Owner and Data Controller
Enable Security GmbH Neuburger Straße 101 b 94036 Passau Germany Privacy Compliance Officer email: firstname.lastname@example.org
Types of Data collected
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
This Website makes use of the
__cfduid cookie which is set by our hosting provider, CloudFlare. The
__cfduid cookie helps Cloudflare detect malicious visitors to our Website and minimizes blocking legitimate users. It may be placed on the devices of the User to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare’s security features.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
So-called cookies are used on parts of this website. They are small text files which are stored on the device with which you access this website. Different categories of cookies are used:
- Essential cookies are necessary for ensuring the core functionality of our website.
- Functional cookies are cookies that are used for tracking user behaviour on our website to improve the functionality of our website.
- Marketing cookies are cookies we are using for serving interest-based ads.
- External media cookies: These cookies serve the purpose of displaying external media (such as videos or maps).
The legal basis for the use of essential cookies is Art. 6 (1) (f) GDPR – a legitimate interest. Our legitimate interest for the usage of these cookies is providing a functioning website.
The legal basis for the usage of the other cookies is Art. 6 (1) (a) GDPR — your consent. Without your consent no non-essential cookies will be set. You can withdraw your consent anytime with effect for the future here.
Use of third-party provider tools
In order to provide and continuously improve our services, we are using the services of the following third-party providers which may also process personal data. These third-party providers have been selected diligently and in line with the requirements of the GDPR.
Matomo is an open source web analytics platform. A web analytics platform is used by a website owner in order to measure, collect, analyse and report visitors data for purposes of understanding and optimizing their website. If you would like to see what Matomo looks like, you can access a demo version at: https://demo.matomo.org.
Matomo is processing the following personal data:
- IP address
- Custom Dimensions
- Custom Variables
- Location of the user
- Date and time
- Title of the page being viewed
- URL of the page being viewed
- URL of the page that was viewed prior to the current page
- Screen resolution
- Time in local timezone
- Files that were clicked and downloaded
- Link clicks to an outside domain
- Pages generation time
- Country, region, city
- Main Language of the browser
- User Agent of the browser
The processing of personal data with Matomo is based on explicit consent. Your privacy is our highest concern. That’s why we will not process any personal data with Matomo unless you give us clear explicit consent.
Hubspot is an integrated software solution that we use to cover different aspects of our online marketing. This includes, among others: Email marketing, social media publishing & reporting, reporting, contact management (e.g., user segmentation & CRM), landing pages and contact forms.
More Information about HubSpots Cookies can be found here:
As part of the optimization of our marketing activities, Hubspot may collect and process the following data:
- Geographical position
- Browser type
- Navigation information
- Reference URL
- Performance data
- Information about how often the application is used
- Mobile apps data
- HubSpot subscription service credentials
- Files that are displayed on site
- Domain names
- Viewed pages
- Aggregated use
- Version of the operating system
- Internet service provider
- IP address
- Device identification
- Duration of the visit
- Where the application was downloaded from
- Operating system
- Events that occur within the application
- Access times
- Clickstream data
- Device model and version
Moreover, we may use the live chat service “messages” from HubSpot on some sub-pages to improve users’ experience on our website for the sending and receipt of notifications (round chat icon on the lower right edge of the screen). If you consent to and use this feature, then the following data are transferred to the HubSpot servers:
- Content of all chat messages sent and received
- Context information (e.g., page on which the chat was used)
- Optional: Email address of the user (if it is provided by the user via the chat feature)
The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want Hubspot to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future. The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
Data may be transferred to the USA as part of processing by Hubspot. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to establish an adequate level of security, Art. 49 (1)(a) GDPR can serve as a legal basis. Please note the reference to the risk of data transfer to an unsafe third-country under sub-item “7. Forms”.
Chargebee is a recurring billing and subscription management tool that helps SaaS and SaaS-like businesses streamline Revenue Operations and is used by us for processing subscriptions and issuing invoices. Additional privacy information can be found at: https://www.chargebee.com/privacy/05-oct-2017/
Stripe Inc. is a financial services and software as a service (SaaS) company. The company primarily offers payment processing software and application programming interfaces (APIs) for e-commerce websites and mobile applications and is used by us for processing credit cards and SEPA direct debit transactions. Additional privacy information can be found here: https://stripe.com/de/privacy
GoCardless provides the technology and other services that help merchants around the world process payments for their goods or services. We use GoCardless for US direct debit (via ACH). Additional privacy information can be found at: https://gocardless.com/privacy/
Savvycal is scheduling software that helps people to find a time to meet instantly. We use Savvycal for scheduling video calls and meetings. Additional privacy information can be found at: https://savvycal.com/privacy/
Additionally, there are third party services that are included due to libraries and frameworks used by our web developers. Those third party services are:
- Google Fonts (https://fonts.google.com/)
- JSdelivr (https://www.jsdelivr.com/)
- Youtube (https://www.youtube.com/)
- Unpkg (https://unpkg.com/)
- Google Marketing Platform (https://marketingplatform.google.com/about/)
- Bootstrap CDN (https://www.bootstrapcdn.com/)
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this W), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13 / 14 of Regulation (EU) 2016 / 679 (General Data Protection Regulation).