1. General

1. This website is operated by Entigo OÜ (“Entigo” or “we”). Entigo recognizes the importance of your privacy and is committed to protecting your personal data. This privacy notice (“Notice”) explains the principles on how Entigo collects and uses information when you visit the following website: https://www.entigo.com/ („Website“).

2. Entigo processes your personal data as described in this Notice and in accordance with applicable legislation, including the European Union’s General Data Protection Regulation (2016/679) and the national data protection laws of the Republic of Estonia, as applicable towards the personal data controller stated in Section 2 of this Notice.

3. In case you disclose any personal data regarding any third person (e.g. your employee, management board member, co-worker, etc.) to us, you are obligated to refer them to this Notice

2. Personal Data Controller

1. For the personal data processing purposes brought out in Section 4 of this Notice, the controller of your personal data is:
   • Entigo OÜ
   • Registry code: 11677579
   • Address: Veerenni tn 38, 10138 Tallinn, Estonia
   • E-mail: info@entigo.com

3. Categories and Sources of Personal Data Entigo Collects and Processes

1. Personal data are information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us.

   1. Training data. Entigo processes the following data related to your inquiry related to the training program: full name, e-mail address, the organisation you work in / represent, position / role, the selected training program, the number of participants and additional information you leave as a note. („Training Data“) Source: Personal Data you directly provide to Entigo upon submitting the registration form.

   2. Contract Data. Entigo processes the following data related to entering into contract with the organisation you work in / represent: full name, e-mail address, position / role. (“Contract Data”) Source: Personal Data you directly provide to Entigo upon submitting the registration form or the Personal Data provided to us by your organisation.

   3. Communication data. Entigo processes the following data if you interact with Entigo via Website’s contact form or e-mails: full name, phone number, contents of your message, e-mail address. („Communication Data“) Source: Personal Data you directly provide to Entigo.

   4. Marketing data. Entigo processes the following data for marketing purposes: name, e-mail address, information on your previous use or interest in our services. („Marketing Data“) Source: Personal Data you directly or indirectly provide to Entigo whilst using the Website.

   5. Public data. Entigo processes the Personal Data that you have made publicly available. (“Public Data”) Source: Entigo utilises the Smart Contract Data functionality provided by Pipedrive, which finds publicly available information associated with your e-mail address or e-mail domain.

   6. Technical data. Entigo processes the following data when you visit the Website: IP address (including location based on the IP address), access-provider, referring URL, date, time, access tokens, session key, browser type and version, operating system, amount and state of transferred data, MAC-address, etc. (“Technical Data”) Source: While you are browsing through the Website, the Website itself generates or collects the Technical Data from your device automatically.

   7. Cookie data. Entigo implements cookies on the Website, for optimising the Website and its functionalities. The cookies may collect your Personal Data. For further information, please see Entigo’s cookie notice: […]. („Cookie Data“)

2. If you fail to provide necessary information, Entigo is not able to answer to your inquiries in regard to the training programmes or fulfil any other purposes provided in Section 4 of this Notice.

4. Legal Basis and Purposes for Processing the Personal Data

1. Entigo’s legal basis to process your Personal Data depends on the objective and context in which we collect the Personal Data. For easier understanding, we have grouped all objectives and data categories for processing the Personal Data with the following legal grounds: performance of a legal obligation, performance of a contract, Entigo’s legitimate interest and your consent.

2. The following depicts a non-exhaustive list of processing purposes that are linked to the specific data categories and legal basis for processing:

Processing purpose	Legal basis for the processing purpose	Categories of personal data used by us for the processing purpose
Contacting via e-mail on phone for the purposes of sharing information about our services	Consent	Marketing Data, Public Data, Cookie Data
Displaying you tailored marketing content based on your preferences	Consent	Marketing Data, Cookie Data
Handling your registration inquiries in regard to the training programmes and sending you offers in regard to our services	Performance of a contract between the organisation you work in / represent and Entigo or taking pre-contractual measures	Training Data, Public Data, Contract Data
Providing the services ordered under the contract between the organisation you work in / represent and Entigo	Performance of a contract between the organisation you work in / represent and Entigo or taking pre-contractual measures	Training Data, Public Data, Contract Data
Enabling communication between you and Entigo	Entigo’s legitimate interest in providing effective customer relations management	Communication Data, Public Data
Analysing statistical data regarding the usage of the Websites; market research	Entigo’s legitimate interest in analysing the functioning of the Website for its business development	Technical Data, Cookie Data
Diagnose and repair problems with the Website; ensuring the safety of the Website by detecting interfering actions	Entigo’s legitimate interest in ensuring the safety of data processing, the Website	Training Data, Communication Data, Marketing Data, Public Data, Technical Data, Cookie Data
Storing information containing Personal Data in Entigo’s backup systems	Entigo’s legitimate interest in ensuring the security of data processing operations	Training Data, Communication Data, Marketing Data, Public Data, Technical Data, Cookie Data

5. Personal Data Retention Period

1. Your Personal Data (all data categories mentioned in Section 3.1, except for Cookie Data) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 4 of this Notice, or until the legal obligation stipulates that we do so. The following is a non-exhaustive summary with examples on storing your Personal Data:
   1. Contract Data will be retained for up to 7 years as of the termination or expiry of the contract concluded between the organisation you work in / represent and Entigo;
   2. Marketing Data will be retained until you withdraw your consent for receiving marketing information;
   3. Training Data and Communication Data will be retained for up to 5 years as of the end of the calendar year the communication was registered;
   4. Public Data will be retained until the termination or expiry of the contract concluded between the organisation you work in / represent and Entigo.
2. After the retention period mentioned in Section 5.1 of this Notice, we might either retain your Personal Data for longer period if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes and enforce the contract between you and Entigo or anonymize your Personal Data and retain this anonymized information indefinitely.
3. After the expiry of the retention period referred to in Section 5.1 of this Notice or the termination of the legal basis for processing purpose, Entigo may retain the materials containing the Personal Data in the backup systems, from which the corresponding materials will be deleted after the end of the backup cycle. Entigo ensures that during the backup period, appropriate safeguards are applied to the materials in the backup. The backed-up materials are put beyond the use, i.e. are not processed for any other purpose, and the materials are deleted by Entigo as soon as possible, i.e. after the end of the Entigo’s backup cycle, the Personal Data will be destroyed.

6. Your Rights as a Data Subject

1. We have a legal obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your Personal Data that we are processing.

2. You may, at any time, exercise the following rights with respect to our processing of your Personal

   1. Data by contacting us via contact information referred to in this Notice: Right to access: you have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing;
   2. Right to rectification: you have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete;
   3. Right to object: you are entitled to object to certain processing of Personal Data, including for example, making automated decisions based on your Personal Data or when we otherwise base the processing of your Personal Data on our legitimate interest;
   4. Right to restrict Personal Data processing: you have the right to request that we restrict the processing of your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of Personal Data; (iii) receive or avoid deletion of Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of Entigo’s legitimate interest in the specific processing activity;
   5. Right to erasure: you may also request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement;
   6. Right to data portability: if your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;
   7. Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time;
   8. Right to submit your claim with the supervisory authority: if you are not satisfied with our response to your request in relation to Personal Data or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim with the Estonian Data Protection Inspectorate (in Estonian Andmekaitse Inspektsioon) at info@aki.ee (https://www.aki.ee/).

3. Please note that you will need to provide sufficient information for us to handle your request regarding your rights brought out in Section 6.2 of the Notice. Prior to answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request.

7. Sharing Your Personal Data and Data Transfers

1. Entigo discloses your Personal Data to third parties only in accordance with this Notice and to persons authorised to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. In specific cases, Entigo will only share your Personal Data with a third party if you have given consent to such disclosure.

2. Only if necessary for fulfilling its statutory or contractual obligations, Entigo may disclose your Personal Data to the following recipients in its data processing activities.

Type of the recipient	Purpose of disclosure	Location of the recipient
Law enforcement and data protection authorities	Entigo discloses your Personal Data to law enforcement and data protection authorities only if we are under a duty to disclose or share these data in order to comply with any legal obligation (for example, if required to do so under applicable law, by a court order or for the purposes of prevention of fraud or other crime)	European Union
Operational service providers (legal advisors, accounting etc. bound to confidentiality)	In case not operating as data processors, the legitimate interests in ensuring the functioning of the Website; conducting of regular business activities, e.g. financial analytics, transactional e-mail service	European Union
Legal advisors, (potential) business acquirers, business transferee(s)	If necessary and required for successfully transferring the Entigo’s business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to the specified acquirers	World-wide
IT-service providers	In case not acting as data processor, for providing IT solutions necessary for daily business functions	European Union and USA

3. In addition to the third parties brought out in Section 7.2 of the Notice, we may transfer Personal Data to third party service providers who act as data processors and may operate the technical infrastructure that we need to host, store, manage and maintain the daily business. The following depicts a list of authorised processors, their location and their reason for processing.

Authorised processor	Processing purpose	Safeguard	Location
IT-service and application providers	Providing IT-solutions necessary for the daily business functions (e.g. Amazon Web Services, Google)	Data processing agreements, standard contractual clauses, EU-U.S. Privacy Shield, if necessary	World-wide
Analytics and marketing software service providers	Providing analytical insight and marketing tools for bettering daily business functions (e.g. MailChimp)	Data processing agreements, standard contractual clauses, EU-U.S. Privacy Shield, if necessary	EU/EEA and/or U.S.
Sales customer relations management software	Assisting sales customer relations management functions (e.g. Pipedrive)	Data processing agreements, standard contractual clauses, EU-U.S. Privacy Shield, if necessary	World-wide

4. In some cases, we may transfer your Personal Data outside the European Union or European Economic Area, if the respective operational services are provided outside the European Union or European Economic Area. We shall opt to use special Personal Data protection safeguards, in order to ensure the safety of your Personal Data. You have the right to get acquainted with or obtain information on the transferring of your Personal Data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Notice.

8. Amendments to This Notice

1. This Notice may be amended or modified from time to time to reflect changes in the way we process Personal Data and, in such case, the most recent version of the Notice will appear on this page. Please check back periodically, and especially before you provide any new personally identifiable information.