site or contact Emily Banks (see Clause 1).