Privacy Policy

                                                                                                                    

1.     Introduction

Enjay cares for personal privacy. As the Data Controller, we are responsible for processing your personal data. This privacy policy describes what information we collect, how we collect that information, and how you can control it.

We do not process more personal data than is needed for the purpose and always strive to use the least integrity-sensitive data. Enjay saves information during the time that there is a business relationship, as long as it is necessary to fulfil the purpose of storing the data, and as long as there is an obligation to save the data by law/regulation. When your personal data is no longer required in connection with the purpose, we are no longer lawfully entitled to process it.

If you want to exercise your rights, have questions or complaints regarding Enjay's processing of personal data please contact us on below contact details. It is of course also possible to report complaints directly to The Swedish Privacy Protection Authority, Integritetsskyddsmyndigheten | IMY.

Company: Enjay AB
Address: Lockarpsvägen 6b, 213 76 Malmö
Corporate identity number: 556865-3751
E-mail: privacy@enjaysystems.com
Phone: +46 40-12 33 30

2.     General

2.1 Emails

Purpose: To be able to give support, answer questions, and communicate with potential, current customers and other stakeholders.

What kind of personal data: Name, e-mail address, phone number, company name and address.

Legal basis: Legitimate interest  assessment. We have an interest in processing personal data to satisfy your requests, to create and maintain contact, give you support and protect our rights.

Storage period: The personal data is collected when we receive the e-mail. The actual e-mail will be deleted after two (2) years. Exceptions: E-mails containing sensitive information will be deleted immediately. E-mails containing data needed to fulfil the Accounting Act can be saved for seven (7) years. E-mails containing data needed to be saved for warranty matters and potential dispute, can be saved for ten (10) years.

2.2 Contact via social media

Purpose: To be able to receive and communicate with people who are interested in Enjay.

What kind of personal data: Name, email address, telephone number, company name. 

Legal basis: Legitimate interest  assessment. We have an interest in processing your personal data to respond to your questions in the best way.

Storage period: The personal data is collected when we you contact us, the storage time determined by the respective contact purpose. Note that the social media that provide the platform in some cases and for their own purposes can continue to process your data according to the user agreement you have with them.

2.3 Online contacts via contact form

Purpose: To be able to respond to your request for contact.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: Consent.

Storage period: The personal data is collected when you fill in the contact form on our website, Linked-in or another digital channel where we have advertised. You can recall you consent at any time.

2.4 Online contacts via downloadable material

Purpose: To provide information about our product.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: Consent.

Storage period: The personal data is collected when you download information from our webpage, LinkedIn or another digital channel where we have advertised. You can recall you consent at any time.

2.5 Offline contacts

Purpose: To be able to respond to your request for contact.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: Legitimate interest  assessment. We have an interest in processing personal data to satisfy your request.

Storage period: The personal data is collected when you contact us via the phone, e-mail, or hand us your business card.  If we have not had any interaction with you for period of two (2) years, we will delete you from the system. If you object to the treatment, or if we don’t see the use of keeping your data we will delete them earlier.

2.6 Purchased contacts

Purpose: To provide information about our product.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: Legitimate interest  assessment. Enjay has an interest to spread information about the product's benefits. In most cases of bought contact lists you have already consented to be a part of the list; in that case we are not the Data Controller. But there is a possibility that we buy a list where you have not consented to exist.

Storage period: The personal data is collected when Enjay buys a list of contacts from company that provides contact information about stakeholders that can be interested of our product.  If we have not had any interaction with you for period of two (2) years, we will delete you from the system. If you object to the treatment, or if we don’t see the use of keeping your data we will delete them earlier.

2.7 Our spontaneous contact

Purpose: To provide information about our product.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: Legitimate interest  assessment. Enjay has an interest to spread information about the product's benefits.

Storage period: The personal data is collected when Enjay finds a contact that Enjay thinks will be interested to receive information. If we have not had any interaction with you for period of two (2) years, we will delete you from the system. If you object to the treatment, or if we don’t see the use of keeping your data we will delete them earlier.

2.8 Newsletter

Purpose: To provide information about our product.

What kind of personal data: Name, email address, telephone number, company name.

Legal basis: If you fill in our contact form or download information the legal basis is consent. In other cases, the legal basis is Legitimate interest  assessment, Enjay has an interest to spread information about the product's benefits.

Storage period: The personal data is collected in cases 2.3-2.7 mentioned above. You can unsubscribe from e-mails at any time through the link at the bottom of each email.

2.9 Contact information to our customers, partners and retailers

Purpose: To enable collaboration across company boundaries and to be able to have a fixed point of contact.

What kind of personal data: Depends on the information we need to fulfil the purpose, can be name, position, address, email address, telephone number and company name

Legal basis: Legitimate interest assessment. Enjay has an interest to keep in contact with you.

Storage period: The personal data is collected when we start to negotiate an agreement or when entering an agreement. The processing of the data will be terminated when the cooperation ends, or if we receive a change of contact person.


2.10 Book keeping and accounting

Purpose: To be able to process invoices and other accounting documents.

What kind of personal data: Name, invoice reference, company details, invoice documents and accounting documents.

Legal basis: Legal obligation.

Storage period: The personal data is collected at the conclusion of the agreement and is then saved for seven (7) years in accordance with the Accounting Act.

3. Job seeker and reference person

3.1 Application for advertised position

Purpose: When you apply for a job with us, we save your information to manage the recruitment.

What kind of personal data: Depends on the information you provide us, can be name, address, e-mail address, telephone number, date of birth, curriculum vitae, education, skills, previous workplaces, personal letter. (please no dot provide us with information about your social security number and/or sensitive information).

Legal basis: Legitimate interest  assessment. We have an interest in processing personal data to handle your application and to be able to assess which candidate best meets our competence profile.

Storage period: The personal data is collected when we receive the job application. If needed to fulfil obligations according to the discrimination legislation we can save your information for up to two (2) years.

3.2 Spontaneous application

Purpose: You can register your interest to work at Enjay without applying for an advertised position. To be able to receive your request and communicate with you, we need to handle your data.

What kind of personal data: Name, address, e-mail address, telephone number, date of birth, curriculum vitae, education, skills, previous workplaces, personal letter and CV. (please no dot provide us with information about your social security number and/or sensitive information).

Legal basis: Legitimate interest assessment. Enjay has a legitimate interest in processing your personal data for your spontaneous job application in order to satisfy your wishes.

Storage period: The personal data is collected when we receive the job application. If needed to fulfil obligations according to the discrimination legislation we can save your information for up to two (2) years.

3.3 Opinion from a reference person

Purpose: To o be able to contact a specified reference person who has previously worked with the job seeker or can otherwise comment on the job seekers competence, personality, and work experience.

What kind of personal data: Name, e-mail address, phone number, company name.

Legal basis: Legitimate interest assessment. To contact you in order to obtain an opinion about the candidate in connection with the recruitment process.

Storage period: The personal data is collected when we receive your contact details. If needed to fulfil obligations according to the discrimination legislation we can save your information for up to two (2) years.

4.     Employees

Enjay has a separate privacy policy for employees

5.     How we protect your information

Our working methods, procedures and IT policies are designed to safely process your personal data.

Only persons within Enjay who need the personal data to perform their duties have access to them.

Our security systems have a very high degree of protection against intrusion, destruction and other changes that may pose a risk to your privacy.

Our security measures are continuously improved in line with technological developments.

6. Transfer of personal data

6.1 To be able to deliver our products

It is necessary that we share some personal information with our partners, mainly contact information, to complete the project. In cases where we transfer personal data, we establish confidentiality agreements.

6.2 Legal obligations

Your personal data can also be disclosed for Enjay to be able to comply with certain legal obligations. They may also be transferred to relevant authorities when this is permitted and necessary by law.

6.3 IT systems and software provided by third party suppliers

Suppliers may process your personal information when they provide services to us. However, these third-party suppliers are processors and only process your personal information according to our instructions. Enjay ensures that a personal data processing agreement or equivalent arrangement is in place with these partners and that they meet all the requirements set out in current data protection legislation.

6.4 Business Transactions

If all or parts of Enjay's business is sold or integrated with any other business or company, your personal information can be forwarded to our advisors, potential buyers and their advisors and transferred to the new owners of the company operations.

6.5 Outside the EU/EEA

In cases where Enjay uses, or will use, subcontractors or cooperates with partners established outside the EU/EEA area, we are responsible for ensuring that these actors can guarantee a level of security equivalent to that maintained within the EU. In order to ensure adequate protection for your personal data when transferred to countries outside the EU/EEA when there is no decision on an adequate level of protection from the European Commission, Enjay has, in applicable cases, entered into agreements with the respective recipients of personal data containing standard contractual clauses decided and approved by the European Commission (EU) 2021/914.

7. Your rights

Since this policy is about how your personal information is processed, we also want you to know what rights you have, your rights are listed below. Normally, rights can be exercised free of charge. We will respond to a request from you without undue delay, normally within one (1) month. If we for some reason need more time, or if we cannot meet your request, we will inform you. We may also request additional information from you if it is required for us to be able to confirm your identity and ensure that it is you and not someone else who tries to gain access to or control the personal information.

7.1 Registry extract

You have the right to get a registry extract of which categories of personal data that are processed about you.

7.2 Rectification

If the data we process about you is incorrect, you have the right to have the data corrected.

7.3 Right to object

You have the right to object to the processing of personal data based on our legitimate interest. If you make such an objection, Enjay will make an overall assessment between our legitimate interests and your interests and fundamental rights.

7.4 Right to limitation of treatment

You have the right to request that we temporarily limit the processing of your personal data. Should e.g. be current;

  • during the time it takes us to check that your details are correct.
  • during the time it takes us to check whether our legitimate interest  assessment in a treatment outweighs your interests and fundamental rights.
  • to enable you to establish, assert or defend legal claims.
  • if the processing is illegal but you want the processing to be restricted instead of deleted.

7.5 Right to be deleted

You have the right to request deletion of your personal data;

  • if the treatment is based solely on your consent and you withdraw the consent.
  • if you oppose treatment that takes place after a legitimate interest  assessment and there are no legitimate reasons that weigh heavier than your interest.
  • if the processing of your data has not followed the applicable law.
  • if deletion is required to fulfil a legal obligation.

In some cases, however, we cannot accommodate a request for deletion, for example if we are required by law to save the data.

7.6 Right to data portability

This right applies to any personal data that you have provided to us based on your consent or if the treatment is based on a business agreement with us. If so, you have the right to get your personal data in a digital format to use elsewhere.

8. Internal practices

8.1 Security & privacy

We have internal policies in place to support our employees with dos and don’ts when handling customer data. All Enjay employees receive security and privacy training during on-boarding and on an ongoing basis.

8.2 Device management

We enforce and implement security measures on employees’ workstations and mobile devices

9. Change of privacy policy (version 1.7)

If this privacy policy undergoes a major change, we will send you a message; by e-mail, inform via a pop-up in the app/on the web, or send a SMS message to you. In some event, we will inform you in advance, and your continued use of the webpage and/or app after the changes will constitute your acceptance of the changes. Therefore, we kindly advise you to ensure that you read all such messages carefully.