1. Personal Data Collected
“Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, or online identifier of that person. The type of Personal Data that we collect about You depends on whether You are a customer, user, employee, or visitor and the requirements of applicable law. We collect the following types of Personal Data from You when You visit the Enable Website and use it as noted below:

Personal Data You may provide to Us:

● Communicating with Us. You provide Personal Data when You join Our mailing list(s), inquire about or purchasing a product or service, apply for employment, filling out an information form, or otherwise contact Us with a question, comment, or request, and supply Your information, such as name, title, company, physical and email addresses, telephone number, resume, user IDs, and/or password.

● Surveys. If you decide to participate, You may be asked to provide certain information, which may include Personal Data.

● Visiting our Locations. If you visit one of Our physical locations, You may provide certain information for security purposes. While on our premises Your image may be captured on security monitoring or closed-circuit video recording.

● Social Media. Any content You provide through Our forums, blogs, or social media pages will be considered “public” and is not subject to privacy protections.

● Sensitive Personal Data. We do not use and ask that You not provide Us with any sensitive personal data (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) through Our websites.

Personal Data We may collect other than from You:

● Automatic Data Collection.  We may use technology that automatically collects Your information while You visit the Enable Website or Enables services platforms such as information about Your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website You visited before browsing to Our website, general location information such as city, state or geographic area; and information about Your use of and actions on or in Our websites, such as pages or screens You accessed, how long You spent on a page or screen, navigation paths between pages or screens, information about Your activity on a page or screen, access times, and length of access. This may be collected through various mechanisms, including cookies, pixels, tags, web beacons, embedded scripts, and similar technologies. See below for information on Our use of Technology and Cookies.

● Other Sources.  We may obtain or collect Personal Data about You from third parties or publicly available information for the purposes of keeping information We collect about You accurate and to provide You with information about Our products and services that may be of interest to You.

● Contract Data.  We may collect Your information from Our customers that provide financial services to You using Our platforms. Enable or its customers may have different privacy notices related to use of Enable’s products and services, in which case such notice related to Enable’s product or services shall apply rather than this Policy.

2. How We Use Personal Data
● We are committed to collecting Personal Data for specified and legitimate business purposes, to limit its use and processing to that purpose, and to not process data in a manner beyond such purpose. Our legitimate business purpose may include:

o Developing and enhancing Our products, services, marketing or security procedures to improve performance, resilience, reliability or efficiency;

o Detecting security incidents and otherwise protecting Our systems from malicious, deceptive, fraudulent or illegal activity including threats or harm including to Our information technology infrastructure, Intellectual property, or goodwill or reputation and prosecuting those responsible for that activity;

o Ensuring compliance with relevant corporate policies and terms; or

o Optimizing utilization of Our corporate resources including the administration of business transactions, personnel and information technology systems.

● We may use Personal Data to help Us improve the Enable Website, our products and services, and user experience. We may also use Your information for marketing analysis and research, to inform You of any promotions, or to market the Enable Services to You or provide you with a demonstration of our products.

● We may use Personal Data as We believe necessary or appropriate to (a) comply with applicable laws and regulations, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) protect our rights, privacy, safety or property, and/or that of You or others; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) update, expand, and analyze our records, or (e) performing a task carried out in the public interest.

● We may use Personal Data to create anonymous, deidentified, or aggregate data and may use such anonymous data for Our lawful business purposes.

​3. Use of Certain Technology
We may use a variety of technology to collect information such as the following:

● Cookies.  Cookies are text files placed on Your computer or device designed to collect standard internet log information and visitor behavior information. When You visit the Enable Website, We automatically collect certain Personal Data through use of cookie and similar technology. We also use cookies to collect information that we aggregate to help Us with understanding how Our website is being used and how effective Our marketing is, to help with use of Our Website, and to make advertising messages more relevant to You. You may manage cookies for our Website the first time you visit it. Information about cookies generally is available at https://www.consumer.ftc.gov/articles/0042-online-tracking.

● Analytical Tools. Enable may use analytical tools to help Us analyze how visitors use Our website. These tools use technology, such as cookies to collect data about the number of website visitors, which website or source that referred the visitor, and the pages within the website the visitor views. Tools we use include Google Analytics and Adobe Analytics which both use persistent cookies. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and Adobe Analytics by visiting http://www.adobe.com/privacy/opt-out.html.

● Web Beacons, Pixel Tags, Clear GIFs, and Other Technologies.  These technologies place electronic (usually transparent) images on websites or in emails which allow for placement of cookies, collection of data such as the time and date you visit a page, length of time on the page, and the IP address of the device that retrieved the image, the time the web beacon was viewed and for how long, and the type of browser that retrieved the image. For example, these tools may be used to determine whether You opened Our marketing communication and viewed the links. If You do not want technologies like this placing cookies on your device, You will want to turn off cookies in Your web browser(s).

● Log File Information.  Enable records log file information whenever You access Our websites. Log Information may include Your IP address, Your browser type, the page from which You accessed Our website, pages within our website you viewed, the last page You viewed before You exited Our website, and the page you accessed upon leaving Our website.

● Webpage Links.  We may include in our communications links to webpages that when clicked will link you to webpages by redirecting You through Our servers (or third-party servers) and we may collect information about You through the redirection to determine whether our communication or marketing initiative is effective. If You do not want this type of information collected, You can choose a text-based version of the message (if the option is available) or elect not to click on the provided link and instead conduct a browser search for the referenced resource.

● APIs and SDKs.  Our platforms may use application programming interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our systems. These tools may allow third parties, such as Our analytics and advertising partners, to collect Your information. You may contact as noted below for more information about Our use of APIs and SDKs.

4. Sharing Personal Data with Third Parties
We may share Personal Data with certain third parties such as our affiliates or subsidiaries, service providers, business partners, advertising and marketing partners, as part of a merger, sale of assets or other type of corporate reorganization, or as necessary to protect Us or others.

● Service providers, such as IT vendors, security product providers, consultants, and vendors, may have access Personal Data as necessary to help support our business activities, such providers will be required to protect Personal Data consistent with this Policy and applicable law.

● Business partners that we use to offer our services or use us to offer their services or with which we offer joint services may need access to Personal Data for the same reasons as used by Enable as notes in this Policy.

● Advertising and marketing partners We may use to promote Our products or services. These partners may use cookies or web beacons or similar tools to collect Personal Data for targeted advertising based on Your interests. We may engage these partners to help Us deliver targeted advertisements about Us on other websites You visit. If we request them to use cookies and tools for such purpose, We will do so in accordance with this Policy. However, such partner may have these connections through other providers or directly through your access of their website and their collection and use of Personal Data through any source other than Enable’s website or communications will be governed by their own privacy policies and statements.

● If We enter into discussions with other parties for various business development initiatives, such as the sale, merger, or reorganization of Our business, we may need to disclose Personal Data we collect. We will do so subject to contractual protections protecting such Personal Data consistent with this Policy and applicable law.

● We may disclose Personal Data to third parties (a) as required by law, judicial proceedings, court orders, subpoena or other governmental order, (b) as necessary to protect Our rights, property, or safety, and/or the rights or property of Our customers, business partners, suppliers, or other third parties, and (c) as necessary to enforce Our policies or contracts, collect amounts owed to Us, or assist with an investigation or prosecution of suspected or actual illegal activity.

5. Your Rights
● If We request Personal Data directly from You, You may elect not to provide such information though You use of our Website and receipt of information about our services may be impacted.

● If required by laws in Your jurisdiction, We may be required to obtain Your consent to use Personal Data in certain contexts, such as use of cookies or similar technologies or sending marketing messages. If We request Your consent to use Your Personal Data, You have the right to withdraw Your consent any time in the manner identified when We requested Your Consent or by contacting us as https://www.enable-technologies.com/contactus. Please note that withdrawing Your consent will not affect the lawfulness of Our collection and use of Your data prior to Your withdrawal of consent. If You withdraw Your consent, We will no longer collection or use Your information except as permitted by law or as may be necessary for the establishment, exercise, or defense of legal claims.

● You can ask Us to stop sending You marketing messages at any time by contacting Us using the details at https://www.enable-technologies.com/contactus. Please note, other permitted uses of Personal Data will continue.

● As noted above, You may elect to turn off certain tracking technologies, such as cookies, by turning off those technologies within your chosen web browser. To learn more about managing cookies on Your device, please visit http://www.allaboutcookies.org/manage-cookies/.

● If You use an Internet browser that may be configured to send "Do Not Track" signals to the online services that You visit. We currently do not respond to “do not track” signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

● See below for notices to residents in certain states.

● If You have any compliant about how we handle Your Personal Data, You may contact us in writing at legal@enable-technologies.com. We request that you include details in your complaint sufficient for Us to investigate. We may contact you for additional information regarding Your complaint and We will contact You regarding a response to Your complaint. You may have a right to file a complaint with a national or local regulatory agency.

​6. How We Keep Personal Data Protected
● If We request Personal Data directly from You, You may elect not to provide such information though You use of our Website and receipt of information about our services may be impacted.

● If required by laws in Your jurisdiction, We may be required to obtain Your consent to use Personal Data in certain contexts, such as use of cookies or similar technologies or sending marketing messages. If We request Your consent to use Your Personal Data, You have the right to withdraw Your consent any time in the manner identified when We requested Your Consent or by contacting us as https://www.enable-technologies.com/contactus. Please note that withdrawing Your consent will not affect the lawfulness of Our collection and use of Your data prior to Your withdrawal of consent. If You withdraw Your consent, We will no longer collection or use Your information except as permitted by law or as may be necessary for the establishment, exercise, or defense of legal claims.

● You can ask Us to stop sending You marketing messages at any time by contacting Us using the details at https://www.enable-technologies.com/contactus. Please note, other permitted uses of Personal Data will continue.

● As noted above, You may elect to turn off certain tracking technologies, such as cookies, by turning off those technologies within your chosen web browser. To learn more about managing cookies on Your device, please visit http://www.allaboutcookies.org/manage-cookies/.

● If You use an Internet browser that may be configured to send "Do Not Track" signals to the online services that You visit. We currently do not respond to “do not track” signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

● See below for notices to residents in certain states.

● If You have any compliant about how we handle Your Personal Data, You may contact us in writing at legal@enable-technologies.com. We request that you include details in your complaint sufficient for Us to investigate. We may contact you for additional information regarding Your complaint and We will contact You regarding a response to Your complaint. You may have a right to file a complaint with a national or local regulatory agency.

7. Children’s Information.

Our products, services, websites and marketing initiatives are not directed to children under the age of 16. By accessing our websites or platforms, You affirm that You are at least 16 years of age. We do not sell or share the information of consumers under 16 years of age. If You are a parent or a guardian, and You believe Your child has provided us with Personal Data without Your consent, please contact us as described below.

8. International Transfers.

● Enable does not currently transfer Personal Data collected from visitors to the Enable Website with any companies located outside of the United States. If cross border transfer of Personal Data occurs, We will ensure that the recipient of Your Personal Data has an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

9. Notice to California Residents

If You are a resident of California, this Section applies to Your Personal Data We collect as a Business and the terms of the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) shall apply. For the purposes of this section, the terms “Business”, “Business Purpose”, “Consumer” “Personal Information”, “Sale/Sell”, “Service Provider” and “Sensitive Personal Information” and “Share” shall have the meaning given to them under the CCPA. The types of Personal Information We may collect shall be the types of Personal Data as set forth in Section 1 of this Policy, and may include:

● Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, telephone number, or other similar identifiers;

● Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a You interaction with Our internet website or advertisements;

● Device information, including device type, operating system, web browsers, IP address, settings and other device characteristics and behavior information, and data extracted from such information; or

● Geolocation data.

Under CCPA, You are entitled to the following (if the Personal Information is older than 12 months, we will use reasonable efforts to comply with any such request):

● You can request what Personal Information We collect about You, how it was collected and third parties to which it is disclosed;

● You can request We delete or correct inaccuracies in Your Personal Information (though We may decline such request if permitted by CCPA and even if deleted retain records of requests for such deletion for the purpose of preventing the selling of such Personal Information for which You have submitted a deletion request);

● You may opt out of any sale of Your Personal Information or sharing of Your Personal Information for targeted advertising, see link in this page’s footer;

● You may request the transfer of specific pieces or Your Personal Information to another entity;

● Exercise the above listed rights free of discrimination.

 

Personal Information collected is used for market analysis and research; to protect Enable data and the Enable Website from threats, violations, or breach; to market and sell Enable Services to You; to improve the Enable Website, our products and services, and user experience, and as required by applicable law or regulation or court order.

We do not Sell or Share (as the terms are defined in the CPRA) any Personal Information We collect without providing You a right to opt out. We do not knowingly collect any Personal Information of any person under the

age of 16. We shall not disclose any Personal Information collected for verification of consumer requests. We do not collect Sensitive Personal Information. We retain information only for so long as necessary for the original purpose collected, unless otherwise required by law or to enforce Our rights or defend claims.

 

We have collected and/or disclosed the above types of Personal Information for business purposes in the past 12 months (prior to the date of this Policy) and may continue to collect and/or disclose such Personal Information to our service partners who provide support of the Enable Website or other marketing support for the Enable products and services, provided such partners do not (a) Sell or Share such Personal Information; (b) retain, use or disclose such information for any purpose other than for the specific purpose of performing the services specified in Our contract with them; or (c) combine such information with any other information received directly by them.

 

The above listed rights may not be absolute and we may decline Your request as permitted by the CCPA. Your request should provide sufficient details for Us to understand, evaluate and responds to Your request. Please note, CCPA requires Us to verify Your identify if You make any of the foregoing requests before We may provide a substantive response to any such request. If You are an “authorized agent” empowered to submit a request on behalf of a California resident, you must provide written authorization of such authority.

Our services and the Enable Website are not directed toward children under the age of sixteen and We do not knowingly collect any personal information from children under the age of sixteen. If a child provided this website with personal information, We ask that a parent or guardian send us a written request to the address listed below and we will promptly delete the child's information from our records. You may exercise your rights under CCPA by contacting us at legal@enable-technologies.com. Please provide sufficient information that allows Us to verify You are the person about whom We have collected Personal Data.

10. Notice to Residents of Colorado, Connecticut or Virginia

If you are a resident of Colorado, Connecticut of Virginia, this section applies only to Your Personal Data if You are acting in Your individual or household context and not if You are acting in a commercial or employment context. How we use Personal Data is described in Section 1 above. In CO, CT and VA you may have the rights related to access, correction and deletion of Personal Data, however these rights may not be absolute. We may decline any request as permitted in the laws applicable in Your state. If you are a CO, CT or VA resident, You may make access, correction or deletion requests to legal@enable-technologies.com and appeal any denials of Your request to legal@enable-technologies.com.

11. Changes to this Policy.

We reserve the right to change this Policy at any time. You may access the most current version of this Policy here at any time. Any changes to this Policy are effective as of the time at which we post such changes to this Website. Your continued use of the Enable Website shall indicate Your acceptance of this Policy and any changes hereto.

12. Contact Us.

You may reach us regarding this Policy at legal@enable-technologies.com. Please use the hotline if you are reporting suspected breach of Personal Data or have an urgent concern. You may also contact us in writing at Enable, 2309 Noriega St, #1002, San Francisco, CA 9412