Privacy Policy

Last updated: 29 April 2022

This Privacy Policy discloses the privacy practices of ENWAY LTD, having its business address at 78, Spyrou Kyprianou, Magnum Business Center, 3rd floor, 3076 Limassol, Cyprus (“ENWAY,” “we” or “us”).

ENWAY receives, collects, stores and manages personal information according to the following Privacy Policy, with the goal of incorporating the “Privacy by Design” approach.  Personal information is also known as personally identifiable information.

By using our website https://enway.com, our mobile applications and/or purchasing our products and services (jointly hereinafter referred to as the “Website”), you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy forms a binding agreement between ENWAY and you, being our customer.

Information for California Residents:

If you are a California resident, please refer to the “Additional Information for California Residents” below.

1. Data Collected

1.1 Data that you voluntarily provide us with:

1.1.1 You may provide us with your personal information in a number of ways, including, without limitation, when you:

• sign up for and use the Website;
• order, or purchase our services;
• download any materials or content through the Website;
• have previously provided us with personal information prior to this Privacy Policy or last updates coming into effect;
• subscribe to our newsletters, and/or service updates;
• complete and submit any forms to us;
• contact us directly in person or via any medium, including but not limited to by mail, telephone, and commercial electronic messages;
• communicate with us for any matters and interact with or browse the Website

1.1.2 Personal information that we may receive includes, but is not limited to:

• contact information such as your full name, email address;
• billing information, such address, phone number;
• company information;
• payment information;
• more detailed contact preferences.

1.1.3 ENWAY may receive this data from you when you manually enter such data, or we may receive such data from third parties. We may combine such data.

1.1.4 By giving us this data, you consent to this data being collected, used, disclosed, transferred to Belarus, and stored by us, as described in this Privacy Policy.

1.2 Data that we collect automatically

1.2.1 We collect data from every visitor and customer of the Website, in particular, we automatically collect data about your visit to the Website, your usage of our services, and your browsing activities. This anonymized information may include IP address, browser type, browser language, cookies data, performance specifications of the customer’s hardware and software, date and time of access to the Website, other information about how you interacted with our Website and our services.

1.3 Data from your use of the Website

1.3.1 We may receive data about how and when you use the Website, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This data may include, for example, your IP address, time, date, browser used, and actions you have taken within the Website. This type of data helps us to improve our Website, services, and products for both you and for all of our customers.

1.4 Cookies and tracking

1.4.1 Cookies are small data files that are placed on your computer or mobile device when you visit a website. Website owners use cookies to make their websites operate, improve functionality and user experience, as well as to provide reporting information.

1.4.2 We may set our own cookies and use third parties cookies (e.g. for advertising, statistics, and analytics).

1.4.3 We use different types of cookies, including:

1. Essential website cookies: these are important cookies as they are necessary to provide you with services available through our Website, such as access to secure areas.
2. Performance and functionality cookies: these cookies are necessary to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
3. Analytics and customization cookies: these cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, to help us customize our Website for you in order to enhance your experience, or to personalize our content and ads.
4. Advertising cookies: these cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. Please read the following link to know more about online advertising: https://www.networkadvertising.org/understanding-online-advertising/.
5. Social Media cookies: these cookies are placed by social media plugins, and other tools meant to provide or improve the content on a website (for example, services that allow the playing of video files, or that create comments sections).

1.4.4 You may opt out from cookies at any time by customizing your cookie preferences. However, in some cases we will not be able to provide you with all services.

1.5 Data from third party sources

1.5.1 We may receive some information about you, such as name, email address, demographic information, IP address, and location from third parties.

1.6 Opting-Out

1.6.1 You may decline to have your personal information collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertised identifier via the privacy settings on your mobile device.

1.6.2 You can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

• http://www.networkadvertising.org/choices/
• http://www.youronlinechoices.com/
• http://optout.aboutads.info/?c=2&lang=EN

1.7 Google Analytics

1.7.1 We use Google Analytics to analyze the way our Website is used. Information generated through cookies (including IP addresses) are transmitted and stored on the Google servers in the US. Google will evaluate and use website activity reports. We will use these reports to improve our service and products in order to improve our functionality and user experience.

1.7.2 For more information on Google Analytics, visit Google’s information page. For instructions on how to opt out of Google Analytics, see above.

1.8 Hotjar
1.8.1 We use Hotjar to analyze your bahavior on the Website. In order to process data about your visit to the Website, Hotjar stores first-party cookies on your browser. Data about your interaction is collected by Hotjar and stored on Amazon Web Services servers in the EU. Hotjar uses collected data to create visual representations of your visit to the Website. Then we use this reports to enhance customer experience.

1.8.2 For more information, visit Hotjar’s Privacy Policy page. For instructions on how to opt out of Hotjar, see clause №1.6

2. Use of the Data

2.1 We only use your personal information for the following purposes:

2.1.1 to provide you with the products and services that you purchased;

2.1.2 to promote products or services available from ENWAY;

2.1.3 to send you informational and promotional content that you may subscribe to or unsubscribe;

2.1.4 to send you notifications, including notifications on change of our Website;

2.1.5 to communicate with customers about our Website, products, services and provide customer care in response to their inquiries;

2.1.6 to enforce compliance with the applicable law;

2.1.7 to protect our rights and safety as well as rights and safety of our users and third parties;

2.1.8 to contact you via surveys to conduct research about your opinion of our products;

2.1.9 to provide information to representatives and advisors;

2.1.10 to prosecute and defend a court, arbitration, or similar legal proceeding;

2.1.11 to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;

2.1.12 to provide, support, and improve the services and products we offer;

2.1.13 to provide suggestions about products that you may be interested in and which you may opt out;

2.1.14 to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

3. Minors

3.1 Minors and children under age of 18 (or other legal age of your country of residence) should not use our Website and Services. We do not knowingly provide any Services to minors. If you access our Website and Services, you represent that you have the legal capacity to enter into a binding agreement. If you are under 18, we require that you inform a parent or guardian about our Privacy Policy as well as obtain their consent to use our Website and Services.

4. Sharing of Data

4.1 We do not share personal information, unless:

4.1.1 Doing so is appropriate to carry out your own request;

4.1.2 We believe it is needed to enforce our Privacy Policy, or if it is legally required;

4.1.3 We believe it is needed to detect, prevent or address fraud, security or technical issues;

4.1.4 Otherwise protect our property, legal rights, or that of others.

4.2 ENWAY is operated from Belarus. If you are visiting the Website from outside of Belarus, you agree to any processing of any personal information you provide us according to this Privacy Policy.

4.3 We don’t share your personal information with third parties, except for our third party service providers, such as with the following services:

Service Name	Website	Location	Purpose
Google Ads	https://ads.google.com/	USA	Advertising

4.4 To receive the full and current list of external services that we use for this purpose, please email us at info@enway.com.

4.5 We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share personal information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use personal information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information with our Agents.

5. Safeguarding your Personal Information

5.1 The protection of your personal information is vital to us. We take commercially reasonable measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. These security measures include, but are not limited to, SSL certificate for HTTPS.

5.2 Our employees, contractors, and any business partners can access personal information on a need to know basis, and under strict duties of maintaining confidentiality. We use encryption for sensitive information and we test our system on a regular basis to ensure we comply with industry practices and standards. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security of any data.

5.3 You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party.

5.4 If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

6. Access to your Personal Information

6.1 You may access your personal information held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:

• delete some or all personal information that we held about you;
• change or correct your personal information that we held about you;
• object to, or limit or restrict, use of your personal information;
• right to access and/or take your personal information: you can ask us for a copy of your personal information in machine readable form;
• access information we hold about you.

6.2 If you request us to view, change and remove your data associated with your account, please contact us at info@enway.com. We will process your request within 15 business days. In accordance with the applicable laws, additional fees may be applied.

7. Changes to the Privacy Policy

7.1 We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make major changes in the way we collect or use information, we will notify you by posting an announcement on the Website or sending you an email.

8. Merge of Company

8.1 If ENWAY merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

9. Data Retention

9.1 We retain your personal information in Belarus. We retain your personal information for as long as we need it to fulfil the purposes for which we originally collect it or as needed to provide with our services, except if required otherwise by law. In some cases we may determine the period of data retention based on the period we need to access the data for the provision of services, receiving payment, or for any other auditing or legal purposes.

10. Additional Information for California Residents

10.1 In this section we describe how we handle personal information of California residents under the California Consumer Privacy Act (“CCPA”). This clause covers personal information that we collect, share and use for the last 12 months.

10.2 We describe the personal information that we collect in section 1 “Data Collected”. The section 2 “Use of the Data” contains information on how we use personal information.

10.3 We share certain personal information in accordance with section 5 “Sharing of Data”. However, we do not sell your personal information to third parties.

10.4 In accordance with the CCPA, California residents are entitled, in addition to other rights described in this Privacy Policy, to:

10.4.1 Request deletion. You have the right to request deletion of your personal information that we collect from you;

10.4.2 Request copy. You have the right to ask for a copy of all or part of personal information that we retain about you over the last 12 months;

10.4.3 Designated agent. You are entitled to designate an agent who is able to make requests on your behalf. The agent should access your account to make a request.

10.4.4 List of service providers. You have the right to request a list of third parties with whom we shared personal information (if any) and what kind of information we shared during the previous calendar year.

10.5 If you want to exercise your rights, please contact us at info@enway.com.

10.6 ENWAY does not tolerate discrimination. The quality of our services is equal for all our customers, irrespective of whether you decide to exercise your rights under the CCPA.

11. Contact us

11.1 Should you have any question or concern, please email us at info@enway.com.