Cookie and Privacy Policy

(last updated: January 26, 2016)
enepath is a corporate group headquartered in Singapore. It offers products and services to clients around the world through companies including enepath Global Holdings Pte. Ltd., enepath (Singapore) Limited, enepath (Hong Kong) Limited, enepath (Americas) LLC and enepath (EMEA) Ltd.
Our business involves providing Advanced Media Platforms, including trading turrets and other voice solutions to our customers (usually financial institutions) to help them manage their voice communications with customers, co-workers and partners, integrating voice trading systems, compliance systems, the back office and supporting data systems. Our solutions include speakers, voice recording, intercom and hoot-and-holler capability and related support and consultancy services.
This policy is divided into the following sections:
This section of this policy applies to our customers and prospective customers and their staff and representatives.

Personal information and how it is collected and used

enepath collects information on certain individuals from its clients, end users of our products/services, and individuals within our clients with whom we interact.

The personal information held by us includes names, contact details, user names, passwords, positions held, employers, information about use of our products and services and other information that can be used to identify individuals or their attributes.

When you provide personal information about other individuals to us, we rely on you to inform those individuals that you are providing their personal information to us and to advise them that we can be contacted for further information (see ‘How to contact us’ at the end of this policy).

enepath collects personal information in a number of ways, including:
 directly from you, for example, when you provide information by phone, in application forms or other agreements;
 from our records of how you use enepath services;
 from third parties such as our related companies, distributors, credit reporting agencies, your representatives;
 from the organisations listed below under ‘Disclosure of personal information’;
 from publicly available sources of information; and
 when you visit our websites (see under ‘Our website and cookies’ below).

The personal information collected may be used:
 to provide our services to the company that you represent, including to provide related support and consultancy services;
 to administer and manage those services;
 to inform you of possible improvements to the services provided to the company you represent;
 to gain an understanding of your and your company’s needs, and to research and develop our services;
 in order for us to provide the company you represent with a better service; and
 to maintain and improve our systems, including monitoring, testing and upgrading.

If you choose not to provide certain personal information, we may not be able to provide you with the services you or your company require, or the level of service on which we pride ourselves.

Personal information is also collected so that enepath and its related entities may market to you and your company (this may be via e-mail, websites, personal interaction, social media, or other methods). This is to keep our clients’ representatives informed of enepath’s products, services and offerings. If you do not wish to receive communications of this sort, please contact us as set out below with your request or follow the instructions in the communications themselves.

Disclosure of personal information

In order to deliver the services your company requires or expects of enepath, we may disclose your personal information to third party organisations so that we can provide our services to you. This includes our contractors and service providers who provide services including:
 customer enquiries;
 installation, maintenance and repair services;
 information technology and network services;
 mailing operations;
 billing and debt-recovery functions;
 market research, marketing and telemarketing services; and
 website usage analysis.

We take steps (e.g. contractual controls) to protect personal information where we disclose it to our contractors and service providers.

We may also disclose personal information:
 to your authorised representatives or your legal advisers (e.g. when requested by you to do so);
 to credit-reporting and fraud-checking agencies;
 to enepath’s related companies and authorised distributors (who may offer products or services to a company that you represent);
 to enepath’s professional advisers, including our accountants, auditors and lawyers;
 to law enforcement and national security agencies, and other government and regulatory authorities;
 to other third parties as required or authorised by law;
 to organisations which assist us to manage or develop our business and corporate strategies and functions, including our corporate risk or funding functions; and
 for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business.

If you are a customer or other individual interacting with one of our customers (e.g. you are a client of an investment bank), this section applies to you.

Some of enepath’s products and services incorporate recording capabilities that allow our customers and other users to record, store and search the contents of voice calls or other communications. Although enepath may use such capabilities in the course of installing, testing or demonstrating its products or services, personal information obtained and held through recordings made by customers of enepath or other users of its products are services are the responsibility of and subject to the privacy policies of such customers or users. Please contact your financial institution, trader or other organisation if you have any questions about the information they collect and hold about you.

To the extent that enepath does have access to your personal information in these circumstances, we may access and handle that information in order to provide our products and services (e.g. by providing technical support) and as required by law.

We do not use that information to send unsolicited direct marketing to you.
From time to time, we engage third party contractors to provide support services in relation to particular products and services, and we take steps (e.g. contractual controls) to protect personal information we disclose to them.

Our website
If you visit our website under the domain name, our system may record information such as your IP address, device details and identifiers, top level domain (e.g. .com, .au, etc), date and time of your visit, pages accessed, information downloaded, previous site visited and browser type. This information is used for statistical, reporting and website administration and maintenance purposes, and for the other purposes described in this policy.

What are cookies?
Cookies are small, encrypted, text files that websites may place on your computer.
Websites use cookies to improve the use of the site with tools like remembering login details, what content the user is interested in and other preferences in general.
Cookies are used by most major websites. While you browse those sites we can use cookies to gather information about your website use, such as the amount of time you spent on each site, your content preferences and user ID details. This information is then sent back to the originating website and other authorised services each time you revisit these sites.
On some of our websites we use cookies to record advertisements you viewed and this can influence which advertisements are presented to you.
If you are concerned about the use of cookies, there are several ways to delete and/or block cookies.
You can choose to delete (or ‘clear’) all the cookies currently stored by your browser via your browser tools. You can also use your browser tools to block and permanently disable cookies. This will prevent you from using all services that rely on cookies until you allow your browser to start accepting cookies again. It will also prevent some types of digital advertising from occurring.
Alternatively, you can download tools which will increase your awareness of which cookies are being left on your computer and decide which cookies to permit and which to block.
Your rights

Under the laws of some countries you may have the right to access, correct and object to the processing of personal information we hold about you, subject to some exceptions. If you would like to do so, please contact us as set out below.

If you are a customer of an enepath customer and require access to personal information that we may store on behalf of an organisation that is an enepath customer (e.g. a financial institution), you should approach that organisation directly in the first instance. We may charge a fee (subject to applicable law) for providing such access.

Additional notice for California residents

If you are a California resident, you may contact us as set out below to request a list of the types of personal information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and the names of those third parties. The list will not be specific to any disclosure your particular personal information, may not apply to all enepath companies and is subject to the other limitations of California Civil Code §1798.83.
Our locations

We have operations in USA, UK, Hong Kong, Singapore and the United Kingdom. We may disclose personal information to parties in those countries, Japan, other countries within Europe and other countries. You accept that where lawful such obligations may be less stringent than the requirements of the privacy laws of your country.

Storage and security of personal information

We may store personal information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.

We retain personal information for as long as necessary to fulfill the purposes described in this policy and deal with disputes unless a longer period is required or authorised by law.

We take the privacy and confidentiality of your personal information seriously, and have implemented a range of measures to protect that information including, depending on the circumstances, encryption, system access controls, network security, site security and enabling our customers to make their own data-hosting arrangements in connection with use of our products and services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to us electronically; any transmission is at your own risk. Once we have received your information, we will use appropriate technical and organisational measures to try to prevent unauthorised access to, loss or destruction of your personal information.

How to contact us

If you have any questions in relation to this policy, please contact us as set out below:
Contact: Privacy Officer
Address: enepath Global Holdings Pte. Ltd
10 Anson Road, International Plaza #18-08
Singapore 079903
Phone: +65-6812-0519

You may also use these contact details to notify us of any privacy concerns you have regarding our handling of your personal information. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.