Data Collection Policy
Types of Personal Data that enRoute View Media Inc. (“enRoute”) collects, by itself or through third parties, there are: email address, Cookies, Usage Data, various types of Data and geographic position.
Personal Data may be freely provided by the Customer, or, in case of Usage Data, collected automatically when using “enRoute” software.
Unless otherwise specified, all Data requested by “enRoute” is mandatory and failure to provide this Data may make it impossible for “enRoute” to provide its services. In cases where “enRoute” specifically states that some Data is not mandatory, Customers are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Customers who are uncertain about which Personal Data is mandatory are welcome to contact the “enRoute”.
Customers are responsible for any third-party Personal Data obtained, published or shared through “enRoute” and confirm that they have the third party’s consent to provide the Data to the Customer.
Data Processing Mode & Locations
Method of Data Processing & Management
The Customer takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Customer, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of “enRoute” staff or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Customer. The updated list of these parties may be requested from “enRoute” at any time.
Legal Basis for Data Processing
“enRoute” may process Personal Data relating to Customer if one of the following applies:
In any case, “enRoute” will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Location of Data Processing
The Data is processed at the “enRoute” operating offices and in any other places where the parties involved in the processing are located (Canada & USA).
Depending on the Customer’s location, data transfers may involve transferring the Customer’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Customers can refer to the section containing details about the processing of Personal Data.
Customers are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the “enRoute” to safeguard their Data.
If any such transfer takes place, Customers can find out more by checking the relevant sections of this document or inquire with “enRoute” using the information provided in the contact section.
Duration of Data Retention
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
“enRoute” may be allowed to retain Personal Data for a longer period whenever the Customer has given consent to such processing, as long as such consent is not withdrawn. Furthermore, “enRoute” may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Data Processing Purposes
The Data concerning the Customer is collected to allow “enRoute” to provide its Services, as well as for the following purposes: Access to third-party accounts, Customer database management, Registration and authentication, Analytics, Infrastructure monitoring, Handling payments, Remarketing and behavioral targeting, Hosting and backend infrastructure, Displaying content from external platforms, Data transfer outside the EU, Location-based interactions and Interaction with online survey platforms.
Customers can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Personal Data Processing Details
Personal Data is collected for the following purposes and using the following services:
This type of service allows “enRoute” to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the Customer.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of “enRoute”, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
“enRoute” is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Customers can inquire with “enRoute” to learn which legal basis applies to which specific service.
Data transfer abroad based on standard contractual clauses – “enRoute”
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by “enRoute” according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Customers are requested to contact “enRoute” through the contact details provided in the present document.
Personal Data collected: various types of Data.
This type of service allows you to view content hosted on external platforms directly from the pages of “enRoute” and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Customers do not use it.
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows “enRoute” to incorporate content of this kind on its pages.
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows “enRoute” to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Payment processing services enable “enRoute” to process payments by credit card, bank transfer or other means. To ensure greater security, “enRoute” shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the Customer, such as emails containing invoices or notifications concerning the payment.
Stripe (Stripe Inc.)
Stripe is a payment processing gateway which allows Customer to make online payments.
This type of service has the purpose of hosting Data and files that enable “enRoute” to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of “enRoute”. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Digital Ocean (DigitalOcean Inc.)
Digital Ocean is a hosting service provided by DigitalOcean Inc.
This type of service allows “enRoute” to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of “enRoute”.
Sentry (GetSentry, LLC)
Sentry is a app crash monitoring service provided by GetSentry, LLC.
“enRoute” may collect, use, and share Customer location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the Customer’s location data may be tracked by “enRoute”.
The geographic location of the Customer is determined in a manner that isn’t continuous, either at the specific request of the Customer or when the Customer doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data collected: geographic position.
By registering or authenticating, Customers allow “enRoute” to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, “enRoute” will be able to access some Data, stored by these third-party services, for registration or identification purposes.
This type of service allows “enRoute” to build user profiles by starting from an email address, a personal name, or other information that the Customer provides to “enRoute”, as well as to track Customer activities through analytics features. This Personal Data may also be matched with publicly available information about the Customer (such as social networks’ profiles) and used to build private profiles that “enRoute” can display and use for improving “enRoute”.
Some of these services may also enable the sending of timed messages to the Customer, such as emails based on specific actions performed on “enRoute”.
ZohoCRM (Zoho Corporation Pvt. Ltd)
ZohoCRM is a User database management service provided by Zoho Corporation.
Further information about Personal Data
The Personal Data collected are used to provide the Customer with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by “enRoute” depends on the payment system used.
Customers declare themselves to be adult according to their applicable legislation. Minors may use “enRoute” only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use “enRoute”.
Customer may exercise certain rights regarding their Data processed by “enRoute”.
In particular, Customer have the right to do the following:
Right to object to data processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in “enRoute” or for the purposes of the legitimate interests pursued by “enRoute”, Customers may object to such processing by providing a ground related to their particular situation to justify the objection.
Customers must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether “enRoute” is processing Personal Data for direct marketing purposes, Customer may refer to the relevant sections of this document.
Exercising the rights
Any requests to exercise Customer rights can be directed to “enRoute” through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by “enRoute” as early as possible and always within one month.
Data collection & processing
The Customer’s Personal Data may be used for legal purposes by “enRoute” in Court or in the stages leading to possible legal action arising from improper use of “enRoute” or the related Services.
The Customer declares to be aware that “enRoute” may be required to reveal personal data upon request of public authorities.
Additional information about Customer’s Personal Data
System logs and maintenance
For operation and maintenance purposes, “enRoute” and any third-party services may collect files that record interaction with “enRoute” (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from “enRoute” at any time. Please see the contact information at the beginning of this document.
“Do Not Track” Request Handling
“enRoute” does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the Customer’s consent, “enRoute” shall collect new consent from the Customer, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through “enRoute” (or third-party services employed in enRoute), which can include: the IP addresses or domain names of the computers utilized by the Customer who use “enRoute”, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the Customer, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the Customer’s IT environment.
The individual or Corporation using “enRoute” who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (“enRoute”)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of “enRoute”. The Data Controller, unless otherwise specified “enRoute”.
The service provided by “enRoute” as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the Customer’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).