Enlighted Privacy Statement

    Last Updated: March 8, 2019

    Your privacy is important to Enlighted. Our goal is to meet a high standard for protecting the privacy of your information. We want to be clear about how we collect, use, protect, and share your information, including your personal information, and the rights and choices you have about the ways in which you can help us protect your privacy.

    Compliance

    Enlighted complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Enlighted has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

    Personal Data Enlighted Collects

    Enlighted collects data from you through our interactions with you and through our products. The data we collect depends on the context of your interactions with Enlighted and the choices you make, including your privacy settings and the products and features you use. You provide some data to us directly, we collect data about your interactions with Enlighted and through the use of our products, and we obtain data about you from third parties.

    When you interact with us, we collect information sent to us by your device. The information we collect may include data about the pages you access, your computer IP address, device ID or unique identifier, device type, geolocation information, computer and connection information, and mobile network information.

    You have choices about the technology you use and the data you share with us. When we ask you to provide Personal Data, you may decline. However, many of our products require some Personal Data to provide you with a service. If you choose not to provide that necessary data, you will not be able to use that product or feature. Similarly, where we need Personal Data by law or to enter into or carry out a contract with you, we will not be able to proceed if you do not provide the data. We will let you know if not providing the personal information will result in our inability to provide you with a product or service. In cases where providing Personal Data is optional, certain features like personalization will not work if you choose not to provide the Personal Data.

    Applicants’ Personal Data

    If you are applying for a job with Enlighted, we collect additional information related to your employment application. We use the Personal Data you have provided to make employment decisions. We also use your data to comply with our legal obligations, such as applicable immigration or employment laws, privacy or security practices of our customers, partners, or vendors, which may differ from Enlighted’s privacy policy.

    At your request, we may disclose your Personal Data to third parties for employment screening, background checks, credential verification services, or other similar services related to verifying the accuracy of the information you have provided. If you do not want your Personal Data, (including test results or background checks) used as described here, you should not provide us with your Personal Data. Not providing the Personal Data will preclude you from proceeding with your Enlighted job application.

    How Enlighted Uses Personal Data

    • Provide our products and services, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when necessary to provide the service or other transaction you have requested.
    • Improve and develop our products.
    • Personalize our products.
    • Advertise and market to you, which includes sending promotional communications and targeting advertising.

    We also use the data for our business purposes, including analyzing our performance, meeting our legal obligations, and developing our workforce. To achieve these purposes, we may combine data we collect from different contexts to give you a better experience, to make informed business decisions, and for other legitimate reasons.

    Reasons We Share Personal Data and our Accountability

    We share your Personal Data (when you have approved such sharing) to complete transactions, or to provide a product you have requested. We may also share data with Siemens (Enlighted Parent Company), Siemens’ affiliates and subsidiaries, with service providers working for us, when required by law or legal process, to protect lives, to maintain the security of our products, and to protect the rights and property of Enlighted and its customers.

    Enlighted may disclose Personal Data to trusted third parties as indicated in the Privacy Policy without offering an opportunity to opt out. Enlighted requires that its agents and service providers that have access to Personal Data within the scope of this Privacy Policy provide the same level of protection as required by the Privacy Shield Principles. We ensure that our agents process Personal Data received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

    In the case of Enlighted sharing Personal Data with a third-party service provider that processes the data solely on Enlighted’s behalf, Enlighted will be liable for that third party’s processing of Personal Data in violation of the Privacy Shield Principles, unless Enlighted can prove that it is not responsible for the event giving rise to the damage. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield and Swiss-US Privacy Shield, Enlighted is potentially liable.

    How to Access and Control Your Personal Data

    You have choices about how Enlighted collects and uses your data. You can exercise your data protection rights by contacting Enlighted. You have certain rights, including to access, correct, erase, object to, or restrict our use of your Personal Data. You may also withdraw your consent for our use of your personal information, if applicable. In some circumstances, you may request a copy of your personal information in a usable electronic format. In some cases, your access or control of your Personal Data may be limited, where required or permitted by applicable law. Where applicable, you may also lodge a complaint with your local data protection authority.

    International Transfers of Data

    Enlighted is a global organization with its headquarters in the United States. We may share your personal information with Siemens (Enlighted Parent Company), Siemens’ affiliates and subsidiaries, and with third party service providers working for us that may be outside the country in which you reside. We have put in place appropriate safeguards to handle the transfers of data to ensure that your personal information is handled as described in this policy.

    In compliance with the Privacy Shield Principles, Enlighted commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Policy should first contact Enlighted as listed in the Contact Us section of this policy. To learn more about the EU-U.S. Privacy Shield and the Swiss-US Privacy Shield, please visit the Privacy Shield website at https://www.privacyshield.gov. and to view our certification, please visit https://www.privacyshield.gov/list.

    Enlighted has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. Enlighted is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

    Cookies

    Cookies are small text files placed on your device to store data. We use cookies and similar technologies for storing your preferences and settings, enabling you to sign in, providing advertising, combating fraud, and fulfilling other legitimate business purposes. Sometimes, we also use web beacons to gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third party providers.

    You have options to control the data collected by cookies, web beacons, and similar technologies. For example, you may use settings in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. At this time, Enlighted does not respond to Do Not Track (DNT) signals.

    Products Provided by Your Organization

    If you use an email address provided by your employer or another organization to access Enlighted products, that organization has the ability to control and administer your Enlighted product account, as well as the ability to access and process your data.

    Many Enlighted products are intended for use by organizations, such as businesses. If your organization provides you with access to Enlighted products, your use of the Enlighted products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. Enlighted is not responsible for the privacy or security practices of our customers, partners, or vendors, which may differ from Enlighted’s privacy policy.

    How Long We Retain Your Personal Information

    Generally, we will keep your Personal Data for the duration of our relationship with you. After our relationship ends, we will retain your personal information for a period of time that permits us to satisfy the following purposes: record retention as may be required by applicable law, for use in a legal claim or proceeding, to address any complaints we receive regarding our products or services, or other legitimate business reasons.

    How We Protect Your Personal Information

    The security of your Personal Data is important to us. We use appropriate technical and organizational measures to protect the security of your data.

    Updates to Our Privacy Policy

    From time to time, we may modify or update this policy. You can see at the top of the policy when it was last updated. Any changes to our policy are effective as of the date we post such changes, unless we inform you otherwise. If we modify our policy in a way that will have a substantial impact on the nature of processing or your privacy rights, we would provide sufficient advance notice to provide you with an opportunity to exercise your rights.

    Contact Us

    Questions regarding the Enlighted Privacy Policy or the practices of our website should be directed to privacy@enlightedinc.com or by regular mail addressed to:

    Enlightened, Inc.
    Attn: Privacy
    930 Benecia Ave.
    Sunnyvale, CA 94085

    To view Enlighted’s previous Privacy Policy, click here.